To a pest, there is no difference between an organic food processing facility and a traditional facility. The pests’ objective remains the same for either – to access the attractive food, water, and harborage sources inside the facility.
This presents a unique scenario for organic facility and QA managers: The pest threat is the same for both, but there are far more restrictions on how to eliminate the threat in an organic facility.
“Pests do not draw a distinction between an organic vegetable processing plant and one that is non-organic,” says Bruce Ferree, an independent food safety consultant based in Lodi, California. “The challenge for a facility manager and their pest management service provider is determining how best to connect traditional IPM protocols with their organic programs.”
The U.S. Department of Agriculture’s National Organic Program (NOP) lays out a uniform set of standards that growers, processors, packagers, and warehouse operators should follow to produce products that are labeled and sold as organic. Under the NOP, the use of pesticides is not prohibited but it is a last resort option.
NOP is governed by US Code of Federal Regulations rule 7 CFR § 205.271 and requires the handler or management of the organic facility to use management practices to prevent pests. It emphasizes the following:
- The removal of pest habitats, food sources, and breeding areas
- Prevention of pest access to handling facilities
- Management of environmental factors such as temperature, light, humidity, atmosphere, and air circulation, to prevent pest reproduction
Ferree says integrated pest management (IPM) strategies including prevention, exclusion, sanitation, monitoring, and cultural practices should be the foundation of any pest management program in an organic food processing plant.
In California, pest management plans and materials must be approved by the California Certified Organic Farmers (CCOF) or another USDA-accredited organic certifying agency. Procedures to ensure that the equipment, facility, and food will not be contaminated by any pest management method must be in place prior to any pest management service being performed.
There are fewer restrictions – it can vary depending upon the certifying body, the auditor, and the type or scope of the pest threat – on the use of pesticides or rodenticides on the exterior of an organic facility or in non-organic production areas. Once a pesticide or rodenticide is approved for use, the materials should be added to a facility’s Organic System Plan (OSP).
Designing your pest management program
Designing a pest management program in an organic facility starts with a thorough inspection and analysis of the facility. This is followed by the creation of a written pest management program that outlines the details of what will be done and how it will be done. The program will place a heavy emphasis on documentation, because this supports the protection and integrity of an organic facility’s certification.
Under NOP guidelines, pest prevention is done through mechanical or physical management and/or natural or approved traps and repellents. This may sound familiar to many Clark Pest Control clients, as this approach mirrors the IPM principles we apply in our pest management programs.
The NOP guidelines outline a specific order of pest management methods in areas where organic products are processed, handled, or stored.
- First use preventative measures, such as good sanitation, then mechanical measures, such as mechanical, sticky, or pheromone traps.
- If preventative and mechanical measures do not adequately control pests, you may use NOP allowed materials from the national list, including carbon dioxide, nitrogen, Vitamin D3 bait, and boric acid, diatomaceous earth, or soap products. Lures and repellents using non-synthetic or synthetic substances consistent with the national list may also be used.
- If preventative, mechanical, and national list materials are not effective, you may use pesticides. In California, the CCOF must be notified before you use pesticides by providing the following information:
- Product labels for all pest control materials used in organic production or storage areas.
- A letter of justification from your pest management provider for its use that explains why you are unable to use national list materials.
Ferree feels that pest monitoring plays an important part of any organic facility’s pest management program.
“Glue boards and sticky traps not only alert you to the presence of pests in a facility and where they may be coming from, but since they contain no pesticides, they are easy to include in any pest program,” says Ferree. “It can also tell you how well a pest program is performing.”
A facility’s organic handling plan must be updated to reflect the use of pesticides and methods of application. The updated organic plan must include a list of all measures taken to prevent contact of the organically produced products or ingredients with the product used.
“An organic food processing facility’s best defense is to stay on top of its sanitation and exclusion protocols and make the facility unattractive to pests,” says Ferree.
Key takeaways
- Pests do not draw a distinction between an organic vegetable processing plant and one that is non-organic.
- Under the U.S. Department of Agriculture’s National Organic Program (NOP), the use of pesticides is not prohibited, but it is a last resort option.
- Integrated pest management (IPM) strategies, including prevention, exclusion, sanitation, monitoring and cultural practices, should be the foundation of any pest management program in an organic food processing plant.
- Documentation supports the protection and integrity of an organic facility’s certification.
- Partnering with a professional pest management company like Clark Pest Control will help ensure that an organic facility stays compliant with NOP standards while also preventing pests from contaminating organic products.