FDA September 3rd, 1987
Food and Drug Administration October 30, 1987 David W. Gilbert II After reviewing the 45-day data from USDA on mean daily catches of houseflies and stable flies in dairy barns, I believe you are correct that a statement in the 9/3/87 Interpretation on Devices for Electrocuting Flying Insects is likely to be misinterpreted. To correct this situation, the paragraph in question will be rewritten as follows:
You may use this letter as a clarification to the 9/3/87 Interpretation. When the Interpretation is next reissued, this change will be incorporated. Sincerely, Thomas L. Schwarz
Applicable Codes/Sections This supersedes the Interpretation dated 8/11/86. Changes in the text are identified by asterisks in the margin; the format has been updated. Issues/Problems Are devices designed to electrocute flying insects effective and acceptable for use in retail food establishments? Interpretation Devices designed to electrocute flying insects can be effective against some pests of public health importance and are acceptable for use if they are positioned so that dead insects are prevented from falling on exposed food, food-contact surfaces, surfaces or clean equipment/utensils, and have "escape-resistant" trays which are emptied at least weekly. Proper positioning of devices in areas where food and food-contact surfaces, equipment and utensils are exposed means:
Center for Food Safety and Applied Nutrition, Additional Regulatory Information In addition to the public health concerns addressed in the model food codes, there are employee safety concerns about these pieces of equipment. Some of these are addressed in Title 29 Code of Federal Regulations (CFR) 1910.301 and 1910.304 and 1910.399 (Occupational Health and Safety Administration). Of particular note are requirements that:
Other concerns about employee safety have to do with human exposure to the radiation hazards of such equipment. Questions include whether the ultraviolet light could cause acute or chronic health problems to persons exposed to the device. Potential short term problems of concern would include skin burns. Questions about possible effects of long term exposure relate to premature skin aging, skin cancer and hazards to the eye such as the formation of cataracts. FDA has measured ultraviolet radiation from a typical insect attracting device and has concluded that there is not a significant concern about acute health problems. The conclusion was based on Threshold Limit Values (TLV) of exposure as recommended by the American Conference of Governmental Industrial Hygenists (ACGIH) as presented and discussed by Phillips (1983). Questions about the health effects of long-term exposure are still unanswered. For this reason it might be prudent for operators to position these devices so that employees are not required to work continuously in close eye level proximity. Discussion/RationaleThe model food sanitation codes require that "effective" measures be taken to minimize the presence of flies and other insects on the premises of a retail food establishment. At the same time food must be protected from potential contamination. To control insects without resorting to poison which can inadvertently contaminate food, pest control consultants are recommending installation of insect electrocutors. These devices contain an attracting light and an electric grid. Fluorescent or ultraviolet bulbs are used as the light source(s). Insects flying toward the light and between the grids cause a high-voltage, low amperage arc which electrocutes the insects. Effectiveness * Light in the 330-350 nanometer (nm) wavelength seems to be the most effective in attracting houseflies, one of the primary target pests. Ultraviolet bulbs called "black light" (BL) and "black light blue" (BLB) emit light in the appropriate range of wavelengths. Electrocutors use BL or a combination of both types of ultraviolet bulbs since BLB bulbs alone have not proved to be as effective as BL bulbs in attracting houseflies and are considerably more expensive. (See Cover Letter above.) Recent tests of bulb combinations have failed to show any significant difference between ......... using BL bulbs alone and .... using a combination of BL and BLB bulbs, in so far as effectiveness in attracting houseflies is concerned. Insect electrocutors are not a panacea. In fact, Lillie and Goddard noted that improper placement of electrocutors "may actually increase the problem with some insects." Rather, they should be considered as supplemental to good sanitation practices - effective exclusion (screening, properly installed air curtains and self-closing doors), effective cleaning of equipment surfaces and areas subject to food debris, and proper storage and disposal of garbage> * It is important to realize that insect electrocutors are not effective for all insect pests and situations:
Acceptability Properly installed and maintained insect electrocutors can be effectively used with little concern in several areas of food establishments. These include receiving areas, corridors and refuse areas. The main concern related to acceptability involves the placement of the insect electrocutors within the food handling area. If improperly situated, dead insects could be impelled by the electric charge or simply fall or be blown from the device onto food, food preparation surfaces or clean food equipment/utensils. This could result in food being adulterated with dead insects or insect parts or possibly with viable microorganisms carried by the dead insects. Ceiling hung traps pose the greatest threat in that they spread insects the furthest. It is therefore important that the device be placed low and far enough from exposed items that dead insects will be of no concern. An additional concern regarding acceptability is the maintenance of the devices. The dead insect carcasses in the catch tray of the electrocutor could become a food source for breeding Dermestids (larder beetles, museum beetles, carpet beetles). Also, eggs of dead insects may hatch and the larvae develop within an unemptied catch tray. Either of these scenarios would result in an ongoing insect infestation of the establishment unless the collection trays are cleaned frequently enough to interrupt the the reproduction cycle - at least weekly. By checking the identification of insects in catch trays, one can use the information to determine potential insect problems such as types of insects entering or establishing breeding populations within the establishment. References Agee, H.R. and R.S. Patterson. 1983. Spectral sensitivity of stable, face, and horn flies and behavioral responses of stable flies to visual traps (Diptera: Muscidae). Environ. Entomol. 12: 1823-1828. Baker, R.R. and Y. Sadovy. 1978. The distance and nature of light trap response of moths. 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