With the COVID-19 pandemic continuing to take a toll on live events, Innovative Publishing Company, Inc. has made the careful decision to convert the Food Safety Consortium, which historically has taken place in Schaumburg, IL, to a virtual conference. This move takes into consideration Illinois’ COVID-19 plan to reopen its economy, which is a Five-Phase Plan. Phase 5 occurs when groups larger than 50 (conferences and conventions specifically mentioned) will be allowed. The state enters Phase 5 only when a vaccine or an effective treatment is in place. The decision to take the Food Safety Consortium virtual is based on the Illinois reopening plan, along with considering the safety and well being of staff, attendees, speakers and sponsors.
Every Thursday, beginning on September 10 through November 12, the Food Safety Consortium Virtual Conference Series will host two presentations and two sponsored Tech Talks, followed by a panel discussion with attendees. Food Safety Tech is the media sponsor.
“This will be much more than a bunch of webinars. We are excited to offer a virtual platform that facilitates greater human interaction,” says Rick Biros, president of Innovative Publishing and director of the Food Safety Consortium. “Whether it’s a random connection in a hotel lobby, a stroll by a booth at a trade show, or a seat next to a new friend in a learning session, we recognize that human connection is important for events. That’s why we’ve invested in new tools for the FSC Conference Virtual Platform to ensure those discussions, discoveries and connections can go on whether our event is offline or online. The new platform provides attendees with a way to keep track of live sessions, connect with sponsors and engage with peers, all in a familiar way. It will also include an event App that offers interactive features.”
Frank Yiannas, FDA deputy commissioner for food policy and response, will remain a keynote speaker, with the new presentation date to be announced.
Call for Abstracts
We are accepting abstracts for participation in the Food Safety Consortium Virtual Series. On the Submit an Abstract page, select Food Safety Consortium 2020 in the drop-down menu.
Categories include:
Food safety
Food defense
Food integrity
Food safety supply chain management
Lessons learned COVID-19
Regulatory compliance
Facility design
C-suite executive forum
Tech Talk Sponsorship
Companies that are interested in sponsoring a 10-minute technical presentation during the series can also submit their abstract through the portal. For pricing information, contact IPC Sales Director RJ Palermo.
Food Safety Tech publishes news, technology, trends, regulations, and expert opinions on food safety, food quality, food business and food sustainability. We also offer educational, career advancement and networking opportunities to the global food industry. This information exchange is facilitated through ePublishing, digital and live events.
About the Food Safety Consortium Conference and Expo (The live event)
Food companies are concerned about protecting their customers, their brands and their own company’s financial bottom line. The term “Food Protection” requires a company-wide culture that incorporates food safety, food integrity and food defense into the company’s Food Protection strategy.
The Food Safety Consortium is an educational and networking event for Food Protection that has food safety, food integrity and food defense as the foundation of the educational content of the program. With a unique focus on science, technology and compliance, the “Consortium” enables attendees to engage in conversations that are critical for advancing careers and organizations alike. Delegates visit with exhibitors to learn about cutting-edge solutions, explore three high-level educational tracks for learning valuable industry trends, and network with industry executives to find solutions to improve quality, efficiency and cost effectiveness in the evolving food industry.
Last week FDA announced the extension of the application period for importers that want to participate in the Voluntary Qualified Importer Program for FY 2021. The COVID-19 pandemic has resulted in travel restrictions and advisories that have hampered efforts by accredited Certification Bodies (CBs) to both conduct the onsite regulatory audits and issue certifications to foreign entities, which are required by the VQIP application.
The application portal will stay open until July 31.
VQIP is a voluntary fee-based program that was established under FSMA. Approved applicants are granted an expedited review and import of human and animal foods into the United States if they prove they are achieving and maintaining a high level of control over their supply chains from a safety and security standpoint. Eligibility criteria includes ensuring facilities of foreign suppliers are certified by a CB that has been accredited via FDA’s Accredited Third-Party Certification Program.
Food and beverage manufacturers are seeing the effects of the coronavirus when it spreads through their workforce. Recently, there have been multiple closures of facilities operated by meat processors, including Smithfield Foods and Tyson Foods as COVID-19 has infected hundreds of workers.
The backdrop of stressful operations and work: Employees now face increased questions before entering plants and feelings of isolation as lunches and breaks are now solo activities due to social distancing. All of these stressors are compounded when you think about what we’re asking them to do: Go into work and keep food on the grocery store shelves. This is a completely new way to operate, and it has a very real emotional effect on our workers.
We’ve received reports from customers where management is getting out of the back office and putting on hairnets to work the production line. The shortage of workers is a very real problem, and our customers are rising to the challenge. Plus, managing this overall labor shortage while doing more safety and sanitation checks than ever before to make sure transmission risks are eliminated is putting stress on everyone working in plants. It’s never been harder to work in the food industry.
In response to California Governor Gavin Newsom’s actions related to the pandemic, we stand behind any effort that is taken to accommodate the needs of these vital, valuable workers, including the executive order to provide supplemental paid sick leave. Such actions, both locally here in California and at the federal level, are critical to elevating the safety of our food manufacturing and distribution workers. Some heroes wear hairnets.
