What Auditors Look For in a Food Plant Pest Program.

Under FDA's current Good Manufacturing Practice rules for human food (21 CFR Part 117), pests must not be allowed in any area of a food plant, and effective measures must be taken to exclude them. Third-party audit schemes such as SQF, BRCGS and AIB look closely at how your pest management program does that, and at the records that prove it.

Requirements vary by scheme and edition, but auditors tend to focus on the same areas.

1. A written program and contract

Auditors expect a documented pest management program that defines the scope, service frequency, responsibilities and target pests. If you use an outside provider, keep these on file:

• The service agreement or contract
• Current applicator license(s) for the technicians servicing your site
• The provider's certificate of insurance

2. An up-to-date device map

Every monitoring device (exterior bait stations, interior mechanical traps, insect light traps) should be numbered and shown on a current site map. The numbers on the map must match the numbers on the devices, and the map should be updated whenever devices are added, moved or removed. A mismatch between the map and the floor is one of the most common audit findings.

3. Appropriate device placement

• Exterior perimeter: secured, tamper-resistant bait stations around the building.
• Interior: typically non-toxic monitoring devices such as mechanical traps. Many audit schemes restrict or prohibit rodenticide baits inside production and storage areas, so check your scheme's requirements.
• Insect light traps: positioned so they don't draw insects toward exposed product or into the building through doorways.

4. Complete service reports

Each service visit should produce a report showing the date, technician, devices inspected, activity found, and any pesticides applied, including product name, EPA registration number, amount and location. Recommendations to the facility (sanitation or structural issues) belong on the report too.

5. Trend analysis

Auditors want to see that activity data is reviewed over time, not just recorded. Periodic trend reports by device, zone and pest type help spot patterns, like rising activity near a particular dock door, before they become problems.

6. Corrective actions that get closed

Findings and recommendations need follow-through: what was found, what action was taken, by whom, and when it was verified. Open recommendations that sit for months, such as a gap under a dock door or a recurring sanitation issue, are a red flag.

7. An approved materials list

Keep a list of every pest control product approved for use at your facility, with current product labels and safety data sheets on file.

8. Exclusion and sanitation

Pest management doesn't stop at the devices. Auditors look at door seals, gaps around pipes and utilities, dock doors left open, spilled product, harborage around the exterior, and how quickly maintenance and sanitation issues get fixed.

This guide is general information, not a substitute for your audit scheme's requirements. Always check the current edition of your scheme's standard and your food safety plan.