Strategic Integrated Pest Management

By Jay Bruesch


Pest management should be less like a war and more like a well thought-out game of strategy. Instead of reacting to pest infestations with an armory of chemicals, integrated pest management is about getting to know your opponents’ strengths, weaknesses and typical behaviors. Rather than waiting to get rid of problems once they are established, you must keep your opponents from advancing in the first place by thinking proactively. This is especially key in organic facilities, which have limited use of many conventional pest controls. Below are some tips on how to think more strategically and less reactionary when it comes to pest management.

The Rules: The NOP’s Built-In Pest Management Strategy
The National Organic Program standards are a great starting point for developing your pest management strategy. The Facility Pest Management Standard (the portion of the National Organic Program text pertaining directly to pest management) gives clear guidance on what is and is not allowed in organic facilities, and provides a framework for how to prevent and deal with problems in a way that is most eco-friendly. Unlike conventional, reactionary pest-management thinking, which often skips right to the chemical solutions, the key to integrated pest management for organic processors is to focus on steps (a) though (c), and in most cases by doing this you will avoid the later steps.

Paragraph 205.271 of the regulation requires organic facilities to manage pests by:
a. Practicing effective sanitation and exclusion in order to remove the resources attracting pests and allowing them to survive, and to deny them access and harborage.

b. Modifying the physical environment (light, air movement, temperature, humidity) in ways that make the facility less attractive to pests, or less conducive to their survival.

c. Using mechanical devices, such as traps, to remove pests. Traps may attract pests by means of light (e.g., insect light traps), trap design (e.g., the tunnel configuration of a multiple-catch mouse trap) or the presence of a pheromone (e.g., a stored-product moth trap utilizing a synthetic sex attractant to lure male moths).

d. If the practices mentioned above are not adequate to prevent or control pests, then a pesticide whose active ingredient is named as an “allowed” substance on the National List may be applied. (The National List, paragraphs 205.600 through 205.606 of the NOP rules, names substances that are allowed—and prohibited.) Pesticide active ingredients named on the National List include boric acid, insecticidal soaps, horticultural oils, non-synergized pyrethrins, synthetic pheromones and elemental sulfur. A number of commercially available pest control products contain active ingredients consistent with the National List.

e. If all other means have been utilized and/or all the previous steps have been considered and found inadequate to prevent or control pests, then—and only then—a material not named on the National List can be used. However, the material must be applied in such a way that no contact can occur between it and the organic food (or food-contact surfaces). Prior to using any substance not on the List, it must be approved by your organic certifier, and named within your facility’s organic handling plan, along with how and when the material would be used. This ensures that you are not using any materials that have been prohibited by the NOP.

Put It In Writing
Once you are familiar with the rules, the next step in any good strategy is to put your game plan on paper. The National Organic Program (NOP) requires an organic-compliant pest management plan as part of the overall organic handling plan. However, it’s key to make this a visible part of your daily operations and ensure that employees are educated on this plan. Don’t just file it away and forget about it.

Your program summary should describe how the various elements of the program are to be conducted (interior rodent control, exterior rodent control, crawling insects, flying insects, stored-product pests, birds, nuisance wildlife, etc.) and list service frequencies and other operational details. It must also include a list of pest control materials (if any) to be made available for use, describing what each material is for, and describing precautions that will be taken when applying each material so that no contact occurs between the material and any organic food or food-contact surface.

The Importance of the Daily Log. One of the most important, yet often underutilized, parts of an integrated pest management program is the daily log report, which is used to report on actions taken, pest control materials applied (if necessary), and recommendations made. Other components of the program, such as activity summaries for rodent devices and insect light traps, capture information that is needed in order to continuously evaluate and adjust the program and make sensible decisions.

Careful documentation and communication is a large part of keeping track of all that is done and shows alignment between actions taken and the established NOP rules. When reporting on pest management activities and making recommendations, the pest management technician should reference the specific rules from the Facility Pest Management Standard. By doing this, everyone—the pest control technician, the organic handler, and the organic certifying agent that comes to audit the program—can easily see that everything is in compliance.

After documenting the issue in the daily log, make sure to have a conversation with those responsible for making changes in sanitation, preventive maintenance and personnel practices. This will bring the issue to their attention and ensure that their role in the pest management strategy is clearly understood.

Don’t Just Record Data—Use It! Whenever there is an issue, the in-house or contracted pest management professional must always review his or her own data on device activity (mouse trap catches, bait-station feeding activity, insect light-trap catches), and identify trends in what is caught and where. Trends in pest activity may point to a weak spot in the plant’s defenses. For example, if mice are frequently caught in the same area, that might mean there is a gap under a door. Cigarette beetles repeatedly showing up in the same insect light trap might mean that a vendor is sending the plant infested ingredients.

Manage the Environment Strategically
Inspect Like a Sleuth. One of the most important parts of integrated pest management is to inspect the property on a daily basis. Look for anything that provides opportunities for pests to find food, water, shelter or access, and then recommend appropriate improvements in sanitation, structural maintenance or personnel practices. Paying attention to inventory records for raw ingredients and finished product will also alert the pest management technician to the location of old or out-of-code product that could become infested.

