By Lisa Lupo

It takes only a quick scroll through FDA’s Recalls, Market Withdrawals & Safety Alerts to see that food recalls occur on a nearly daily basis to a vast range of food companies. But what do you do when it happens to you?

How does a food company stay ahead of the curve to protect, then rebuild, its brand reputation when a recall is announced? What needs to be done immediately, soon, and down the road?

THE FIRST 24 HOURS/WEEK. “Bring your recall team together,” said The Acheson Group Senior Director of Food Safety Cameron Prince. Along with senior management, legal counsel, and insurance representatives, communication personnel should be involved from the very start, he said. “If not, they’ll always be playing catch up.”

Within the first 24 hours, you also need to dedicate a “war room,” assemble the team, and bring discipline around the management of it, Prince added. The team will be spending a lot of time in the war room, so make sure they have everything they will need. Then, he said, “Notify FDA as soon as you can. Don’t be afraid to notify them; FDA is actually your friend.” And, in any case, you will have to deal with them eventually, so it’s best to contact FDA as soon as you know there is a risk to the public.

On the other hand, Food Industry Counsel Founder and Attorney Shawn Stevens said you shouldn’t overreact. In recent years, there has been a tendency for companies to overreact to suggestions from consumers or other parties to FDA, that product may be contaminated or causing a problem, he said. Too often, both FDA and the food company will rush to judgment on the product and scope without having all the information or considering the impact. “It doesn’t do consumers or the industry any good if more product or wrong product is recalled,” Stevens said.

This can be particularly true when an issue originates in an ingredient, because a single pound of recalled ingredient can ultimately trigger the recall of millions of pounds of finished product. Take for example, the incident of a salt which was facing a foreign-object contamination recall that would have resulted in the recall of 100 million pounds of finished product. Because the contaminant did not present a reasonable probability of health risk in the finished product, the company engaged with FDA to dispute the recall — and was successful. But companies are generally afraid to engage with FDA in such a way, Stevens said, resulting in decisions that are made too abruptly without anyone asking the right questions.

While this should be done within the first 24 hours, the company needs to first ensure it is fully prepared. “Do a comprehensive investigation and due diligence to ensure you know all the facts,” Stevens said.

If you do need to recall, move forward with your plan, determining what needs recalled — and what doesn’t, adequately detailing the reasons for both. And do it quickly. “There can be very serious consequences if it is not done quickly,” Stevens said.

COMMUNICATION: INTERNAL, EXTERNAL. It is important that employees are informed that a recall is being considered or happening, and that they are told to whom they should direct any questions they receive, Stevens said. Employees should never discuss the incident with the media themselves, but should be told to refer all external queries to the designated communications person.

This is one area where advanced preparation is critical. Rather than attempting to write a press release at the last-minute, companies should have a generic release on hand which can be tweaked to fit the incident, Stevens said, adding, “Be very polite to reporters. Say, ‘Yes, we have announced a recall, but it would be very helpful if you could send me your questions in writing, along with your deadline, and we will respond.’”

That tends to be the best way to respond, he said. The reporters may have to wait, but they will get an answer ... and your company won’t be in the news as having said “No comment,” or being unavailable to respond.

Additionally, Prince said, while senior management has to lead the recall team, they can’t get in the way. “Trying to deny it or cover it up just doesn’t work; you have to be transparent,” he said. “A lot of companies have survived recalls because they were honest; a lot have failed because they tried to cover it up.”

It’s often the smaller companies that tend to be panicky, Prince added. “If you have internal expertise, use it. If you don’t, get the very best communications or risk management people to come in and help.”

While all this is going on, designated company representatives should be calling all emergency contacts for its commercial customers. But, be sure you have all your facts at hand. Medium and small companies that have just gotten their product into a major retail chain often fear making that call. “It’s tricky,” Prince said, “but my advice is to really think through the best time and how to tell them. Be confident; have all the information ready. If they think you are hiding something, it will be worse.”

Calls also should be made to your GFSI certifying body and export authorities, as applicable. “If you are exporting, there is a lot more responsibility,” Prince said. “Just be proactive. Contact all that need to know —You can’t overcommunicate.”

