ISO 22000: WHAT IS ISO 22000 GAP ANALYSIS? – Section VI

Gap Analysis VI

The Purpose of the ISO 22000 Gap Analysis is to allow an organization to evaluate the current situation of the manufacturing process relevant to food safety requirements stated in the ISO 220000 Standard, which will help to implement an Internationally Certified Food Safety Management System namely “ISO 22000 Food Safety Management System Certification” in later stages.

On the other hand, while conducting a Gap Analysis the auditor compare the best practices with the processes currently in place in your organization specific to food safety requirements stated in the ISO 22000 standard based on Good Manufacturing Practices, however today the new system FSSC 22000 is also overlook the same phenomenon in an extensively improved way.  The audit will also determine the “gaps” between your organization’s practices and the identified best practices as well as help you to select the best practices you will implement in your organization while you implement the ISO 22000 FSMS. The gap analysis will also give you an in-depth understanding of the differences between current practices and best practice with an assessment of the barriers that need to be addressed before successful implementation of ISO 22000 FSMS.

In order to achieve given objectives within an ISO 22000 FSMS, pest management is critical in the food processing and handling, food service, food retail, hospitality, health care and other facilities where we live, work and play. Both in-house and contracted pest control services primarily involve use of pesticides to manage pests in urban, non-production agriculture and agricultural environments. A variety of local, national and international regulations and standards govern pesticide registration, production, sale, and handling and use to protect human and environmental health concerns which is also relevant to GMP as well as ISO 22000. Thus evaluations basically conduct to observe whether these practices are in line with ISO 22000 requirements or not.   

Section VI: Pest Control Systems

6.0 All requirements (GMP and Codex requirement)

Pests pose a major threat to the safety and suitability of food. Pest infestations can occur where there are breeding sites and a supply of food. Good hygiene practices should be employed to avoid creating an environment conducive to pests. Good sanitation, inspection of incoming materials and good monitoring can minimize the likelihood of infestation and thereby limit the need for pesticides

Buildings should be kept in good repair and condition to prevent pest access and to eliminate potential breeding sites. Holes, drains and other places where pests are likely to gain access should be kept sealed. Wire mesh screens, for example on open windows, doors and ventilators, will reduce the problem of pest entry. Animals should, wherever possible, be excluded from the grounds of factories and food processing plants.

The availability of food and water encourages pest harbourage and infestation. Potential food sources should be stored in pest-proof containers and/or stacked above the ground and away from walls. Areas both inside and outside food premises should be kept clean. Where appropriate, refuse should be stored in covered, pest-proof containers.

Establishments and surrounding areas should be regularly examined for evidence of infestation.

Pest infestations should be dealt with immediately and without adversely affecting food safety or suitability. Treatment with chemical, physical or biological agents should be carried out without posing a threat to the safety or suitability of food.

Compliance Criteria

Closely inspect the given points to identify the extent of the existing design and recommend to improve or to maintain the current model. Concentrate on the given points to evaluate more thoroughly and systematically. 

The Control Points

  

Special Reporting type service

1. The company must either contract the services of an approved pest control organization, or must have trained on site personnel, for the regular inspection and treatment of premises to deter and destroy infestation by insects, birds or animals. An outside contractor must always be accompanied on his visit by a member of staff.
2. It is recommended that pest control companies should provide a minimum of six visits per year at regular intervals, with personnel on 24 hour call out. Where problems are evident, daily revisiting must be specified until the area is clear.
3. Safe and hygienic disposal of pests is required after capture or fumigation. Documented procedures are therefore needed from the contractor or for the business.

Pest control records including bait plans, labels and dating

1. Detailed records of the pest control inspections must be kept in correct date order in the onsite Report Book.
2. A member of the management team - (normally the QA manager) must be made responsible for ensuring that all recommendations made in the report are reviewed and actions have been taken within an agreed time scale.
3. The internal bait stations should be sited by the pest control officer. An accurate site map showing where stations are located should be compiled and held in the Report Book.
4. Each bait station should be adequately labeled and the bait boxes clearly date marked at each site inspection.