Temp Workers and Lack of Training Protocols
COVID-19 has had a significant impact on the availability of skilled workers in food facilities. Through all the layoffs stemming from the economic standstill, food manufacturers and grocery workers are reporting increases in hiring to help keep up with demand—and to mitigate the effects of sick employees going on quarantine for two weeks. For instance, Albertson’s, a large food grocery chain store, reported that it was hiring for 2,000 positions.
But hiring temporary workers is only half the battle. The task of training people who may have never worked in grocery or food manufacturing has become more critical in the face of new demands on sanitation and social distancing. With these measures in place, it’s no longer a case of a new employee showing up for work and shadowing another employee or supervisor. Technology can close the gap, especially in food production where the regulations and safety standards require strict adherence to processes. For example, software can facilitate shorter employee training in the areas of quality policies and good documentation practices.
Same Volume with Fewer Workers
We are working closely with customers and partners to cope with new guidelines for social distancing inside food facilities, providing the capability to do remote audits as visitor restrictions have increased. Our software is also being used to screen food manufacturing workers for symptoms of COVID-19 before shift work starts to help prevent the spread of the coronavirus to other essential workers.
In response to increased needs from customers, we have developed three solutions to address the impact of COVID-19. These solutions, which include a personnel screener, changeover manager and remote supplier auditor, can help food and beverage manufacturers efficiently manage physical distancing measures, symptom screening, and travel restrictions.
It can’t be stressed enough: The people who carry out food safety protocols are doing more checks and using more labor time to conform to regulations and guidelines for COVID-19. And, adhering to the systems, regulations and processes used to promote safe, high-quality products (in the same or even higher volumes) remains as crucial as ever. Simplifying these processes by leveraging software has been shown to cut 8 to12 hours of labor per day for a single facility. This is critical at a time when even one person being sick can cause lower throughput.
Plus, this isn’t like manufacturing a car where a line will be built to produce hundreds of thousands of cars over a two- to three-year period. Food manufacturers must often change a line over to produce a different flavor, package type or food type altogether, in as little time as possible to keep production going. Robots and automation can help, but in a crisis like this where immediate productivity gains are needed, software can make the much-needed difference.
Foodborne illnesses cost billions of dollars each year in the United States. A lack of standards can lead to severe consequences, including loss of customers, negative impact on brand reputation and employees missing work due to illness. As a result, safety is vital for any brand that is committed to high-quality food and maintaining a positive brand image.
Food safety management systems—the processes and procedures that companies set up to prevent contamination—are essential in reducing the risk of foodborne illness and ensuring the safest products possible.
By FDA regulation, most food processors must have HACCP as well as corrective actions/preventive action (CAPAs) plans in place. Even with the right safety guidelines, however, contamination or exposure to food hazards can still occur. The following are four ways to improve the quality of your food safety management system.
1. Conduct Regular Audits
Even if your business’s HACCP is highly effective in theory, it won’t prevent contamination unless actual practice lines up with documentation. Regular audits can ensure employee practice complies.
HACCPs are structured around identifying both potential food hazards and critical control points (CCPs) where your system has the opportunity to prevent, mitigate or eliminate a potential issue. Usually, this means storing food items or performing some biological, physical or chemical action to a target limit— like a specific temperature—to prevent or mitigate contamination.
For example, in the manufacturing of chicken products, cooking and hot-holding are critical control points at which the product needs to be heated to a certain temperature to eliminate or prevent potential hazards. Here, an audit would be a chance to ensure employees cooked and hot-held foods at the proper temperatures. If they aren’t, the food safety management team can make policy changes that ensure practice lines up with planning.
The audit process should be consistent and occur regularly. It should also cover every aspect of your HACCP strategy and place a particular focus on potential hazards and CCPs. These audits can be a way to uncover the strengths and weaknesses of your current HACCP strategy. Companies can use this information to build upon existing practices or demonstrate how procedures could be more effective.
Stainless steel is popular in food handling due to impermeable surface and resistance to corrosion, two characteristics that help reduce the risk of food contamination. (free image from Splash)
2. Consider a CCP Monitoring System
You can use automated or digital systems to ensure that CCPs aren’t deviating from control limits. With the right sensors, it’s possible to ensure that food remains between target limits at each CCP. For example, automated sensors can quickly alert plant staff if the temperature of food in cold storage rises above a certain threshold, or if there is a deviation from a given CCP.
These alerts can help staff quickly respond to deviations, ensuring compliance, and reducing the risk of contamination by food hazards.
3. Review and Maintain Equipment
An thorough equipment program can be highly effective in reducing the risk of food contamination. To minimize risk, your plan should look at the equipment needed in your plant, as well as how it’s constructed and maintained. For example, choosing industry-standard or food-safe materials can help prevent contamination. Investing in the right kind of stainless steel can both improve operating costs and help reduce the risk of food exposed to hazards.
Preventive maintenance plans for food safety equipment can also reduce the risk of contamination by ensuring the proper functioning of site equipment.