When FDA does show up at the door, be sure you have all your records ready and cooperate fully, Prince said. “It’s not a criminal investigation, it’s a regular FDA investigation, so it’s not to be feared,” he said.”

It also is advisable, especially for retailers, Stevens said, to have a toll-free number for incoming calls from concerned consumers, so it is shown that the company cares and is responsive.

Prince made a similar recommendation, stating that the line should be manned 24 hours even if you have to add hours or people to do so. Responding quickly to customers will help keep you ahead of the social media wave. “If consumers call and don’t get an answer, they can wreak havoc on Facebook or Twitter in no time,” he said.

ONGOING IMPROVEMENT. A root cause investigation should be conducted, so corrective action can be determined and implemented. Today’s recalls can involve large amounts of product produced over long periods, as pathogenic strains in product or on food surfaces can be matched to those in drains, other plants, and other times. “So, how do we prevent it?” Stevens asked. “It’s environmental monitoring, environmental monitoring, environmental monitoring.

“Every case involves environmental monitoring or control, so put more testing into the process,” he said, adding, “The dialog has to change from root cause analysis to root source analysis.”

A root cause analysis determines cause such as an employee didn’t do his job right (e.g., clean the floor), with the corrective action being to retrain the employee and retest. But a root source analysis will ask how Listeria got in the drain in the first place, Stevens said. “Coupling environmental monitoring with robust root source analysis will solve a lot of problems.”

REBUILDING TRUST. Once the recall and corrective action is completed, the company often will have to rebuild the trust of its consumers and the confidence of management and employees. Transparency and honesty are critical for both, Prince said. Proactive media and social media communication is important in rebuilding consumer trust. If a senior executive can put him or herself directly in the public eye and speak well, that will go a long way, he said. Prince said he has seen companies shut down and not speak at all with the media — then go out of business. “They are viewed as hiding something,” he said. “There are lots of lessons on this out there. Hiding things never works.”

Companies generally learn a lot from having an incident, he added. If they use those lessons to make improvements, to become leaders in food safety and build a food safety culture, people see that and respect it.

A culture of food safety can be described in three Cs: compassion, commitment, and communication, Stevens said. Truly feeling that food safety is critical, living it in every action, and conveying it not only to employees but also to customers.

It often is said the food safety is non-competitive, but in actuality, he said, “Food safety is extremely competitive — to your consumers and your customers. Food safety is as important a term as food quality; it’s not a quality product if it’s not safe. Market what you are doing, and people will want to do business with you.” And, he said, do it when there is not a crisis.

SIX MONTHS/YEAR LATER. “Never, ever become complacent,” Stevens said. “In every corner of every facility, there is a pathogen just waiting.”

Stevens also believes it is important that those who have been through recalls share their stories. “A lot of companies don’t want to talk about their problems, but you should educate the rest of the industry. Instead of trying to push it away, embrace it.” Talking about it at industry functions, discussing lessons learned and how to prevent an outbreak actually will build up the brand and set up the company as a thought leader, he said.

Prince agreed. “If you’ve learned something from a recall, go out and share it if it will help others. Don’t ever forget about what happened. Learn from it.”

The author is Editor of QA. She can be reached at llupo@gie.net.

By Lisa Lupo

Rats and mice have always been a grave concern in food processing facilities. They enter through structural gaps and openings; make their homes in and around food storage; and contaminate foods, packaging and food-contact surfaces with urine, droppings, and hairs. What do pest management professionals see as most problematic about these pests? What do they do and recommend for control? And how do they expect technology to impact service?

In 2016, PCT — the sister magazine of QA, conducted a survey of pest management providers on rodent activity and services, sponsored by Bell Laboratories. In this feature, we relay the key statistics (See Rodents Remain Problematic), with analysis of the responses and food-facility impacts from food processing pest control experts including McCloud Services Technical Director Patricia Hottel; Rentokil Director North America Commercial Pest Marketing Jeff Robbins; Industrial Fumigant Co. Staff Entomologist and Product Manager Jerry Heath; and Rollins Director, Quality Assurance and Claims Kim Kelley-Tunis.

