FSMA pest control starts with one short rule, 21 CFR 117.35(c): no pests in any area of a food plant, effective measures to keep them out, and pesticides used only under precautions that protect food. That rule does not dictate a log, a map, or a retention period. Record duties come from elsewhere in Part 117, and only some plants trigger them. Investigators read pest records either way. What follows is our reading of the rule text, not legal advice; the facility’s qualified individual makes the final call.
Quick answer: Under FSMA, 21 CFR 117.35(c) requires food plants to exclude pests and use pesticides safely, but it sets no record format. Pest records become required records when the hazard analysis makes pest control a preventive control, and then 117.305 and 117.315 govern their content, timing, and two-year retention. Pest control food safety records outside the plan still get read by FDA investigators.
In this article
- What does FSMA pest control require in a food plant?
- When do pest control records become required FSMA records?
- What does an FDA investigator look for in pest control records?
- What should pest control records contain under Part 117?
- How should an activity finding become a corrective action?
- Where does connected monitoring fit in food processing pest control?
- Frequently asked questions
What does FSMA pest control require in a food plant?
FSMA’s Preventive Controls for Human Food rule is 21 CFR Part 117. Pest control sits in subpart B, the good manufacturing practices (CGMPs); record rules sit in subpart F.
The core text is 21 CFR 117.35(c), and it opens bluntly: “Pests must not be allowed in any area of a food plant.” The plant must take effective measures to exclude pests from production and holding areas, and pesticides are allowed only under precautions that protect food, contact surfaces, and packaging.
Neighboring rules come up on every visit:
- 117.20(a): grounds free of litter and weeds that harbor pests, and “inspection, extermination, or other means” if a neighbor’s lot is neglected.
- 117.35(a): buildings kept in repair. A dock door gap lands here.
- 117.35(b)(2): pesticide chemicals identified and stored so they cannot contaminate food.
- 117.37(f): rubbish handled so it does not attract or harbor pests.
Notice what is missing. None of these sections requires a written pest procedure, a log, or a retention period. The dietary supplement rule, 21 CFR 111.16, does require written pest control procedures; the human food rule sets an outcome and leaves the method to the plant. Animal food plants have parallel language in 21 CFR 507.19.
When do pest control records become required FSMA records?
Part 117’s record rules apply to “all records required by this part” (117.301). So does any section require your pest records? That turns on the plant’s hazard analysis.
Every facility under subpart C must write one (117.130), weighing facility condition and sanitation among other factors. Pests touch both.
Path A: pest control stays a CGMP program
Pest control has traditionally been a prerequisite program that supports the food safety plan without sitting inside it. In our reading, the subpart F rules then do not attach to pest records by name. They remain the plant’s evidence that its measures are “effective,” and investigators still ask for them.
Path B: pest control becomes a preventive control
A plant may instead decide that pest control, or part of it, is needed for a specific hazard. It can be written up as a sanitation control (117.135(c)(3)) or an “other control,” which the rule says includes “other current good manufacturing practices” (117.135(c)(6)). Now it must be written (117.135(b)), with monitoring, corrective action, verification, and the records listed in 117.190. Monitoring and corrective-action records are reviewed by or under a preventive controls qualified individual (PCQI) within 7 working days, unless a longer window is justified in writing (117.165(a)(4)(i)).
The PCQI also prepares or oversees the food safety plan (117.126(a)(2)), so the PCQI decides. The PCO advises. Some industry articles claim FSMA made pest control a preventive control at every plant. The rule text does not say that.
Our view: whichever path the plant takes, build pest records to the subpart F standard anyway. It costs little and removes an argument during an inspection.
What does an FDA investigator look for in pest control records?
In FDA’s fiscal 2025 inspection-observation data, pest control under 117.35(c) was cited 249 times, second among Foods citations behind foreign supplier verification (cited 483 times). The table counts only electronically generated Form 483s, so treat it as a floor.
The Dough-To-Go, Inc. letter (May 12, 2026) cited the grounds rule, 117.20(a), partly on the firm’s own records. Pest control reports dated October 22, 2025, documented heavy mice activity in exterior trap X4, hidden in overgrown vegetation. A separate 117.35(c) citation covered apparent gnats, an apparent rodent excreta pellet, and a dock door gap.
In the Marin Baking LLC letter (May 28, 2025), FDA cited 117.35(c) after finding rodent excreta pellets on a dry ingredient shelf. The firm described its fixes. FDA said it could not assess them without documentation “such as your pest control records.”
The common thread: investigators read the pest file, and a finding without a documented fix works against the plant. The perimeter counts too. Trap X4 was outside the building.
What should pest control records contain under Part 117?