4. Provide Employee Support and Encourage Buy-In
Training programs are an essential component of any HACCP. If your employees don’t know how to handle food properly or aren’t aware of HACCP documentation or the CCPs in the food processing pipeline, they won’t be able to execute the plan and prevent contamination.
While training programs are crucial, they don’t necessarily guarantee compliance. Common pitfalls exist that can discourage employees from following the plan. To encourage employee buy-in, training should begin by discussing the importance of food safety and the potential risks of contamination.
The training should also be robust enough that employees feel confident when executing the HACCP. Training staff should be sure to provide visual demonstrations and opportunities for employees to practice before they become responsible for food safety. Tests or evaluations both during and after training can be useful tools in determining how well your employees understand your business’s HACCP strategy. Regular follow-ups on training can also ensure compliance and reduce the risk of contamination.
Improving Food Safety Management Systems
For any business that works with food, safety programs are essential in ensuring the safest and highest quality product possible. Existing food safety management systems can often improve with the right methods. For example, automated monitoring systems can reduce the risk of deviating from CCP limits. Employee training and regular audits can also ensure that a plant’s food safety practices line up with the documented plan.
Birds of different species can become a pest problem depending upon where they are landing, roosting or nesting. In terms of food facilities, birds can cause various concerns: Product safety risks, possible contamination (bird droppings/feathers), poor audit grades, inspection failure, secondary insect pest problems, vectoring of foodborne illness pathogens, plant closures or fines. It is for these reasons that it is essential that food, beverage and product manufacturers (FBP) establish an integrated bird management (IBM) program.
An IBM program will ensure that every essential team member is on the same page in terms of the protocols for managing pest birds within and around the facility. Even if a facility has taken a proactive approach to bird control, the potential exists for birds to enter a facility. Especially considering bird pressures around adjacent properties, buildings, bodies of water and food sources near the facility.
Read Part I of this series: Bird Problems and Control Methods for Food Production FacilitiesIBM for food industry facilities is a systematic approach to preventing birds from gaining access within a facility and reducing the length of time birds remain within a facility. Nuisance birds, depending upon how severe the bird pressure—i.e., how many birds are landing, roosting and/or nesting within a given area—can cause severe damage to equipment, property, food products, displays, vegetation, façade signage, ledges, roofs, HVAC equipment, drains, fire suppression, electrical equipment and more. The longer that birds are permitted to remain within and around a facility, the more damage they can cause, and the harder it is to remedy the problem. Thus, it is critical to remove any birds that have gained entry as soon as possible to prevent possible FBP contamination and the birds getting comfortable within the facility.
There are several components to developing an IBM program. First, you need to conduct a complete inspection of the interior/exterior of the facility, followed by a review of the current data as well as any historical bird data. Now that you have all the raw data, you can begin developing the site-specific IBM plan for the FBP facility. Now that you have the program designed, the program can be implemented. Finally, after a defined timeframe that the IBM program has been active, the program needs to be evaluated to determine if any adjustments need to be made to the program.
Inspection
The first step in developing an IBM program is to conduct an initial site inspection audit of the interior and exterior of the facility.
An example of an integrated bird management food safety audit checklist. Credit: Aviaway
The following various elements need to be inspected and with said findings documented.
An example of an interior audit spreadsheet. Source: Aviaway. (Click to enlarge)
On the interior of the facility, look at the following items:
Active Birds with the Facility
List the areas and locations of birds
Example: Location(s): Food prep area(s), warehouse, etc.
Any history of birds and related areas
Interior Landscaping
Type(s) and necessity
Food Processing Areas
Any active control measures in place
Assess the level of risk
Bay Doors
Location(s): Gaps
Location(s): Bumpers
General Doors
Location(s): Gaps
Location(s): Bumpers
Location(s): Structural
Location(s): Doors left open
Additional Access Point(s)
Check all equipment areas that enter/exit building
Pipe-Line Penetrations
Sanitation
Conductive Conditions
Location(s): Standing water
Location(s): Food Sources
Debris
Bird Droppings or Nesting Materials
Staff feeding birds
All access to food and water
An example of an exterior audit spreadsheet. Source: Aviaway. (Click to enlarge)
On the exterior of the facility, look at the following items:
Active birds with the facility
List the areas and locations of birds
Example: Locations(s): Rear loading dock
Any history of birds around the exterior of the facility
Adjacent Structures
Accessory buildings and structures
Sanitation Practices (Exterior)
Location(s): Dumpsters
Exposed food sources and spillage
Trash Receptacles
Trash Removal Frequency
Food Waste on Ground
Cleaning Practices
Cleaning Practices Schedule
Cleaning Food Waste Bins
Motion Doors
Bay Doors (Exterior)
Location(s): Gaps
Location(s): Bumpers
Location(s): Structural
General Doors (Exterior)
Location(s) Doors Being Left Open
Additional Access Point(s)
Bodies of Water
Conductive Conditions
Structural (Exterior)
Location(s): Pipe-Line Penetrations
Location(s): Flashing
Location(s): Pipes
Location(s): Openings
Location(s): Roof
Location(s): Roof Hatches
Location(s): Windows
Location(s): Canopy (Front/Rear)
Location(s): Awnings (Front/Rear)
Location(s): Façade Signage (Front/Rear/Side)
Drainage
Standing Water
Clogged Drains
Landscaping
Retention ponds
Bird Droppings or Nesting Materials
Exterior Storage
Merchandise Displays
Existing Bird Control Devices
Review
Next, after all the above items have been inspected and findings recorded, all the data needs to be reviewed. In addtion, all the current bird management practices within the facility, documentation practices, and current audit/inspection findings should be all evaluated together. All this information is your road map for developing your IBM Program. Make sure that while you are collecting all the said raw data, you also speak with all necessary staff to get the most accurate information possible.
