The Nemesis® X isn’t meant for the production line – and may be evaluated for certain back-of-house spaces when installed in a manner consistent with the FDA Food Code – applicable local adoption – site policy – audit standards – and customer requirements.
PestWest built it as a flying insect pest electrocution system – not a glue board ILT. Inside the housing are two Quantum® X LED filament lamps – each rated 370 nm UVA with unique 360° LED UVA technology. The system draws 19 Watts – “should be left operating 24/7/365” –  and the I4U calls for replacing the Quantum® X LED lamps “at least once every 3 years.”
Quantum® X LED lamps are FEP shatter-resistant coated – which matters because the FDA Food Code addresses lighting protection.
“6-202.11 Light Bulbs, Protective Shielding.”
“(A) Except as specified in ¶ (B) of this section, light bulbs shall be shielded, coated, or otherwise shatter-resistant in areas where there is exposed FOOD; clean EQUIPMENT, UTENSILS, and LINENS; or unwrapped SINGLE-SERVICE and SINGLE-USE ARTICLES.”
“(B) Shielded, coated, or otherwise shatter-resistant bulbs need not be used in areas used only for storing FOOD in unopened packages, if:”
“(1) The integrity of the packages cannot be affected by broken glass falling onto them; and”
“(2) The packages are capable of being cleaned of debris from broken bulbs before the packages are opened.”
And insect control device placement.
“6-202.13 Insect Control Devices, Design and Installation”
“(A) Insect control devices that are used to electrocute or stun flying insects shall be designed to retain the insect within the device.”
“(B) Insect control devices shall be installed so that:”
“(1) The devices are not located over a FOOD preparation area; and”
“(2) Dead insects and insect fragments are prevented from being impelled onto or falling on exposed FOOD; clean EQUIPMENT, UTENSILS, and LINENS and unwrapped SINGLE-SERVICE and SINGLE-USE ARTICLES.”
Nemesis® X – in its own I4U – identifies the system for “use within non-food/non-feed areas” and tells you – “Do not place adjacent to, or over, food preparation areas, food contact surfaces, exposed food, food ingredients, raw materials, and food packaging.”
That “adjacent to” buffer is a precaution. Follow the I4U and you are building in a conservative placement approach that is intended to assist facilities in evaluating installations against the cited FDA Food Code provisions – provided the authority having jurisdiction (AHJ) – local code – site policy – audit standards – and customer requirements allow the Nemesis® X installation.
Examples of locations that may warrant evaluation for installation under applicable regulations, facility policies, audit standards, customer requirements, and AHJ approval…
- Receiving areas – “suspend at least 8.2 ft (2.5 m) above floor-level and clear of forklift trucks.” – that height is from the I4U.
- Suspend it 10-15 ft inside – and perpendicular to – each receiving door – with the bottom of the Nemesis® X above the top of the door – offset from direct airflow – and away from exposed product zones.
- With 240 to 280 m2 (~2580 to ~3000 ft2) suspended coverage – it can pull flying insect pests laterally before they ride air currents inward.
- Electrocution ILTs are often used as flying insect control en masse captors for receiving areas precisely because they intercept at entry points – not over product.
- Dry warehouses and packaging storage – wall-mount for 120 to 140 m2 (~1290 to ~1500 ft2) of flying insect pest pull coverage along perimeters – near compactors and corrugate.
- Mount Nemesis® X high on columns to pull flying insect pests away from racked, sealed-item storage areas – never over them.
- Fragment-control is addressed by distance placement – retained-catch design – and keeping the catch tray in place – final acceptability depends upon the authority having jurisdiction (AHJ) – and site conditions.
- Segregated ingredient rooms – sealed – intact containers only – where placement does not put the system over or adjacent to ingredients – raw materials – food packaging – or exposed food-contact surfaces while maintaining alignment with the requirement that devices are “not located over a FOOD preparation area.”
Run it like an inspector would.
- Keep the tray in – flying insect pest retention is a design expectation under the cited FDA Food Code provision – not just good sanitation.
- An electrocutor without its tray will not satisfy the requirement to “retain the insect within the device.”
- Empty the tray weekly or as the site requires.
- The I4U says – “Always assess insect species within the catch tray for trends and root cause analyses.”
- Root cause analyses – log species and counts – that log supports evidence of monitoring – retention checks – and corrective action.
- Clean dry – the Nemesis® X is IP20 – and the I4U warns against use in “wet areas or outdoors.”
- Clean it per the I4U.
- Replace both Quantum® X LED lamps at the three-year mark – UVA fades – you don’t see it.
- Map it – put the flying insect pest electrocution system height – setback – and coverage circles on the master sanitation plan.
- Inspectors look for the two tests – not over prep and no pathway for fragments to reach food or clean tools.
- Know your plant type – in facilities where the FDA Food Code – or a state-local code based upon it – is used as the applicable standard – the placement described is a conservative approach that supports alignment with the cited provisions – provided local code – site policy – audit standards – customer requirements – and the authority having jurisdiction (AHJ) allow it.
- In USDA-FSIS or GFSI-audited facilities – customer specifications – audit schemes – or facility policies may be more restrictive than the FDA Food Code placement language and may require glue-board ILTs where product or product-contact materials are exposed.
- Use the Nemesis® X strictly in “non-food/non-feed areas” – receiving – warehouses – and maintenance corridors.
The goal is to install and maintain the Nemesis® X in a way that aligns with the cited 2022 FDA Food Code provisions where adopted and applicable. Done this way – flying insect pest electrocution stays at the dock – not over the line.
Reference note: U.S. Food and Drug Administration, Food Code 2022, January 18, 2023 – version. Citations include § 6-202.11, “Light Bulbs, Protective Shielding,” and § 6-202.13, “Insect Control Devices, Design and Installation.”
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Disclaimer: This article is provided for general informational and educational purposes only and does not constitute professional, legal, medical, veterinary, engineering, regulatory, or other professional advice. Always read, understand, and follow all product instructions for use, pesticide labels where applicable, and all applicable federal, state, provincial, and local laws, regulations, and requirements. Final installation, deployment, and use decisions should consider the authority having jurisdiction (AHJ), facility policies, audit and certification standards, customer requirements, manufacturer instructions for use, and site-specific conditions. Any references to the FDA Food Code, USDA-FSIS-regulated facilities, or other regulatory, audit, or industry standards are provided solely for educational purposes and do not constitute approval, endorsement, certification, listing, or acceptance of any product, installation, deployment, or practice by the U.S. Food and Drug Administration (FDA), USDA-FSIS, or any regulatory agency, certification body, audit scheme owner, customer, or authority having jurisdiction. Users are responsible for complying with all applicable requirements and for exercising their own independent professional judgment.
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