World Grain - August 2018 - 78

FEATURE

be proactive with

FSMA
Act early, monitor constantly, and document everything
by Chelle Hartzer

ant to stay one step ahead of the U.S. Food and
Drug Administration (FDA) and your next audit? Be proactive.
The Food Safety and Modernization Act (FSMA) has
been in effect for over a year, and that means compliance
with Hazard Analysis and Risk-based Preventive Controls
(HARPC) is a must. As part of your food safety plan, you
must demonstrate a proactive approach to protecting your
grain products. All plans should include a pest management program, as pests are an unpredictable and common threat to products. Not only are FSMA regulations
active at this point, but the FDA continues to expand its
support for states to fully implement and enforce regulations. While this latest addition does not directly affect
grain products, it shows there is no time to waste. Food
safety programs should have been updated yesterday, but
the second-best time to start revising your plans is today.
Let's start with the basics. HARPC has many stipulations that trickle down to pest management. Generally,
it can be broken down into the following characteristics,
with pest-related implications each step of the way:
1. Hazard analysis. Conducting an inspection is the
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sional will identify the hazards (pests) and the highrisk areas in your facility where they may take residence. This can allow you to get ahead of potential
pest issues before they even occur.
2. Risk-based preventive controls. The key here is
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take immediate action. The longer you wait, the more
likely pests will establish themselves and become a
bigger, more expensive problem for your facility.
3. Monitoring. Devices are a great way to keep an eye
on pest populations around the facility, but don't
overlook the value of training. Employees can be a
78

big help in detecting and reporting on pest invaders.
4. Corrective actions. If pests or conducive conditions
are spotted within a facility, that's important to know.
But, corrective actions are the key to then eliminate
the problem. Once completed, ensure a protocol is in
place to monitor results over time.
5. 9HUL¿FDWLRQRegular service visits with a pest management professional will verify corrective actions
are working. If a strategy isn't working, the approach
needs to be adjusted. In addition, every facility
should have an annual assessment including a pest
trend analysis to highlight areas for improvement.
6. Supply chain. :KLOH QRW VSHFL¿F WR SHVW PDQDJH
ment, don't forget about incoming goods. It's never
a bad idea to inspect shipments before bringing them
inside the facility.
7. Record keeping and documentation. Everything
done to proactively prevents pests and deal with current pest issues should be recorded. Auditors need to
see an effective program is in place, and documentation will help demonstrate consistent improvement.
8. Reanalysis. Conditions change, and your plan should
change too and adapt to new issues and concerns.
You also need to be aware of the pests most likely to put
your proactive food safety plan to the test. Consider how
each pest you face can be prevented and think through
how the tactics you implement measure up to FSMA's
HARPC regulations. There are always proactive tactics to
help prevent these pests, which will be necessary to keep
them from feeling at home inside your facility. Here are
some examples you might encounter in your facility and
how the steps in HARPC can apply.
LESSER GRAIN BORERS
These pests can be tough to spot, especially since
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