Organic Pest Management Operations and Requirements

By Joe Montecalvo, Ph.D.


The primary objective of in-plant pest control to meet the U.S. Department of Agriculture (USDA) National Organic Program (NOP) standard requirements is to develop an integrated pest management (IPM) program that emphasizes both prevention and physical methods of control. Meeting this two-pronged objective may be challenging since historically, chemical control methods using crack and crevice, fogging and fumigation have been used in conventional operations that cannot be used in the organic processing environment.

Central to the issue of pest control and management operations for the organic food industry is a firm understanding of 7 Code of Federal Regulations (CFR) part 210, as well as an understanding of available, effective control measures. Sometimes overlooked, prevention programs should be the heart of a well-designed IPM program for the food plant. Following are some practical approaches for pest management designed for organic food process handling, processing operations and packaging that may be useful in optimizing an organic pest control program for companies either in the planning stages of organic certification or that are already certified.

Prevention, Prevention, Prevention
Perhaps the most important consideration in the design and development of any cost-effective pest control program is prevention of pest access to the plant and continuing employee training and education about pest control measures. Plant personnel must always be vigilant in observing any signs or indicators of pest activity. Additionally, utilizing regular building maintenance, avoiding or eliminating overhanging vegetation and policing the plant’s exterior and grounds all function in concert to enhance effectiveness of pest prevention programs.

Pest management operations are based on both common sense and scientific principles. Specific designs include many factors, such as location of the plant, overall pest pressure for rodents and insects, and to a lesser degree, bird activity. Also of consideration is the nature and composition of inbound ingredients and food processing operations. For example, a cereal milling operation may have different requirements than does a tomato processing plant in terms of keeping pests at bay.

A number of strategies may be used to meet specific pest control objectives and maintain compliance with certification agencies and with 7 CFR.

Rodent Control
Rodent control is an important component of any pest management operation since rodents have been characterized as biological vectors for many human diseases, as well as cause ingredients and products to become adulterated, requiring them to be discarded or destroyed, which has significant economic impact.

Generally, rodent control involves both physical and chemical measures. Two species of rats are most abundant in the United States, the Norway rat (Rattus norvegicus) and the roof rat (Rattus rattus.) The Norway rat is red-brown to gray-brown in color, about 300 to 500 grams in weight and sometimes is called the sewer rat or barn rat. The roof rat generally will seek a higher elevation for its habitat and is gray to black in color and is generally a bit smaller than the Norway rat at 200 to 350 grams. The fertile female rat can produce six to eight pups per litter, four to seven times per year providing a potential, prolific number of off spring in any given year.

Mice (Mus musculus domesticus) are known to enter building openings that are as small as the diameter of a nickel. Typical females wean 30 to 35 young per year and weigh approximately 15 to 24 grams. Mice have a unique ability to be carried into food premises in crates and cartons, which may be stored in farm sheds or packing areas that are generally not under the supervision of a pest management plan. Both rats and mice are nocturnal and their presence can be determined by visual observation of fecal pellets, chew marks, tracks and urine stains.

Prevention of rodent entry into the plant is a key strategy to rodent control. This involves routine building maintenance and keeping decorative shrubbery 25 to 30 feet away from the building. Additionally, all food process waste and garbage dumpsters should be stored in elevated sheltered areas, since rodents find elevated storage less attractive.

In the plant and dry warehouse areas, a number of physical measures may be used in compliance with the NOP. These include Katchalls, tin cats, glue boards and snap traps for mice. To manage the exterior of the plant, bait stations may be placed around the building perimeter and, in some cases, along the fence lines for building sites that have large yards or are situated in rural agricultural areas where rodent pressure may be very high.

Fundamental to the USDA’s 7 CFR Part 210 NOP requirement is the restriction of chemical pest controls; however, bait stations will contain a rodenticide. Therefore, in order to be compliant with 7 CFR, it is important to know what strategies allow for chemical pest control yet maintain organic integrity and compliance. According to 7 CFR, the USDA-NOP has approved the use of vitamin D3 under the trade name Quintox. This is a granular bait that is not as toxic or lethal as anti-coagulant rodenticides, and therefore, may not be as effective. This is problematic in areas that have high rodent pressure.