Documentation
Now that you have conducted your inspections and collected all the data, it’s time to create a site-specific IBM Policy & Plan for the facility. The development and implementation of the IBM plan will provide the appropriate procedures that are to be implemented to prevent, control and exclude birds from entering a facility and from keeping birds an acceptable distance away from the facility. With proper training and implementation of IBM procedures, there will be a reduced likelihood that birds will be able to enter the facility, and the length of time birds remain inside the facility will be reduced—thus, reducing the level of pest bird damage caused, reducing hazards to food sources, equipment, the public, and the facility environment.
Each facility is unique in its operation, location and potential for bird activity. The facility’s IBM plan will be designed to factor its control options when remedying and preventing bird pressure.
Implementation
Now that you have an IBM Plan, it’s time to implement the plan. First, make any necessary changes based upon findings of the audit and review of all data. Next, correct any conducive conditions that were discovered during the inspection. All the items that may require adjustment may need to be planned out depending upon budgetary constraints. Define staff roles regarding bird control efforts on a front-line facility level. Each member of the action team must fully understand their role and responsibility about the implementation and day-to-day operation of the plan.
The IBM Plan is the roadmap that should be followed for managing pest birds throughout the interior and exterior of the facility and related structures. It will set forth the facility’s bird threshold levels and site-specific facility needs. Furthermore, the IBM Plan will provide in detail how each phase of the plan will be implemented at each facility. The facility coordinator, in collaboration with the IBM coordinator, shall be responsible for the administration and implementation of the IBM plan. Each of their roles and responsibly should be thoroughly reviewed and understood.
Next, conduct staff training on proper bird control removal methods if handing live removal internally. Otherwise, what are the approved processes for third-party vendors who are providing removal services? Finally, conduct a review of the new documentation process to record all necessary data for the IBM program. Data collection is a critical component in evaluating the success of the plan and determining if any adjustments need to be made.
Evaluation
To ensure goal compliance, the IBM program should be evaluated at each site annually. The review must consist of all records, the number of birds that gained access into the store, corrective actions taken (at the facility level and outside efforts), and any plan adjustments. By reviewing all the data collected, the plan’s effectiveness can be determined, and whether alterations need to be made. Note that the IBM plan is not a static document that sits in a binder. The plan will have to evolve as operations change, or the set goals of the program are not met.
Conclusion
A proactive approach to reducing bird populations is critical for food industry facilities. As such, the IBM program will ensure that your entire staff is adequately trained on all the site-specific bird control methods, reduce the frequency of birds entering the facility and create a documented bird control program that is designed for your specific facility.
Modern food supply chains are inherently complex, with products typically passing through multiple suppliers and distributors, as well as countries and continents, before they end up on the supermarket shelf. While global supply chains offer consumers greater choice and convenience, they also make protecting the security of food products more challenging. With additional stakeholders between farm and fork, products are exposed to an elevated risk of biological or chemical contamination, as well as food counterfeiting and adulteration challenges—potentially putting consumer health and brand reputation in jeopardy.
Given the importance of maintaining the safety, quality and provenance of food products, global regulatory bodies are placing the integrity of supply chains under increased scrutiny. In the United States, for example, the adoption of FSMA moved the focus from responding to foodborne illnesses to preventing them by prioritizing comprehensive food testing measures, enforcing inspections and checks, and enabling authorities to react appropriately to safety issues through fines, recalls or permit suspensions.1 Similarly, China’s revised Food Safety Law (known as FSL 2015) is widely considered to be the strictest in the country’s history, and seeks to drive up quality standards by empowering regulators, and enhancing traceability and accountability through robust record-keeping. 2 The European Union continues to closely regulate and monitor food safety through its General Food Law, which is independently overseen by the European Food Safety Authority from a scientific perspective.
Achieving the Highest Standards of Food Security, Integrity and Traceability
For producers, manufacturers and distributors, the heightened regulatory focus on the security and integrity of the food supply chain has placed additional emphasis on accurate record-keeping, transparent accountability and end-to-end traceability. To meet the needs of the modern regulatory landscape, food chain stakeholders require robust systems and tools to manage their quality control (QC), environmental monitoring and chain of custody data. Despite this, many businesses still handle this information using paper-based approaches or localized spreadsheets, which can compromise operational efficiency and regulatory compliance.