1. Of survey respondents, 66% said that fall and winter were their busiest seasons for rodent control service. What does this mean for food manufacturers, especially this time of year? What should they be doing for prevention?

Kelley-Tunis: As the temperature drops, rodent activity increases, as rodents, just like humans, are looking to move into warmer areas with a stable food source during the cold winter months — and food manufacturing facilities provide just that. Prevention begins with a comprehensive and systematic pest management plan, detailing the methods the facility will use to prevent rodents from entering. This would include measures to identify and seal rodent entry points, as well as sanitation to prevent rodent access to food or water resources.

Hottel: Reviewing past service records can be valuable in determining and predicting the seasonal impact of rodents. For facilities that border agriculture fields, there can be an increase in rodent activity, especially mice, tied to harvest activities. More grain movement also can equate to greater spills and availability of food for rodents around processing and storage facilities. Thus, additional equipment may be required for monitoring and control, with increased monitoring and inspection for signs of rodents, followed by reaction to any indicated activity.

McCloud Services

Bell Laboratories

Heath: The single greatest preventive action one can take is exclusion — attending to openings, door thresholds, rail-shed track openings, etc. Sanitation and harborage elimination also are important, especially in the near outdoor areas. For example, leaves and litter blow around in the autumn, packing into piles in corners, etc., providing excellent harborage for rodents.

2. The most common rodent pest was said to be the house mouse, with Norway/roof rats second and third. How are these rodents best controlled?

Robbins: Because most rodents are attracted to food processing facilities for the same basic necessities: food, water, and shelter, reducing food sources can help reduce attractants. That means sealing garbage cans and ensuring contents are emptied regularly and diligently, quickly picking up any loose raw materials that may inadvertently be dropped, and cleaning any waste materials from all surfaces and flooring. Vegetation management is often overlooked, but reducing overgrowth and weeds can reduce potential harborage, and cutting back trees or branches that touch the building can eliminate the potential of a “super-highway” by which rodents can find entry into the roof and ceiling areas.

Kelley-Tunis: The best method for controlling both rats and mice is through exclusion, though that is often difficult to accomplish. Therefore, manufacturing facilities must rely on additional methods to help prevent rodents from entering and infesting their facility, such as maintaining a strict sanitation program that prevents rodent access to food, water, and shelter. This not only includes cleaning practices normally associated with a sanitation program, but also having a process to identify and correct potential problem areas in the facility that could promote a rodent infestation. Facility employees also should be educated on what they can do to help prevent an infestation.

3. How do control and prevention differ for mice and rats?

Hottel: Mice and rats are more similar than dissimilar when it comes to prevention, but control efforts will be different with a somewhat wider range of trapping tools available for mice. Behaviorally, there are differences in approaches to the three species. Controlling an elusive rat once it gets inside a facility can be one of the most challenging situations a pest management professional can encounter — and it is just one more reason for good prevention programs to keep rodents out.

Robbins: Mice are extremely curious, whereas rats are very cautious. Rats will avoid unfamiliar or new things in their normal paths. So, a cunning strategy is needed to allow a rat to become familiar with traps. Rats are also attracted to water as they need it daily, whereas mice can extract water from food. Therefore, water becomes an important consideration for rat control and prevention. Mice tend to build nests in hidden areas near food sources, so it is critical that food processors manage food storage areas to ensure entry is restricted. Thus, cutting off food supplies and utilizing well-placed traps are some of the best ways to eliminate mice.

4. The vast majority of PMPs said that, in their markets, the number of rodent infestations have stayed the same or increased. With all the control efforts going on, why do you think fewer than 5.2% have seen any decrease?

Hottel: Rats are a community problem. If cities lack the funding to support good community-based control programs, you will see more rodents tied to these areas. Although the rats which have migrated onto the processors’ property may be controlled, there is another set of rats ready to move in. Funding for some of these community programs has been decreased in recent years, and we have seen increases in rat activity in these areas as a result. Food-storage practices have changed over the years, such as the holding of product rejects in trailers for use in animal feed also can impact rodent, insect, and bird activity around a facility. Not only can these feed trailers be an area for rodents to get food, but we have seen cases where rodents were transported from the animal feed handler to the food processor. Storing product for animal feed minimizes waste going to landfills, but it can increase the time that food waste remains on a food processor’s site. Additionally, because that trailer is dealing with waste, it may not receive the level of scrutiny needed in checking for pest activity.

