FDA 483 OBSERVATION · #27 OF 1,923 MOST-CITED

Lack of effective pest exclusion

FDA cited this observation 780 times across 745 firms in recent inspections. Below: how it breaks down by program area and fiscal year, and real examples of how FDA worded it on Form FDA 483.

What this grouping is not

An observation-type page groups FDA’s published citation records. The grouping, the compliance steps and the root causes are SPEQ synthesis, not an FDA classification of any citation, and a count measures what FDA published rather than risk.

BY PROGRAM AREA
Foods780
BY FISCAL YEAR
FY20208
FY201918
FY2018112
FY2017329
FY2016313

What this observation means, and how to comply

SPEQ's practitioner reading of this finding. The regulatory basis is a cited fact; the interpretation, compliance steps, and root causes are SPEQ synthesis — not an FDA classification of the citation.

21 CFR 117.35(c)

The plant did not take effective measures to exclude pests from the facility — as distinct from having pests present, this is the failure of the exclusion measures (seals, barriers, controls) meant to keep them out.

Why FDA writes it — Pest exclusion is a preventive control: keeping pests out is more reliable than removing them once inside. When exclusion measures are ineffective, the plant is open to a recurring contamination vector, so FDA cites the inadequate exclusion even where active infestation is limited.

HOW TO COMPLY
  • Take effective measures to exclude pests from manufacturing, processing, packing, and holding areas and to protect against contamination.
  • Seal entry points — doors, walls, utility penetrations — and maintain barriers that keep pests out.
  • Maintain grounds and waste handling so pests are not attracted to or harbored near the facility.
  • Monitor with devices and inspections, and treat sightings as a signal to find and close the entry route, not just to remove the pest.
WHY FIRMS GET CITED
  • Reliance on trapping/treatment inside rather than sealing the structural gaps that let pests in.
  • Unsealed entry points and poor exterior maintenance that continually invite pests.
PROFESSIONAL · REMEDIATION PLAYBOOK · SPEQ SYNTHESIS

How to close this finding — and stop it recurring

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What this observation is associated with

Firms cited for this observation also appear in FDA compliance actions — warning letters, injunctions, or seizures — at 1.2× the rate of the average FDA-cited firm (9.1% vs 7.8%), across 745 FEI-matched firms.

This is an association, not causation, and reflects co-occurrence in FDA's records — not a claim that the observation caused or preceded the action.

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How FDA worded it — real examples

Effective measures are not being taken to exclude pests from the processing areas and protect against the contamination of food on the premises by pests.

Great Harvest · Indianapolis, Indiana · Foods · 2020-03-09

Effective measures are not being taken to protect against the contamination of food on the premises by pests.

Quarrymen Coffee Roasting Co. · Bloomington, Indiana · Foods · 2020-01-10

Effective measures are not being taken to exclude pests from the processing areas and protect against the contamination of food on the premises by pests.

Orangeburg Pecan Company Inc · Orangeburg, South Carolina · Foods · 2019-11-19

Effective measures are not being taken to exclude pests from the processing areas and protect against the contamination of food on the premises by pests.

Hot Mama's - Belize LTD · Floral Park · Foods · 2019-11-14

Effective measures are not being taken to exclude pests from the processing areas and protect against the contamination of food on the premises by pests.

Rivera's Factory Inc. · Manassas, Virginia · Foods · 2019-10-24

Effective measures are not being taken to exclude pests from the processing areas and protect against the contamination of food on the premises by pests.

Southwest Airlines Inc. · Indianapolis, Indiana · Foods · 2019-10-21

Related SPEQ references

Where to read the requirements behind this observation area on SPEQ. These are SPEQ's topic and audience pages — not an FDA classification of the citation.

Contamination control →Food industry →

Examples are a representative sample of FDA's published inspection observations. Open the 483 observation explorer →