Baiting and proofing standards including monitoring systems

1. Whilst it is not possible to bait food production areas where open food is handled, all ancillary areas must be covered.
2. Wherever practicable, baits should be based on fatty or waxy substrates or back break traps. Those based on grains are not acceptable due to the increased contamination risk to any food stuffs being manufactured or stored in the vicinity. The internal rodent bait should be safe e.g. held in a tamper resistant box.
3. External bait stations should be tamper resistant and situated around the external area of the factory site. They should be clearly marked.
4. Where stored product insects (spi) are considered a risk, the appropriate spi treatment must be included in the control programme, and fumigation applied as required. Pheromone traps should be used wherever there is a risk of insect infestation.
5. External doors, windows and sky lights should be close fitting and have no gaps. Bristle strips should be fitted where necessary.
6. Where doors are open during normal production hours, suitable barriers should be fitted to prevent pest ingress. This includes fly screens where necessary, which must be kept clean.
7. Opening windows should either be sealed or fitted with non-removable insect screens.
8. Open drains must be fitted with a grill or mesh covering. They must be in a good state of repair and functional.
9. Air-bricks should be fitted with a suitably fine mesh cover.
10. The external fabrication of food premises should be constructed and maintained so that there are no entry points for pests.
11. Birds must be excluded from all production and storage areas. To facilitate this, all apertures in the eaves of the roof or the roof itself, or the walls must be identified and either closed off or suitably screened.
12. Additionally canopies must be proofed to prevent birds roosting.
13. Where birds are already present on the site they and their nests must be removed in concert with wildlife statutes.
14. Domestic animals e.g. cats and dogs must also be excluded from the factory environment. Staff should never feed or encourage stray animals to come on site, and all factory doors and other entrances must remain closed. Domestic animals must not be used for pest control purposes.

Fly killer’s position and condition

1. All production and ambient storage areas should be protected by electrical insect “knock
   
   down” devices. For maximum effect, these should be sited in areas of minimum light intensity, but must not be sited directly above open food handling areas.
2. Each unit should be fitted with a suitable catch tray which should be regularly inspected and emptied when necessary. Flying insect “counts” can be particularly useful in identifying problems with one particular insect type.
3. The units must be constantly switched on even after production has finished and the premises vacated.
4. The ultra violet tubes on these units should be replaced at twelve month intervals or more frequently if necessary.

Good perimeter control

1. There should be a clear perimeter zone, free from accumulations of rubbish, packaging materials, raw materials, pallets and redundant equipment, which could provide harbourage for pests. Ideally the perimeter zone should be fenced for security.
2. Efficient and effective pest control begins with good perimeter control.
3. The exterior finish of factory buildings should be maintained in good condition. In general vegetation must not be allowed to grow around the immediate perimeter or on or near walls and roofs. All gutters and exterior drains must be kept clean and functional. Pallets, plastic trays or other materials must not be stored against the factory walls, to prevent pest harbourage.
4. There should be adequate facilities for the disposal of rubbish and general factory debris located a significant distance from production areas. Rubbish bins, skips or other containers must be totally enclosed and regularly emptied to prevent over spill. Good housekeeping here is essential as spillage will encourage the presence of birds, insects, rodents and other scavengers.

Storage and housekeeping standards (including stock rotation)

1. The most effective, common sense approach towards infestation control is in maintaining good housekeeping standards i.e. controlling accumulation of food and packaging debris, keeping passages clear and un-littered, removing redundant equipment and materials from the manufacturing area and ensuring good stock rotation.
2. Goods and equipment should not be sited against walls. A minimum gap of 50cm must be left to allow for adequate cleaning and inspection purposes. Walls/floor junctions must be kept free of debris.
3. Every employee on site must be made aware of the need to exercise good housekeeping practices to reduce the risk of pest infestation. This must be implemented by induction for new employees or briefing sessions for existing ones.

Access incoming check systems for ingredients

1. All incoming raw materials whether they be food ingredients, packaging or equipment, must be thoroughly checked on arrival at the site for pest infestation. If the materials show evidence of damage to the outer packaging, product seal, pallet wrapping or to the pallet itself, then they should be Quality Assurance quarantined and further investigation must be carried out. If rejected by the Quality Assurance department, the raw material should be clearly labeled ‘reject’ for return to the supplier stating why.
2. In the event that pest infestation is found on incoming materials, they should be labeled ‘reject’, isolated from the factory, the pest control contractor called immediately and the infestation treated before it spreads.

Segregation of damaged or returned goods

1. There must be complete physical segregation of infestation damaged or returned goods to guarantee that they will not be used in production. 
2. Designated reject areas within the goods in the warehouse facility will help in emphasizing ‘rejected’ stock and isolate the problem.

Safety and technical documentation, approved baits and pesticides

1. Pest control documentation must be clear, concise and legible. It must be kept up to date and
2. regularly reviewed by the technical department.
3. Documentation relating to the safety and application of approved baits and pesticides must be available, usually in the form of a data sheet. Information relating to the Control of Hazardous Substances to
4. Health must be readily accessible in either the pest control Record Book or a separate named document.
5. All documentation/records detailing the safe use and application of these pesticides requires the signature or identification of the checker, to ensure accountability.