Robbins: A number of factors have contributed to increased rodent populations. From the milder winters we’ve experienced that lead to longer reproductive cycles, to unusually long growing seasons with more natural food resources, rodent populations will thrive when supplies of food are plentiful and the environment is ideal.

Another factor is the general decline of natural predators, due to urban population sprawl. And because increased urban building can trigger rodent populations to spread, we’ve been seeing rodent populations increase in areas where they weren’t before. The roof rat, in particular, was previously a predominantly coastline problem. But industry research has shown that this rodent is now moving into new areas, gaining a foothold along transportation lines in the middle of the U.S. as well. Processors who have never had issues with roof rats may find themselves encountering these rodents for the first time.

Kelley-Tunis: Even though control efforts around facilities may have increased, the overall populations of rodents in the environment have not decreased. Our efforts only target those rodents that are trying to gain entry into our facilities, they don’t target the millions of other rodents that live everywhere else.

5. What do you find to be the best types of equipment or products, or combination of these, for rodent control — particularly in/around food processing facilities? Why?

Kelley-Tunis: Bait stations and traps, both single and multi-catch traps, remain the preferred method of control for rodents in and around a facility. These devices were designed to utilize the animal’s instinctive behavior against it.

Heath: In addition to baiting and trapping as the standards for rodent management service, facility staff efforts to maintain sanitation, eliminate harborage, and maintain the building for exclusion are important. This is an example of the partnership always necessary between service providers and food facilities. Fumigation for rodents is not very common, but it is sometimes necessary for quick resolution of a problem.

Robbins: There’s no roadmap to the “best rodent control” strategy because every facility is unique. The types of products being manufactured, geographic location, neighboring properties, climate — all can impact how and why rodents become a problem at a facility. The urgency with which issues need to be addressed also comes into consideration in choosing a control strategy. So, working with a pest control provider who understands the facility’s unique needs will result in the best program.

6. Do you rotate rodenticide products? Why/Why not?

Hottel: Flexibility is important, but different types and formulations of rodenticides should be tied to activity levels and purpose, rather than to a set calendar rotation system. There is a tradeoff between palatability and weatherability in baits. Some are formulated with increased weatherability but those same ingredients, such as wax content, can impact acceptance. This is a consideration and part of the selection process. If we are primarily in a monitoring mode, wax content may not be as critical a factor. Weather, such as spring or summer, is another consideration when bait melt or molding is more of a concern. Another consideration is activity; for example, if we want to determine if rodents are coming in from the exterior, baits or monitoring blocks with detection dyes would be selected.

Heath: Rotation of rodenticide products is not practiced quite as much as it should be. Products don’t need to be rotated as much for resistance management purposes as some would think, but rotating occasionally for a fresh taste, better palatability, etc., could help in many situations. Using soft baits in fall and winter and blocks in spring and summer when ant depredation is an issue makes lots of sense.

7. More than 75% of respondents see technology as able to help improve their ability to offer rodent control services. In what ways do you see it as helpful — or not?

Hottel: Technology and the way in which it helps us track and trend levels of activity is extremely helpful. It increases our ability to perform remote quality checks and direct technical support where needed. We look forward to remote monitoring devices and the role they will play in reducing the need for weekly inspections of traps and the ability to further customize programs to fit our clients’ needs.

Robbins: With the advent of the Internet of Things (IoT), technology certainly has a place in advanced rodent control strategies. Technology can be leveraged to help alert a facility to trouble, allowing problems to be quickly addressed and further control strategies implemented. Internet-connected devices will allow processors and their pest control providers to be notified when an individual trap or bait station experiences activity, allowing for resources to be dispatched as quickly as needed to determine the level of problem.