Use 21 CFR 117.305 as the yardstick. It governs required records and makes a fair test for any pest file.
| 117.305 element | For pest records | Where sensor data fits |
|---|---|---|
| (a) Originals, true copies, or electronic records | Paper reports and platform records are both acceptable | Event history kept in the platform |
| (b) Actual values and observations | Counts, evidence type, device condition, not “OK” | Each event carries a detection type |
| (c) Accurate, indelible, legible | No pencil, no overwritten entries | System-generated timestamps |
| (d) Created at the time of the activity | Written at the visit, not rebuilt later | Events log as devices report; technician notes still get entered at the visit |
| (e) Enough detail to show a history | Trends can be reviewed from the file | Historical logs and trend data |
| (f) Plant, date and time, signature or initials | Every report initialed by whoever did the work | No initials on a sensor event; the technician’s response note supplies them |
That last row is the honest limit of sensor data. A device can report that something moved at a station at 2:10 a.m. It cannot say who looked, what they found, or what got fixed.
Required records are kept at least 2 years (117.315(a)(1)). Everything except the food safety plan may sit offsite if it can be produced within 24 hours, and electronic records accessible from the site count as onsite (117.315(c)). They must be promptly available for official review (117.320).
One detail surprises people: records kept to satisfy Part 117 are exempt from Part 11, FDA’s electronic records rule, unless another regulation also requires them (117.305(g)). That exemption comes from the rule, not from any software.
A typical pest file holds the written program, device list and map, service reports, pesticide records, trend reviews, and corrective actions; we cover how digital pest records change inspection preparation separately. Before service starts, agree with QA in writing on export format and on who keeps the history if the contract ends.
How should an activity finding become a corrective action?
If pest control is a preventive control, 117.150 spells it out. Written procedures must correct the problem, reduce the chance it recurs, evaluate affected food, and keep that food out of commerce when its safety cannot be assured. All corrective actions are documented.
If pest control stays a CGMP program, 117.35(c) still demands “effective measures,” and the Marin letter shows FDA still wants paper behind the fix.
A finding usually moves like this:
- Record the finding with time and location.
- Check nearby ingredients, packaging, and lines for exposure.
- Find the root cause and make the exclusion or sanitation repair.
- Close it with the date and the initials of the person who did the work.
- Review the trend. If the pattern repeats, ask the PCQI to revisit the hazard analysis.
The technician’s side belongs in a written technician response protocol. A connected sensor gives it an earlier, more specific first entry than the next scheduled visit would. Put one caution in every protocol: a missing check-in is a service exception, not proof that the location is quiet.
Where does connected monitoring fit in food processing pest control?
At selected points, not everywhere. Think exterior traps like X4, docks and receiving, and locked or after-hours spaces where activity recurs or checks are hard. The site risk assessment decides which stations get a sensor.
In pest control for food industry accounts, the GTO system emails configured recipients the sensor location, timestamp, and detection type (motion, vibration or shock, or temperature). It keeps activity logs and trend data. Name devices exactly as the plant’s device list does, or records and map drift apart.
The system does not create compliance or cover points without sensors. Time-stamped event, device, and response records can support a facility’s pest control evidence when tied to the site map and corrective-action process, but the platform does not certify compliance or guarantee an inspection result.
Food manufacturing pest control also has physical constraints. The GTSensor 4.0 fits many standard traps and bait stations; confirm GTSensor trap and station compatibility during the site survey. The enclosure is rated IP51, so keep sensors out of washdown and direct-spray zones. Sensors run on batteries and talk over LoRa 915 MHz to the gateway.
Check the GTConnect gateway requirements early: a standard power outlet and 4G cellular, with other options to confirm with Rook Pest. Test coverage at the planned points before rollout.
Start with a 90-day pilot at a handful of problem points. For sites that also hold a GFSI certification, our article on HACCP, BRCGS and IFS programs covers the scheme side.
Frequently asked questions
Is pest control a food safety program under FSMA?
Yes, at minimum as a CGMP under 21 CFR 117.35(c). Whether it is also a preventive control in the food safety plan depends on the facility’s hazard analysis, and the PCQI makes that call.
Does FSMA require a written pest control program?
Section 117.35(c) does not require written procedures by itself. Preventive controls must be written (117.135(b)), so a written program is required if pest control is in the food safety plan.
How long do FSMA pest control records need to be kept?
Records required by Part 117 are kept at least two years after they are prepared (117.315(a)(1)). Part 117 sets no retention period for pest records outside the food safety plan. Many plants keep them two years anyway.
Does FDA accept electronic pest control records?
Yes. Section 117.305(a) allows electronic records, and 117.315(c) treats them as onsite if they can be accessed from the site. They still need a date and the initials of whoever did the work.
Does a quiet sensor report prove there are no rodents?
No. Sensors cover only the points where they are installed, and an absence of alerts does not prove an absence of activity. Inspection by a trained technician still covers everything the sensors do not.
If you service food plants or run QA at one, bring the PCQI into the conversation from the start. Talk with Rook Pest about a monitoring pilot at your highest-risk or hardest-to-reach points.