Be careful that the pest management technician doesn’t develop “horse blinders syndrome.” This occurs when the pest management technician faithfully checks and cleans every trap, and accurately records every mouse and flour beetle, but doesn’t notice other things that are going on, away from the “boxes” (permanent pest management equipment, such as rodent devices and insect light traps). It is possible to service interior mouse traps and exterior bait stations perfectly, and find no activity at all, while mice that have hitchhiked into an interior plant area are happily reproducing and contaminating product.

Understand What’s Bugging You. Do your homework so that you understand the pest’s biology and typical behaviors. What kind of habitat do they thrive in? What do they like and dislike? In one facility, American cockroaches were showing up in multiple levels and areas within a food plant. A pest control material, such as a cockroach bait, would have relieved the symptoms but not solved the problem over the long term. Considering the known behavior patterns and preferred living conditions of American roaches, this problem was traced to cockroaches living in the sewer system and making their way into the plant via neglected floor drains whose traps had dried out from disuse. The solution was to add water to the drains and float some mineral oil on top of the water to prevent the drains from drying out.

Be Inhospitable. As defined by the NOP regulations, the first two steps of an integrated pest management system for an organic facility revolve around sanitation and modifying the environment so it’s not attractive to pests. Besides keeping your facility clean, you can deny these uninvited guests what they need through proper light management, inventory monitoring, air movement, dehumidifiers and exterior landscape considerations. A few examples include:

• Many springtail problems (springtails are fungus feeders that are associated with damp areas and are very difficult to kill with pesticides) have been solved by simply installing a fan to improve air circulation and dry out an area.

• One can take advantage of the fact that yellow light sources, such as sodium vapor, are much less attractive to flying insects than are white light sources like mercury vapor bulbs—and much less likely to result in flying insects finding their way into a facility. The practical application of this knowledge would be to install mercury-vapor bulbs on light standards in the parking lot, away from the building, and sodium-vapor bulbs in lamps above dock doors. Using this scheme, night-flying insects would be attracted away from the building, and the vulnerable door areas would be rendered unattractive to insects.

• Look for, and correct, any exterior- or landscaping-related conditions that might contribute to pest presence. For example, mulch and low-growing ornamental plantings create an inviting environment for pests; a well-drained perimeter rock border is a better idea. Make sure the ground is sloped away from the plant on all sides to allow for good drainage and dry conditions around the building. And keep all gutters, downspouts and rain diverters in good condition so that water is led away from the plant.

Execute the Plan Strategically and Creatively. If pests manage to find their way into your facility, it is important to go back to your pest management plan. Double check steps (a) and (b) from the NOP rules, locating any newly developed leaks, spills, drips, gaps or cracks that may be providing entry or food for the pests. Document this in your daily log and discuss with maintenance to ensure the issue is taken care of immediately. Then look at non-chemical tools you can use, step (c). Only after all this, should you consider steps (d) or (e).

The actual course of pest management decisions does not always progress in linear fashion from step (a) through step (e) of the NOP’s rules, waiting for one thing to fail before trying the next thing. But each step must be considered and taken if appropriate. One must choose a sensible course of action according to the circumstances at hand, using the rules of the Facility Pest Management Standard as your main guide.

In addition, creative thinking will get you far in pest control as well. Often times you can find ways to solve your pest problem without resorting to the use of chemical pest management.

Here are a couple examples of companies that thought outside the box:

• If You Can’t Close It, Leave It Open! Airborne product dust in an organic food plant was finding its way onto the tops of false-ceiling tiles, which were nearly impossible to clean. The resulting infestation of flour beetles needed to be eliminated in order to protect food products from contamination. The solution proved to be simple: Since there was no way to effectively prevent flour from floating up into the false ceiling, the answer was to remove the ceiling tiles entirely. Of course, overhead structures like trusses and utility chases still needed periodic cleaning, but the amount of dust that needed to be dealt with overhead was greatly reduced.

• A Hot Idea. Fluid dairy ingredient had leaked from a bulk milk tank into hollow wall blocks, and the residue that dried in the wall led to an infestation of black flour beetles that emerged continually from cracks at floor level and around pipes. Pesticides would have offered only temporary relief.

Keeping in mind insects’ inability to adapt to temperatures above 120 degrees F., the facility’s maintenance staff was asked to help: they used the plant’s steam-cleaning apparatus to direct steam heat against the affected wall, solving the problem without any use of chemicals.

In Conclusion
Organic pest management means having a good plan that is executed perfectly and documented with perfect records. Having a strong preventative strategy in place (rather than just taking reactionary measures when needed) is key not only to maintaining a pest-free facility, but also to honoring your commitment to the organic mission and principles.

Jay Bruesch is a board certified entomologist and a member of the Entomological Society of America, and the technical director for Plunkett’s Pest Control. Bruesch has provided service protocols and compliance tools to many organic clients and teaches on the subject of organic pest management to professionals throughout the United States. You can reach him at jay@plunketts.net.