Electronic documentation (such as barcoding pest control devices) allows us to easily collect data on rodent infestations and our pest management program. This data can then be used to look at pest trends in a facility, such as which rodent pests are present during different months and rodent activity within specific areas of the facility over time. Knowing what the pest trends are in a facility allows us to make predictions about pest activity, where to focus pest prevention efforts, and any problematic areas to zero in on. As a result, pest control services for rodents can be highly targeted to specific pressures and the amount of rodenticide applications significantly reduced.

Kelley-Tunis: The continued advancement in technology will absolutely allow us to improve our rodent control offerings. In fact, the technology of the future will change what many rodent control programs look like.

8. In general, PCOs don’t feel that consumers really understand the health implications of rodent presence. Why is it important that management and workers in the food processing industry understand this?

Kelley-Tunis: It’s interesting, most consumers recognize that rodents do pose a health risk, but they think that these infestations tend to occur in areas where there are no control measures and poor sanitation exists. They don’t recognize that rodents can infest almost anywhere, especially a food manufacturing facility — even one with an already established control and sanitation program in place. Employees also must recognize that no place is immune from a rodent infestation and that little things, like closing a door or cleaning up any food debris, are important in keeping rodents out of a facility.

Heath: Consumers in general might not understand, but food processors are mostly very well attuned to pathogenic risks and audit standards/plant inspections where rodent activity evidence could be devastating to their business.

Hottel: Understanding the health implications can help increase support for sanitation programs by those who carry out the sanitation and exclusion efforts in the plant. Thus, it is critical to emphasize the amount of contamination that a single mouse can cause through its droppings, hairs, and urine. Linking that contamination to diseases such as Salmonella is equally important in gaining support to exclude and remove critical resources for these pests in the facility.

It is a pest management partnership and gaining support in that partnership on all levels leads to a more effective program.

The author is Editor of QA magazine. She can be reached at llupo@gie.net.

By Lisa Lupo

Filling positions in science, technology, engineering, and math (STEM) fields with qualified workers has become a global challenge impacting numerous industries, including that of food and beverage manufacturing. While a number of efforts are being initiated across the industry to address the issue (as discussed in Schooling for the Future, QA March/April 2017), the Kroger Manufacturing Division is leading a charge to fill the skills gap through its federally registered Apprenticeship Program.

It all started when Engineering, Maintenance, and Controls Supervisor Ray Gaites of the division’s Pontiac Foods plant in Elgin, S.C., was finding it difficult to get qualified electricians to work on the food processing equipment. So he suggested the plant begin an internship program. When the idea was forwarded to corporate human resources, the suggestion came back: “How about an apprenticeship?”

That conversation of 2010 eventually led to manufacturing-wide adoption of the initiative, with customized Registered Apprenticeship Programs at nearly all of Kroger’s 35 manufacturing facilities — and a goal of having a program at every location by the end of 2017, with at least 40 registered apprentices across the division.

“We had 35 plants crying out for help because they couldn’t find skilled labor; we had one plant that was 18 people down in maintenance,” said Stacey Rose, corporate brands and manufacturing human resources and labor relations senior manager. “So, we decided to start with the most painful points: highly skilled hourly maintenance mechanics and electricians.”

The Pontiac plant began with the electrical/electronic service operator (EESO) apprenticeship program because, as Gaites explained, “Recruiting experienced industrial electricians can be difficult and very time consuming,” because it is critical that vacancies are filled with qualified people. So, he said, “The apprenticeship program allows us to prepare for our future by cultivating talented individuals who can gradually and seamlessly transition into the fully qualified EESO slot.”

FOOD SAFETY & QUALITY. While the key focus of the program is that of electrical and electronic service and maintenance of the facility and its equipment, the program has significant impact on all operational aspects, including those of food safety and quality. “Any type of training has quality and safety as underlying factors,” said Site Leader John Bomba. “When you have people who are better at their skills, you have a better program, and you won’t have mishaps that can lead to foreign objects or contamination.”

The apprenticeship program focuses heavily on safety requirements, and participants learn about and become skilled in such aspects as the food-grade requirements of the equipment and line efficiency. This increases food quality and safety because, Bomba said, “If you have everything running well, it creates a safer environment for people and the same for food quality. When equipment goes down and you have to fix it, that’s when you have more exposure to contamination.”