The fundamental flaw of these traditional data management approaches is their reliance on manual data entry and transcription steps, leaving information vulnerable to human error. To ensure the accuracy of data, some companies implement resource-intensive verification or review checks. However, these steps inevitably extend workflows and delay decision-making, ultimately holding up the release of products at a high cost to businesses. Moreover, as paper and spreadsheet-based data management systems must be updated by hand, they often serve merely as a record of past events and are unable to provide insight into ongoing activities. The time lag associated with recording and accessing supply chain information means that vital insight is typically unavailable until the end of a process, and data cannot be used to optimize operations in real-time.
Furthermore, using traditional data management approaches, gathering information in the event of an audit or food safety incident can be extremely challenging. Trawling through paperwork or requesting information contained in spreadsheets saved on local computers is time-consuming and resource-intensive. When it comes to establishing accountability for actions, these systems are often unable to provide a complete audit trail of events.
Digital Solutions Transform Food Security and Compliance
Given the limitations of traditional workflows, food supply chain stakeholders are increasingly seeking more robust data management solutions that will allow them to drive efficiency, while meeting the latest regulatory expectations. For many businesses, laboratory information management systems (LIMS) are proving to be a highly effective solution for collecting, storing and sharing their QC, environmental monitoring and chain of custody data.
One of the most significant advantages of managing data using LIMS is the way in which they bring together people, instruments, workflows and data in a single integrated system. When it comes to managing the receipt of raw materials, for example, LIMS can improve overall workflow visibility, and help to make processes faster and more efficient. By using barcodes, radiofrequency identification (RFID) tags or near-field communication, samples can be tracked by the system throughout various laboratory and storage locations. With LIMS tracking samples at every stage, ingredients and other materials can be automatically released into production as soon as the QC results have been authorized, streamlining processes and eliminating costly delays.
By storing the standard operating procedures (SOPs) used for raw material testing or QC centrally in a LIMS, worklists, protocols and instrument methods can be automatically downloaded directly to equipment. In this way, LIMS are able to eliminate time-consuming data entry steps, reducing the potential for human error and improving data integrity. When integrated with laboratory execution systems (LES), these solutions can even guide operators step-by-step through procedures, ensuring SOPs are executed consistently, and in a regulatory compliant manner. Not only can these integrated solutions improve the reliability and consistency of data by making sure tests are performed in a standardized way across multiple sites and testing teams, they can also boost operational efficiency by simplifying set-up procedures and accelerating the delivery of results. What’s more, because LIMS can provide a detailed audit trail of all user interactions within the system, this centralized approach to data management is a robust way of ensuring full traceability and accountability.
This high level of operational efficiency and usability also extends to the way in which data is processed, analyzed and reported. LIMS platforms can support multi-level parameter review and can rapidly perform calculations and check results against specifications for relevant customers. In this way, LIMS can ensure pathogens, pesticides and veterinary drug residues are within specifications for specific markets. With all data stored centrally, certificates of analysis can be automatically delivered to enterprise resource planning (ERP) software or process information management systems (PIMS) to facilitate rapid decision-making and batch release. Furthermore, the sophisticated data analysis tools built into the most advanced LIMS software enable users to monitor the way in which instruments are used and how they are performing, helping businesses to manage their assets more efficiently. Using predictive algorithms to warn users when principal QC instruments are showing early signs of deterioration, the latest LIMS can help companies take preventative action before small issues turn into much bigger problems. As a result, these powerful tools can help to reduce unplanned maintenance, keep supply chains moving, and better maintain the quality and integrity of goods.
While LIMS are very effective at building more resilient supply chains and preventing food security issues, they also make responding to potential threats much faster, easier and more efficient. With real-time access to QC, environmental monitoring and chain of custody data, food contamination or adulteration issues can be detected early, triggering the prompt isolation of affected batches before they are released. And in the event of a recall or audit, batch traceability in modern LIMS enables the rapid retrieval of relevant results and metadata associated with suspect products through all stages of production. This allows the determination of affected batches and swift action to be taken, which can be instrumental in protecting consumer safety as well as brand value.
Using LIMS to Protect Security and Integrity of the Food Supply Chain
Increasingly, LIMS are helping businesses transform food security by bringing people, instruments and workflows into a single integrated system. By simplifying and automating processes, providing end-to-end visibility across the food supply chain, and protecting the integrity of data at every stage, these robust digital solutions are not only helping food supply chain stakeholders to ensure full compliance with the latest regulations; they are enabling businesses to operate more efficiently, too.
Various types of pest birds can impact food plant structures and facility surroundings. Even a single bird that finds its way into a food plant can trigger a host of concerns such as, failed audits, product contamination, plant closure, production stoppage, lost revenues, fines, structural damage, health hazards to occupants and fire hazards.
In most cases, a food plant operation has a bulletproof pest control plan; however, in most cases, birds are always an afterthought in most pest management plans. After inspecting and consulting numerous food plants, I hear the same story over and over: “I have a person in the warehouse that can chase them out” or, “are birds really a big deal?” or, “why do I have to be concerned about birds?” and on and on. Despite what you may think, birds are a big deal, and you should take them seriously!
Larger birds, such as pigeons, can cause more problems around the exterior of a facility on HVAC units as seen here. (Image courtesy of Aviaway Bird Control Services & Consulting)
Since food processing plants contain areas that have very sensitive environments, birds can introduce various adulterants and harmful contaminants. Birds can cause potential harm to humans due to foodborne illness.
