Have you been noodling over the latest audit standards?
As a food processor or packaging company, you know how important it is to meet stringent pest management protocols at audit time. But with inconsistent requirements from one food safety auditor to another, understanding the differences may be daunting. The good news is, with the right preparation, your organization will be ready for the pest management portion of your next third-party audit. Here is some background on the major food safety and quality standards out there today.
GFSI
The Global Food Safety Initiative (GFSI) is a collaboration of global food safety experts from retail, manufacturing and foodservice companies and from food supply chain service providers. It is coordinated by The Consumer Goods Forum, the only independent global network for consumer goods retailers and manufacturers worldwide.
The GFSI framework – launched in Europe in May 2000 – has taken on added importance in recent years, especially since Wal-Mart became the first nationwide U.S. grocer to adopt GFSI standards in 2008. This move, in effect, put Wal-Mart’s vast supplier base on GFSI standards. GFSI does not undertake any accreditation or certification activities, but the GFSI guidance document contains commonly agreed-upon criteria for food standards, against which any food or farm assurance standard can be benchmarked. GFSI does not have any of its own standards but accepts the following global standards:
- SQF – Safe Quality Food
- BRC – British Retail Consortium
- IFS – International Food Standards
- Global GAP (HACCP based)
- ISO 22000
- None of the existing U.S. standards are accepted
BRC
Short for British Retail Consortium Global Standard for Food Safety, BRC is the UK’s equivalent to the Food Marketing Institute (FMI). U.S.-based organizations that need to adhere to the GFSI compliance have the option of accepting the BRC standards or SQF standards. BRC standards tend to be directed toward a facility with a pest management contractor outlining the best practices and requirements to meet their standards, while Safe Quality Food (SQF) standards offers a tiered registration process. While SQF has pest control standards that can be followed by a contracted pest control service provider, these are also geared toward an in-house pest control program. Because BRC focuses on a contractor relationship, the standards outline the need for senior management to review the pest management provider’s program. It also calls for an audit of the program to be conducted by someone other than the technician (this could be a supervisor or independent quality assurance staff member from the pest management company). For both SQF and BRC, it’s essential to read the details depending on which standards your facility must adhere to. For BRC, check out section 4.11 (Pest Control) of the standards.
SQF
Safe Quality Food (SQF) standards are managed by the Food Marketing Institute (FMI) and approve third-party auditors to perform certification audits. There are two codes for SQF standards:
- SQF 1000 : Geared to primary producers (e.g., farms)
- SQF 2000 : Manufacturers, processors, retail and foodservice, wholesale and distribution, food sector services (contact services)
- SQF Level 1: Food safety fundamentals
- SQF Level 2: Level 1 + HACCP-based food safety and pre-requisite programs
- SQF Level 3: Level 2 + quality systems
And, within each code, there are various levels:
U.S.-based organizations that adhere to SQF 2000-Level 3 standards are automatically in compliance with GFSI specifications. SQF standards are geared toward an in-house staff member who handles pest control. For example, SQF addresses the disposal of pesticides, which would not be an issue for a licensed contractor who would take care of that off-site.
SQF lists its pest control requirements in section 6.5 (Management of Pests and Vermin).
FDA
Food manufacturing and processing plants must adhere to food safety standards set forth by the federal government. The Federal Food and Drug Administration (FDA), United States Department of Agriculture (USDA) and enforce these regulations.
The FDA oversees all food manufacturing and processing plants except for those producing animal products including meat, poultry, eggs and egg products. The FDA also regulates food distribution centers, unlike the USDA. The FDA’s biggest concerns when it comes to pest management are that the foods are manufactured and processed in sanitary conditions, there is no contamination by pests, and pesticides are being used according to their EPA approved label use. Unlike the USDA, the FDA typically does not inspect plants on any schedule.
When violations occur, the FDA can issue a warning, a fine or shut down plants. The two principal portions that deal with pest control are in sections 402(a)(3&4) under Title 21 of the Code of Federal Regulations.
USDA
The USDA is a governing body that regulates all producers of animal-based food products, including meat, poultry, egg and egg production plants, under the Federal Meat Inspection Act and the Federal Poultry Inspection Act. Each facility is inspected by the Inspector in Charge (IIC) to make sure that federal regulations are being followed. The IIC is either a USDA contact based at the plant or who often visits – based on the size of the operation. The IIC has the final say on which products, including pesticides, can and cannot be used within a plant, and also reviews the pest control program.
USDA regulations around pest management are much more detailed than FDA guidelines, specifically when it comes to chemical usage. Only certain chemicals are allowed to be used – and under very specific conditions as described in the two Acts. All pesticides must be USDA-approved for the intended use, and the IIC must understand all regulations for pesticide application.