It also is beneficial to have the expertise in-house, because employees have full knowledge of the equipment and operations in which it is run — and they have ownership in the results, Bomba said.

But it’s not an easy program. “I am very demanding,” Gaites said. “I have very high expectations. In this field, there are no second chances sometimes. I would hate if my lack of focus were to put someone in a compromising situation.”

A MANUFACTURING-WIDE PROGRAM. While many of Kroger Manufacturing’s apprenticeship programs focus on EESO, some facilities are implementing or developing other apprenticeships for positions such as lab technicians, industrial manufacturing technicians, roaster operators, and pasteurizers, as well as a corporate HR internship. Additionally, the HR intern, Tre’Von Howell, has been valuable in assisting the Pontiac plant with the rollout of a number of new positions and promotions, Rose said. “We’ve given all our plants the autonomy to design their own program within Department of Labor (DOL) apprenticeship requirements,” Rose said.

But, regardless of the field, “When we started looking at a registered apprenticeship program manufacturing-wide, we used the Pontiac plant, which had a functioning program, as a model, asking, ‘What has worked for you?’” Rose said.

All Kroger’s apprenticeship programs are registered with the DOL and work with local colleges and/or technical schools for applicable classes and accreditation. As explained by Bomba, a company working with the registered apprenticeship program hires or identifies a full-time employee for training to fit a company need, then constructs a four-year hands-on training and classroom experience. The employee’s wage can rise as training progresses in the program. At the end, the employee has a federally recognized credential certifying a broad-based level of training, adequate for hiring anywhere in the country.

Additionally, as one of the 230 DOL ApprenticshipUSA Leaders of Excellence in Apprenticeship, Development, Education, and Research (LEADERs), Kroger has committed to expanding apprenticeships across the U.S. and helping the program achieve its goal to “engage businesses and partners across all industries to discuss the value of apprenticeships and to encourage greater adoption of it as a workforce and talent development strategy.”

THE PONTIAC PROGRAM. “The program allows us to prepare for our future by grooming talented people,” Gaites said. The Pontiac Foods plant launched the program and hired its first apprentice, Sandra Simonds, in December 2011.

With Simonds now having completed the program, she works as an EESO. In the intervening year, the plant has added two additional EESO apprentices, Tim Moore, who is 6,000 hours into the 8,000-hour program, and Lisandra Diaz-Rivera who began her journey September 1, 2017.

While providing a federally registered career path, the Pontiac program also provides a significant wage progression, starting apprentices at an hourly wage of $14.55, with semi-annual increases over the four-year, 8,000-hour program as OJT and educational benchmarks are met. Upon completion, the employee’s income has increased to the hourly entry-level EESO wage of $23.03.

SANDY’S JOURNEY. Sandra Simonds was hired on December 5, 2011, as the facility’s — and Kroger Manufacturing’s — first EESO apprentice. Formerly an Army signal support system specialist, Simonds said, “I was in the military for four years; when I got out, I didn’t know what to do with my life, so I went to Savannah Technical College.” Deciding that she’d like to get into electrical engineering, Simonds got a job in residential and commercial wiring...then, in 2010, the housing market crashed and she was laid off. With the poor economy leaving her unemployed for over a year, she moved back home to South Carolina, where she saw Pontiac Foods’ ad on the web and immediately applied.

“She worked hard throughout the four-year program to learn and apply new skills and successfully completed it on December 5, 2015,” Gaites said. Five years later, Simonds is an integral part of the team on night shift, with the skills she learned as an apprentice and those she continues to learn every day having proven to be beneficial as she provides production and project support in addition to completing routine preventive maintenance tasks, he explained.

“The technical aspect of my job is so much different than in housing — that’s what I really like; it is challenging every day,” Simonds said. While she plans to continue her education to attain her electrical engineering degree, Simonds sees the fact that the apprenticeship program is federally recognized as being very important because of the opportunities it provides.

It was, in fact, Simonds who came up with the idea to tie the program in with a college to get it accredited, with courses counting toward a degree.

