Threshold Action Plans & Pest Trend Analysis in Food Facilities

September 2024 Edition:

Paul Gough, ACE 
Corporate IPM Manager 
FSS, Inc. 

Threshold action plans. Trend analyses. These are two essential and interrelated parts of a successful food safety pest management program, which are commonly required by food safety audit standards. But what they look like or consist of is left to the imagination, and too often they are treated as formalities satisfied with checklists and graphs that provide little value. 
In the Mallis Handbook of Pest Control, 10th Edition, Jeffrey Tucker, BCE, defines Structural Integrated Pest Management: 
“Structural integrated pest management (SPM) is an approach…to determine if, where, what, and when pest management intervention is needed…to keep pest numbers low enough to prevent annoyance, structural or property damage, disease transmission, or violations of regulatory/statutory requirements.” 
A threshold action plan defines what pest quantities, locations, and behaviors trigger intervention, and what those (often progressive) interventions should be. This should be a living document, revisited regularly based on trend analysis and evaluation. The pests included are based on a pest risk assessment of the facility, taking into account the structure, processes, products, environment, and history to determine what pests to establish thresholds for at what levels. This is a useful tool to decide ahead of time how to respond to pest activity. SOPs can be put in place, responsibilities assigned, suppliers notified, and budgets established in advance so that response to pests is a plan, not a crisis. 
A trend analysis is an evaluation of how pest activity is developing or changing over time, and how corrective actions have affected those trends. This analysis can determine whether pest risks are shifting, which thresholds are being exceeded, and whether corrective actions have been effective. Evaluation can either demonstrate that the program is working, or lead to revision and improvement. 
What’s most important (and most often neglected) is the partnership and interaction between the pest management professional and the customer. The development and review of a threshold action plan should be site-specific, and the thresholds and corrective actions included must be agreed upon, practical, and helpful. Otherwise the plan ends up being a burden and source of stress for everyone involved that ultimately goes ignored.  
Trend reviews should involve active review and discussion of program data, typically available via online portal tools, that the service provider and customer can review together. This should include pest activity and sightings, corrective actions implemented and their effect on activity, and trends over various time scales to account for seasonality and notable events like construction, extreme weather, and changes to processes or products. Conclusions, action plans, and recommended updates to the program should be documented, with the goal of demonstrating that the IPM program is actively managed and responsive to changing needs.