BB Guns: An Ineffective Rat Control Program

FDA once seized food from a warehouse that had a rat infestation problem, which unsurprising violates the Food, Drug, and Cosmetic Act. A food is adulterated “if it has been prepared, packed, or held under insanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health.” FDCA, Section 402(a)(4). To clarify this statutory requirement, FDA created current Good Manufacturing Practices (cGMPs) for making, packing, or holding food and these regulations specify that pests (like rats) are not allowed in a food facility. Furthermore:

Effective measures shall be taken to exclude pests from the processing areas and to protect against the contamination of food on the premises by pests. The use of insecticides or rodenticides is permitted only under precautions and restrictions that will protect against the contamination of food, food-contact surfaces, and food-packaging materials.

21 C.F.R. 110.35(c) (old regulation); 21 C.F.R. 117.35(c) (new regulation)

There have been many food seizures due to a pest infestation over the last 100+ years. What makes this one standout: the warehouse used a BB gun as a pest control measure.

Alas it was not effective. Also, it raises the risk that a missed shot could become embedded in a food, which would raise a different adulteration charge (although FDA did not indicate if they found any embedded objects in any food).

While BB guns should be avoided, “Guard, guide, or pest-detecting dogs may be allowed in some areas of a plant if the presence of the dogs is unlikely to result in contamination of food, food-contact surfaces, or food-packaging materials.”

Question, could I use a pest-detecting and deterring cat instead?

Sources:

FDA Consumer (July-August 1998), page 39.

The Redwood Gazette (November 24, 1932), page 8 (ad modified by the author).

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