TIM’S JOURNEY. Pontiac’s second EESO apprentice, Tim Moore, was hired on July 7, 2014, as a production associate on night shift. “I saw the job opening at Pontiac and applied. Two to three weeks after I started, I found out about the apprenticeship program,” he said. Quickly realizing that line work was not his strength, “I was already looking to move up,” he said, so he asked one of the facility’s electricians about the program.

Even while Moore said he began begging Gaites for an opportunity, continually bugging him until he got the interview, Resource Leader Don Owczarczak said that he actually hired Moore with the intention that he would quickly move up. “We hired Tim to be a packer, stating, ‘You don’t belong as a packer, but we want you.’ So, we brought him into the plant knowing we would find a spot for him.”

“Even with no background in manufacturing or electrical, after interviewing him we were sure that he would be a good candidate for the program because of his determination and desire to succeed,” Gaites said, adding, “He has consistently met or exceeded expectations.” Not only has Moore completed 6,000 hours and all classes required for the industrial electrician certificate at Midlands Technical College, he has done it with an overall average grade of 92%.

“It has changed my life,” Moore said of the apprenticeship. “It has given me new skills and a lot higher earning potential.” Moore also plans to continue with his education to acquire a degree.

LISANDRA’S JOURNEY BEGINS. Prior to being selected as an apprentice, Lisandra Diaz-Rivera was in plant services. An electrician, who was impressed with her mechanical aptitude and work on the line, approached Gaites about interviewing her for an apprenticeship. While stating that he would like to develop a mechanical program at the plant, Gaites told her about the electrical program. “I thought it would be a wonderful idea,” Diaz-Rivera said. “It will help me grow professionally and learn about manufacturing, so I was very excited when I was selected.” Diaz-Rivera also works to improve her knowledge on her own by taking overtime hours on the lines. “When it’s available, I work the lines and learn how they run,” she said.

Along with Gaites and Pontiac Human Resources Manager Farisa McGowan, Simonds and Moore sit on the facility’s Apprenticeship Committee. The team provides ongoing assessment of the program, discusses issues, and suggests improvements.

LESSONS LEARNED AND ADVISED. While Pontiac Foods has retained the basis of its apprenticeship program, it has made changes throughout the years to improve the program and meet the continuing evolution of the industry. With the industry’s technological advances, some of the original classes are no longer relevant or are not offered by the partnering colleges, Gaites said. On the other hand, robotics has created a whole new area of training, and the plant has realized it needs to add more mechanical training.

“We’re still learning,” Gaites said. “Sandy (Simonds) had a harder time of it because of what we have learned since then.” For example, they now realize that the apprentices need more training in and a better understanding of the mechanical aspects of the equipment. “But we aren’t stopping her training even though she’s finished the program,” he said.

However, Bomba added, “it has to remain flexible once you start; you need to continue to discuss it and make improvements.”

For workers interested in participating in an apprentice program, Rose said, “It’s ideal for those who want to challenge themselves, as it’s constant learning. If you want to learn a trade that will last you a lifetime, it’s perfect.”

Rose is so passionate about the apprenticeship program — and its industry-wide expansion — that she regularly speaks at conferences about the initiative to spread the word and bring new workers into industry STEM positions.

“There is a complete skills gap in the industry, and we can’t just keep stealing from each other,” she said. “We need to create our own skilled labor force; it’s part of bringing skills back to America.”

The author is Editor of QA magazine. She can be reached at llupo@gie.net.

Rodenticides have never been in a more tenuous position. That’s not to say they are on their way out, but there is a lot of uncertainty surrounding them, and their long-term future is cloudy. At present, the regulatory landscape for rodenticides remains pretty steady at the federal level; but at least one state, California, could realistically, and drastically, alter its regulations in the coming months.

In February, Assembly Member Richard Bloom (D-Santa Monica) introduced an anti-rodenticide bill to the California General Assembly. The bill, AB 1687, a proposed amendment to section 12978.7 of the Food and Agricultural Code, proposes to ban all types of rodenticides (including first- and second-generation anticoagulants, bromethalin, and cholecalciferol) for structural pest management professionals and the public. Agricultural uses would be exempt. Wildlife advocacy groups are aggressively pushing the bill and are singular in focus on this issue.