Pest Bird Species
There are four main pest birds: Pigeon, Starling, Sparrow and Seagull. Each one of these birds can cause a host of concerns and issues for food processing facilities. Just one bird can cause catastrophic damage. In most cases, small pest birds such as Sparrows and Starlings can gain access into a facility through a variety of ways:
Damaged bumpers around truck bay loading dock doors.
Open doors (seems obvious, but I always find doors wide open during audits).
General building deficiencies.
Larger birds, such as Pigeons and Seagulls, typically cause more problems around the exterior of a facility on ledges, rooftops, HVAC units, loading docks and related areas.
In either case, these various types of pest birds can cause significant problems on the interior and exterior of food plants.
Conducive Conditions
In most cases, facilities want to reduce as many conducive conditions as they can around and within the facility in a timely fashion. A conducive condition is one whereby due to a building condition, structural design, equipment operation, food or water source, or surrounding conditions (i.e., near a public landfill, raw materials mill or body of water) can attract pest birds to a facility. With each of these conditions, great care must be taken to reduce as many conducive conditions as possible.
Examples of Conducive Conditions
Structural Conditions
Loading docks/canopies with open beams and rafters
HVAC equipment
Pooling water (roof and landscaping)
Structural overhangs and ledges
Open access points
Landscaping (types of plantings)
Damaged truck bay bumpers
Gaps and opening around the structure
Doors with improper sealing
Human Conditions
Open dumpsters
Overflowing dumpsters
Dirty dumpsters
Product spillage
Employees feeding birds
Doors left open
All these conducive conditions, if left unresolved, can lead to significant bird problems. Reducing as many conducive conditions as possible will be the first step of any bird management program.
Bird Control Methods
From the start, your facility should have a bird management plan of action. For the most part, bird problems should not be left to be handled internally, unless your staff has been properly trained and has a bird management plan in place.
Most birds are protected by the Federal Migratory Bird Treaty Act of 1918. However, Pigeons, Sparrows, and Starlings are considered non-migratory birds and are not protected under this Act. Even though these three bird species are not protected, control methods still need to be humane. More specifically, your bird control program must also comply with is the American Veterinary Medical Association (“AVMA”) Guidelines for the Euthanasia of Animals if this is the control method selected. The AVMA considers the House Sparrows, Feral Pigeon, and the Common Starling “Free-Ranging Wildlife.” And Free-Ranging Wildlife may only be humanely euthanized by specifically proscribed methodology.
In addition to the above-mentioned regulations, various regulations regarding the relocation of birds/nests may also apply. I also always recommend checking with local and state agencies to ensure that there are no local regulations that may apply. Bottom line: Don’t rely on untrained internal practices; one misstep could result in heavy financial fines and penalties.
Bird Management Strategies
First Line Defense
Stop any bird feeding around the facility immediately
Any bird management plan should have a clear policy prohibiting employees from feeding birds. Once birds have been accustomed to routine feeding, the birds will continue to return.
Eliminate Standing Water Sources
All standing or pooled water needs to be eliminated. Thus, routine roof inspections need to be conducted to ensure drains are working properly.
Landscape irrigation needs to be calibrated to ensure no puddling of water in areas of low sun exposure.
Proper Sanitation Practices
Ensure that dumpster lids are closed when not in use.
Trash removal frequency adequate.
Routine cleaning of trash receptacles.
Immediate removal of spilled food.
Eliminate Entry Points
Survey the facility to ensure that all holes are properly sealed.
• Around truck bay bumpers and doors
Exhaust vents are properly screened.
Windows are closed and have screens when in use.
The most appropriate bird control strategy will be determined based on the severity of the bird pressure. For example, if the bird pressure is high (birds have nested), then in most cases, you will only be able to use bird exclusion methods. Whereas, if the bird pressure is light to moderate (birds have not nested), bird deterrent methods can be used. This is an important distinction. Bird exclusion is physically changing the area to permanently exclude said pest birds. Whereas, bird deterrent devices inhibit birds from landing on treated areas.
Bird Deterrent Methods
After the previously mentioned first-line strategies have been implemented, the next step would be to install bird deterrent products (birds have not nested).
Bird Spikes
Bird Wire
Electrified Shock Track
Bird Gel
Sonic & Ultra Sonic Devices
Lasers and Optical Deterrents
Hazing & Misting Devices
Pyrotechnics
Live Capture
Bird Exclusion Methods
If the birds have nested in or around the facility, the next step would be to install bird exclusion products (birds have nested).
Bird Netting
Ledge Exclusion (AviAngle)
Architectural modifying structural
Aggressive Harvesting (Targeting)
Prevention Strategies
The best prevention strategy is planning and knowledge. Conduct a bird audit and develop a bird management plan before birds get near or inside the facility. The key is to act quickly, as soon as an incident occurs. I find countless times when I am called in to consult or service a food plant, that the birds got into the facility and no one knew what to do, and as a result, the birds remained within the facility for an extended period, thus increasing the risk of exposure. It is always much easier to remove a bird when they are unfamiliar with their surroundings. Whereas, it is much more difficult to remove birds from a facility that has had a long-standing bird problem.
