PESTS AND REGULATORY FOOD SAFETY

Food Protection and Pest Management

Dr Brian Prystupa phD

All International Standards for Hygiene, Food Safety and GMP have detailed specifications for pest control and fly control in particular.  

These are the Good Manufacturing Practices (GMP) regulations (21 CFR Part 110) and the Hazard Analysis Critical Control Point (HACCP) regulations (21 CFR Part 123).  The new ISO 22000 Standard also deals with indoor fly control.  The GMP regulations specifically mention flies, for example, as a type of pest requiring exclusion. In addition, the FDA Food Code deals with the monitoring and exclusion of pests through sanitation programs in at least five sections (Food Code 6-202-13, 6-202.15, 6-202.16, 6-501.111, 6-501.112).

The GMP regulations, which cover all food processors, specifically require not only good in-plant sanitation but also elimination of reservoirs and harbourage both inside and outside a facility and effective perimeter barriers to prevent pests from entering the facility. These regulations also call for extra care to be exercised to exclude or exterminate pests that originate from adjacent grounds that are not under the control of the plant manager.

Electric Fly Zappers or Electro-cutors are designated for outdoor use 18-20 feet away from entrances to food facilities as these devices were know to forcibly eject fly bodies onto nearby food and food surfaces.  Indoors, the new UV Fly catchers using horizontal sticky surfaces are approved for use above food and direct food surfaces.

1. Flies are known to carry a wide variety of pathogenic and disease-causing microbes.

FDA has a long history of concern over the adulteration of foods with pests and pest filth. The concern covers four broad regulatory areas: pests as aesthetic pre-harvest contaminants; pests as visible, obnoxious nuisances; pests as indicators of insanitary conditions in a food processing facility; and pests as carriers of food-borne pathogens. Recent developments involving emerging food-borne pathogens such as E. coli 0157H have increased the need to better understand the true capabilities of pests, such as flies to carry and transmit food-borne pathogens.

2. FDA Law – The Food, Drug and Cosmetic Act.

Sections 402(a)(3) and 402(a)(4) define two types of adulteration. These sections apply to pests among many other types of filth and extraneous materials. Section 402(a)(3) deems a food adulterated “if it consists in whole or in part of any filthy, putrid, or decomposed substance, or if it is otherwise unfit for food.” Pests or pest fragments in a product qualify as a “filthy” substance within the meaning of section 402(a)(3). Section 402(a)(4) deems a food adulterated “if it has been prepared, packed or held under unsanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health.” Pests not only qualify as “filth” under section 402(a)(4) but certain disease carrying pests may render a product injurious to health by contaminating the food with pathogens.

Preventing the spread of food-borne pathogens by flies in a facility is accomplished through the facility's pest control program and/or sanitation program, including Sanitation Standard Operating Procedures (SSOPs). Two separate parts of the Codes and Regulations specifically mandate the exclusion of pests from food-handling and food processing facilities.

In addition, it is important that a fly species be recognized by food and beverage Managers as a potential threat to public health from the transmission of enteric pathogens.  Flies exhibit all the most dangerous attributes are likely to spread food-borne diseases.

3. Exclusion and Monitoring

Exclusion of pests from food-handling and food-processing facilities is a complex matter that requires knowledge of the natural histories and life histories of the different types of pests that may be encountered in a facility. Extra vigilance is required for pest species such as flies that exhibit the natural attributes associated with the transmission of food-borne pathogens by pests and extra precautions may become necessary to exclude these disease-carrying pests from food-handling and food-processing facilities.  Food handling staff must be trained and educated on the needs and methods of excluding flies and other food pests.  Entry doors must be kept closed at all times, even on hot days.  Food waste must be kept covered, removed regularly, and containers cleaned regularly.

House Flies: House fly young develop in very unclean places, such as fresh manure or garbage. The adults feed at these sites too, but they also feed on most human foods. House flies become pests when they find access into a home. The house fly can complete its development in as little as six days with each female being able to lay up to 900 eggs. The adults are about 1 inch in length. They have four dark stripes on their middle section just behind the head. Separating house flies from some other flies that look similar may be difficult. If in doubt, consult an expert. House fly breeding and feeding sites make them potential health hazards.

Blow Flies and Bottle Flies: Blow flies and bottle flies are medium-sized flies with robust bodies. They usually have a green, blue, bronze or black sheen. The key to identifying blow flies and bottle flies is this metallic shine on their bodies. These flies take about 10 days to complete development. Blow flies and bottle flies usually breed in decaying animal carcasses. They are important in nature in returning organic matter to the soil. Blow flies and bottle flies appear within minutes after an animal dies. They may also breed in garbage, animal feces or even meat or fish left out after a meal. Around a home, these flies suggest the presence of a dead animal such as a mouse, squirrel, bird or stray animal. If eaten, these flies can give people stomach problems, diarrhea or food poisoning. Sometimes blow flies and bottle flies lay their eggs on open wounds of pets and even people.

Flies are an even greater threat to human health than cockroaches. Control flies by making sure windows and doors are properly closed or screened. Keep flies away from garbage or other things that are close to the kitchen or food preparation area.