This isn’t the first prominent rodenticide change in California. In 2014, the state changed the regulatory status of second-generation rodenticides, by far the most commonly used type of rodenticide, to restricted use. This means that only certified pesticide applicators, and those operating under their supervision, can purchase and apply second-generation anticoagulants in California.

This change was intended to keep a prominent group of rodenticides out of the hands of the public, who are not trained in pesticide application or safety, and often not inclined to read and follow label instructions. However, consumers are still able to purchase and apply first-generation rodenticides as well as bromethalin, an acute toxicant.

A vote on the bill will take place in early 2018, allowing time for additional non-target wildlife toxicological data to be collected and analyzed. Predators such as mountain lions, coyotes, and birds of prey are the driving force behind the proposed bill because they can ingest rodenticides by consuming poisoned rodents. While the incidence rate for unintentional predator poisoning is unknown, we should have a better idea in the coming months as more research is completed.

What we won’t know is the effect of rodenticide usage by certified structural pesticide applicators compared to public and agricultural uses. Science and common sense should be driving regulatory decisions, yet we know that isn’t always how things go.

According to Copesan Director of Technical Support and Regulatory Compliance Bennett Jordan, “In the world of worst-case scenarios, losing every rodenticide active ingredient would immediately present an incredible challenge to pest management professionals and anyone who has a facility that produces, processes, stores, or distributes food within California.”

TOM MYERS

The Food Safety Modernization Act (FSMA) is based on prevention and risk management, and exterior bait stations containing rodenticides are often the first line of defense outside food facilities. There are virtually always outside areas that are conducive to rodents and rodent pressures to match.

PREVENTION IS CRITICAL. Taking all feasible efforts to exclude rodents from your facility is a must, and prevention, with a strong exclusion strategy, is critical. But preventing rodent entry 100% of the time can be a tall task and does not account for human error.

Snap-traps can be used in bait stations in place of rodenticides, yet they require more frequent checks and cease to enable rodent capture once triggered. If the exterior of your facility is serviced monthly, a trap that is triggered in the first week leaves you unprotected for the rest of the month. The loss of rodenticides also would increase the length of time it takes a pest management technician to service the facility and necessitate more frequent service visits in some cases.

The real message for the lawmakers and citizens of California should be that commensal rodents pose a massive risk to public health. Most people are aware that mosquitoes and ticks can transmit diseases, but the laundry list of pathogens that rodents can vector should not be a well-kept secret.

Rodents are synonymous with filth, but it goes far beyond the “ick” factor. Rodents have been found carrying dozens of pathogens in their feces, urine, and saliva, including pathogens such as E. coli, Salmonella, Campylobacter, and many others. We must be very cautious about the impact of removing any type of rodent management tools from the hands of professionals with food safety and human health on the line.

A DRY ICE OPTION? On the other side of the country, Chicago, New York City, Boston, and the District of Columbia made headlines last year by applying carbon dioxide (CO2), in the form of dry ice, to rodent burrows to asphyxiate rats. The results were impressive and seemed to make a sizable dent in populations in notorious rat strongholds; not an easy feat.

The only problem is that these applications violated the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) because the dry ice was not labeled or registered for this use. However, in a collaborative approach with the Environmental Protection Agency (EPA) and an international rodenticide manufacturer, the EPA registration for a pelleted dry ice product was finalized this June.

Indeed, dry ice poses unique challenges for distributors and applicators because it has an incredibly short shelf life and must be stored and used under a very narrow range of conditions. But it does allow a new and highly effective option for controlling Norway rats in burrows.

While this is a welcome pest management tool, and will be an excellent approach to rodent control in some locations, it will not provide substantial relief against the house mouse and the roof rat, two rodent species that rarely burrow.

Clearly, rodenticides are a complicated and regulation-laden topic. As states and municipalities get creative in their approaches and accompanying legislation, it becomes increasingly important to communicate regularly with your pest management provider to ensure your IPM program both complies with appropriate regulations and maintains effective pest protection for your facilities.