Once you have a plan, who oversees the bird management plan? Are thresholds determined and set for various areas of the facility? For example, a zero threshold in production areas? Threshold levels will be set based upon by location and sensitivity of the said location. What steps are going to be taken to remove the bird? For how long is each step conducted? These questions need to be answered and developed to stay ahead of bird problems.
Reduce as many conducive conditions as possible. The longer a conducive condition stays active, the more likely birds, as well as other wildlife or rodents, will be attracted to the site and find a way into the facility.
Pathogen Contamination & Hazards
Birds present a host of problems, whether they are inside or outside of a facility. Birds can roost by air vents, and the accumulation of bird feces can enter the facility air system. Bird droppings on walkways and related areas allow for the possibility of vectoring of said dropping when employees step on droppings. Thus, spreading fecal matter/spores and other contaminants to areas throughout the facility.
If birds are within the facility, droppings can spread on product lines, raw materials, stored products, equipment and more, thus, causing contamination. Because of a bird’s ability to fly, they are perfect creatures to spread various diseases, pathogens, ectoparasites and fungal materials. Diseases such as Histoplasmosis, Salmonella, Encephalitis, E-coli, Listeria, and more. Birds have been known to transmit more than 60 infectious diseases!
Besides the spread of potentially harmful contaminants throughout the facility, bird droppings and nesting materials can also create a host of additional problems:
The acidity in bird droppings can damage building finishes, façade signs, lighting and more.
Wet bird droppings can create a slip and fall hazard.
Bird nesting materials can create a fire hazard around façade signs, exit signs and light fixtures.
Bird nesting and debris can clog roof drains and cause roof leaks from standing water.
Introduction of ectoparasites into the facility such as bird mites, lice, fleas, ticks and more.
Conclusion
In summary, taking a proactive approach to bird control is the best practice. Reduce food, water and shelter sources (aka conducive conditions) promptly. Pest management programs need to implement a more in-depth section of the program for bird control. Like integrated pest management, bird control should be based upon an integrated method. Each facility will have its unique challenges. As such, each bird management plan needs to be tailored to the specific site. A well designed and balanced, integrated bird management program will provide long-term and cost-efficient bird control.
Patricia Wester, PA Wester Consulting and Founder, The Association for Food Safety Auditing Professionals
The most commonly cited observation during a Preventive Controls inspection is an incomplete or incorrect hazard analysis, according to FDA data. Food Safety Tech is hosting a special complimentary webinar series, instructed by Patricia Wester, founder of The Association for Food Safety Auditing Professionals, that will provide attendees with important tips on conducting and documenting a thorough hazard analysis. During the one-hour event, Wester will help participants understand how to recognize gaps in a hazard analysis as well as share best practices for closing those gaps. The content is geared toward food safety professionals and auditors who develop, manage or review food safety plans in a Preventive Controls landscape.
Many industries are moving toward unannounced third-party certification audits and the food industry is no different. If regulatory audits are unannounced, why is the food industry reluctant to adopt unannounced third-party audits? There are a number of benefits to unannounced audits—most importantly is their positive impact on a company’s food safety culture and how they prepare facilities to face FDA inspections.
Unannounced audits for food are required for many third-party certification audits. Typically, regulatory audits are always unannounced. Unannounced audits help demonstrate compliance and provide confidence to all stakeholders that your manufacturing sites are operating on the same GMP level, day to day, shift to shift, for every day your organization is manufacturing and distributing food products. With announced audits, companies tend to prepare for them before they occur. However, if there is a significant amount of difference between your sanitary operations prior to and during an announced audit versus normal operating conditions, you are sending your employees the wrong message.
Although there are differences between certification schemes, the GFSI third-party unannounced audits usually have a 40- to 60-day window in which the audit must be completed to allow the certification body to complete technical reviews and review corrective actions so that the certificate does not lapse. If it is a surveillance audit, then the audit is more likely to be truly unannounced, but a company still has the option of using blackout dates and the auditor will verify that the request was necessary. The bottom line is most companies have a certain timeframe when they know unannounced audits will occur.
Leonard Steed will present “Unannounced Audits: Are You Ready?” on November 14 at the 2018 Food Safety ConsortiumThe biggest impact on third-party audits is when the audit score is directly related to financial incentives for employees. This situation motivates employees to pursue activities to achieve the maximum score, not directly related to food safety. Activities may include significant audit preparation to eliminate or reduce GMP deficiencies, reduce or control the auditor’s access to records or areas of known plant deficiencies, “auditor shopping”, and to appeal any audit finding that lowers the score. Switching auditors or appealing findings can be legitimate tools to correct a system when auditors make errors in judgement or behavior. The activities to achieve the highest score should be reasonably governed because they could take away from the primary goal to operate in a food safe mode.
The goal of an internal audit program is to be compliant with regulatory inspections and third-party certification requirements and should therefore be risk-based. Determine what factors present the most risk to an organization and then align internal audits with those risks. At this point in time, being able to perform well on a regulatory audit should be a primary concern. Since the FDA and state regulatory agencies usually perform unannounced inspections, it would seem necessary to have your food safety plan, prerequisite programs and operations in a constant state of readiness to mitigate the risk of potentially unsafe food in commerce resulting in a recall.