Since rodents are biological vectors for human diseases, the objective of any sound rodent control plan is to reduce the risk as low as possible for entry into the plant. Therefore, use of anti-coagulant rodenticides, such as bromadiolone, brodifacoum and chlorophacinone may be used in exterior bait stations but only if justified by a pest control contractor and/or by rodent logs showing on-site pressure. Certifiers that conduct significant processing certifications will require a letter of justification for the use of anticoagulant rodenticides only if rodent pressure can be documented.

Insect Pest Management
Generally, the major insects encountered in food processing plants are cockroaches, weevils, flies, and to a lesser degree, silver fish, which prefer a warm moist or wet environment, and ants. Most insects are seasonal and insect management programs can be divided into flying insect control and crawling insect control, which will require different mechanisms.

Prevention is a key for insect control, beginning with the use of air curtains, screen doors and routine refuse waste removal from the site. Insect light traps, which use high voltage currents in front of an ultraviolet (UV) light source, are very effectiveand pose no hazard. Some are equipped with glue boards to snare the insect after electrocution. Generally, placement of insect electrocutors is near the shipping and receiving doors, in the path or hall to the processing plant and also in the area of covered docks, so that the unit is positioned near the entrance. This may be an important consideration for seasonal high insect pressure from flies and other flying insects.

Control of crawling insects starts with prevention by elimination of entrance into the building by using regular building maintenance. Use of sticky traps, containing an adhesive may be used for both crawling and flying insects. However, the principle method of crawling insect control that is approved per 7 CFR is the use of pheromone traps that use specific sex pheromones, which may be combined with glue board, sticky traps or trapping chambers.

Another method of insect control is specific quality control inspection of in-bound ingredients and packaging materials. Evaluation of in-bound raw ingredients can be a powerful tool to reduce the risk of an in-plant insect infestation.

But what if prevention and physical control measures are not or are only partially effective? What approaches may be used to insure organic compliance with 7 CFR? Typically, grains, flours and other bulk cereal-based ingredients are not insect-free and if conditions allow for an infestation to occur, for example, in a flour milling operations, what can be done?

First, it is important to consider that cold temperatures lower than 42.8°F (6°C) will cause insect death in a matter of days. If temperatures are maintained at less than –6°F, insect death will occur in minutes. Therefore, one simple and effective method of infestation control is the use of cold temperatures.

Another approach, sometimes used to control organic grain and flour, is movement of the materials into a satellite trailer or silo, which is then fumigated with carbon dioxide gas. Carbon dioxide is approved by 7 CFR per section 205.605.

If a plant needs to be chemically treated by fogging or fumigation with phosphine, methyl bromide as an example, specific protocols are allowed per certifier approval for compliance with 7 CFR. In most cases, a plant may be fogged or fumigated if the complete inventory of organic ingredients, products and packaging materials are physically removed from the plant and stored in an off-site trailer and returned to the plant only after the recommended time for re-entry, noted on the product label, has elapsed. In most cases, the time for re-entry is 48 to 72 hours after the operation.

Additionally, certifiers will want a removal/re-entry log that documents what ingredients, packaging materials and/or fin-ished products were removed and listed according to date and time, the re-entry date and time and the signature of the plant personnel responsible for this operation.

Overall, this may be a time-consuming operation, so emphasis should be placed on prevention, physical methods and timely scheduling of organic production runs in order to reduce the storage time of both organic ingredients and packaging materials.

Bird Control
Birds, such as pigeons (Columbia Livia), present unique challenges to organic food process operations. Since birds are carriers of salmonellosis, toxoplasmosis and pseudo tuberculosis in their droppings, reduction in bird population is a key objective for food process operations. Bird populations can be significantly reduced by proper yard and exterior ground management and by consistently performing daily sanitation operations. Physical traps or decoys— but no avicide—may be used.

Use Good Protocols
Development of a pest management program that meets USDA 7 CFR requirements should be based on prevention and physical methods of control. Protocols and mechanisms are available that allow for maintenance of both organic integrity and effective pest management. Organic pest management operations should not compromise food safety at any level. Overall quality of sanitation operations can influence the integrity of the organic company’s pest management operations. Continuous review and optimization is a key component in the development of a certified organic pest management plan.

Joe Montecalvo, Ph.D., is a consultant and professor of food science at Cal Poly in San Luis Obispo, CA, where he teaches food plant sanitation and pest management, and food chemistry. He has served on subcommittees of the National Organic Standards Board (NOSB) where he has provided technical expertise in food plant sanitation chemicals and processing operations. E-mail him at montecalvo@aol.com.