One way to evaluate your food safety culture is to anonymously survey employees at all levels of the organization to gather information on attitudes and opinions about food safety and institute changes to improve your position. Another way is to initiate change by instituting unannounced audits on all manufacturing shifts and require participation by all departments in the audit function to move away from “QA-centric” food safety verification systems. The significant change is that all departments would be involved as an auditor and responsible for maintaining regulatory compliance. For some companies, the inclusion of all plant departments in the audit function has moved the needle in the goal to improve their food safety culture. To further define food safety culture in other terms, it could mean adhering to GMPs all the time, the importance of accurately completing and verifying food safety records, and fostering consensus between departments on the severity of food safety nonconformances requiring prompt corrective action.
Maintaining GFSI certification is an excellent way to achieve food safety requirements for compliance with FDA inspections. Although not specifically required by GFSI, another application of your internal audit program is to review your regulatory policy by performing a mock FDA inspection to identify any gaps in hazard analysis, identify preventive controls including the supply chain controls, accurately complete food safety records, and provide examples of corrective actions when preventive controls were not completed properly, and environmental corrective actions. If you decide to perform a mock FDA inspection of your facility, do not forget to include the FDA Guidance document criteria, as it is important to understand what the FDA expects to see when they are evaluating your implementation. Your internal audit program is a proactive program to note nonconformances before they become full blown problems, so don’t be afraid to use it to its fullest extent.
In the food manufacturing industry, just as in any other industry, cybersecurity is very important. Your organization should be having cyber vulnerability assessments or penetration tests performed at least once a year. Like any big test you have taken in your life, this sort of assessment can be scary, but if you prepare for it, you can greatly improve the potential of passing the test. As you prepare for the assessment, there are six things you can either implement or do to make the result of this audit better for your organization.
Do an inventory of what is connected to your network. You cannot expect to defend devices on your network that you are not aware of. Be sure when you perform this inventory that you include any device that connects to your network. Think past the routers, switches, desktop PCs, laptops and printers. What is connecting to your wireless network? Is your security system or HVAC system connected to the network? Creating a network device inventory can be difficult, but there are tools available to make it easier. Once you have created the initial inventory, your baseline, go back at least monthly to look for new devices or devices that are no longer connected so you can update your inventory.
Determine what is running on all of your network devices. In the first step you inventoried the hardware—now we need to inventory what is running on each device. You can use tools such as Nessus to inventory the software on each computer as it scans the network to perform the device inventory. This is the quickest way to complete both of these steps. If there is old or unused software on a device, remove it. You need to document the operating system and application software on each device. This software Inventory should also be included in your baseline and verified/updated on at least a monthly basis.
Use the Principle of Least Privilege. This is a very valuable cybersecurity concept. Never give a user or device more rights on the network than they/it need to perform their assigned tasks. Privileges are assigned based on roles or job functions. If a user is unable to download and install applications on their PC or laptop, you reduce the chance of a device becoming compromised. Many hackers, once in a network, move laterally through the network from machine to machine looking for information or vulnerabilities that can be used to give themselves more abilities on the network. If a hacker were to gain access to a user account or system with low privileges, it decreases the amount of damage they could do.
Use Secure Configurations. All operating systems, web browsers and many other networked devices have secure configuration settings. One of the problems with doing this is that operating systems alone can have hundreds of settings to choose from. The Center for Internet Security provides benchmarks for just about every conceivable device. The CIS Benchmarks are distributed free of charge in PDF format to propagate their worldwide use and adoption as user-originated, de facto standards. CIS Benchmarks are the only consensus-based, best-practice security configuration guides both developed and accepted by government, business, industry, and academia.
Set up a policy and procedure for applying security patches. New vulnerabilities are discovered every day and when these vulnerabilities are found, vendors release updates or patches to mitigate the vulnerability. Exploiting vulnerabilities is what a hacker lives for. An unpatched vulnerability can be almost an open door for a hacker to get into your computer or network. It is mind boggling to hear that some organization was hit with ransomware because they didn’t load a security patch that was released six to 12 months ago. When an application reaches end-of-support, the vendor stops releasing patches, and that should tell you that it is time to upgrade the software to the newest version or find another tool to perform that task. Never use unsupported software on your network. Speaking as an auditor, a fully patched network is impressive.
Create an Incident Response Plan. Let’s face it, no matter what you do to protect yourself, something is eventually going to go wrong. Do you have a plan to continue operations if you lose access to your office building? Do your users know what to do if they receive or fall prey to a phishing e-mail? This process starts with performing a risk assessment. Once you have determined the potential risks, you then move on to determining how to mitigate the risks. You will need to create policies and procedures and then train the employees on them, so they know what to do.
By performing these six steps you will be protecting and strengthening your networks, your users, and trust me, you will impress the auditor. Also, it should be noted that these are not once and done steps—these are steps that must be repeated sometimes on a daily, if not at least on a monthly, basis.
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