16.3 Integrated Pest Management

Pests are a facilities problem before they are a chemical problem. A cockroach on the make line during Saturday service means the building already offered access, food, water, or shelter. Integrated pest management (IPM) is the Food Code-aligned way to take those invitations back, then let a licensed pest control operator (PCO) use pesticides only where they will not become a food contaminant.

Deny Access

Pests enter through the openings you stop noticing. IPM starts with the building envelope:

• Screens on windows and vents that open.
• Door sweeps and weather stripping on exterior doors, including the dock.
• Self-closing doors that actually latch; a brick used as a doorstop is an open invitation.
• Sealed holes around pipes, conduit, and the grease-line chase. A pencil-width gap is a mouse highway.

Inspect deliveries. A case of buns can arrive with roaches. Break down and remove cardboard; do not park incoming product against a dumpster wall and then against the flour rack.

Deny Food, Water, and Shelter

A clean, dry, sealed storeroom is hostile habitat.

• Clean under equipment and along wall-floor junctions (that cove base from 16.1 exists for this).
• Store food in sealed containers, not open bags.
• Keep product 6 inches off the floor so you can clean and so you can see droppings and rub marks.
• Fix leaks. A drip under the dish machine is a water fountain.
• Empty and recycle cardboard promptly. Corrugated board is a roach hotel.
• Wipe grease. Roaches follow kitchen fat the way rodents follow grain.

If the night crew leaves bus tubs of food soil and a leaky soda gun, no PCO contract will look successful on Monday.

Work With a Licensed PCO

The PIC does not apply restricted-use pesticides. That is the PCO’s license, not the CFPM certificate. The PIC’s job is to:

• Choose a licensed operator who will inspect, identify, treat, and document.
• Walk the building with the PCO: dock, dry storage, dish pit, bar, employee lockers, and the exterior pad.
• Keep service reports. Inspectors will ask what you found and what you changed.
• Do the sanitation the PCO cannot do for you.

A monthly spray with no inspection, no sanitation, and no exclusion is not IPM. It is perfume over a nest.

Identify the Pest

Treatment follows identification. Learn the signs the exam uses:

One dropping is a sign. “We only saw one” is not a pass.

Pesticides, Traps, and What Never Belongs in Food Areas

Restricted pesticides stay with the licensed PCO. If an employee “brought something from home,” stop, isolate it, and treat it as a chemical hazard.

Pesticide storage in the operation (when any general-use product is even on site): locked, labeled, and away from food, utensils, linens, and single-use items — the same isolation rule as other chemicals.

Glue boards and traps go along walls and in corners, never on a prep table, never above open food. Check them on a schedule. A forgotten glue board under a cooler is evidence, not a program.

Never use tracking powder in food areas. It is a toxic dust that becomes a food contaminant. Never place bait where it can fall into food, sit on a cutting board, or be dragged by a rodent across a prep surface. If bait is used at all, the PCO places tamper-resistant stations in locations that cannot contaminate food — typically the exterior or non-food mechanical spaces, following the label and the jurisdiction.

Live Animals: §6-501.115 and the Five Exceptions

Pest control and animal control are different rules with the same goal, and NRFSP names the second one as its own task — 811 Enforce Animal Standards. §6-501.115(A) is the baseline: live animals may not be allowed on the premises of a food establishment (Priority Foundation). Then the Code lists narrow exceptions, each conditioned on contamination of food, clean equipment, utensils, and linens, and unwrapped single-service and single-use articles not resulting:

Two more paragraphs matter. (C) allows live or dead fish bait to be stored if contamination cannot result. And (D) — one of the 2022 edition's better-known changes — allows a food establishment to permit pet dogs in outdoor dining areas if approved by the regulatory authority. Note the condition: approval, not a default right. A patio that puts out water bowls without asking the health department is not operating under (D).

The manager's job here is a short, teachable policy: service animals are welcomed in the dining room and kept out of prep, staff never ask for documentation of a service animal's training, pet dogs on the patio only if your jurisdiction approved it, and no animal — including a staff member's dog "just in the office" — in food prep, storage, or warewashing areas. Handwashing after contact with animals or service animals is already on the 6.2 trigger list for a reason.

Pests During Service

Seeing a pest on the line is a now problem, not a Monday work order.

1. Protect food. Cover, move, or discard product that may have been contaminated. A roach in the garnish pan means that pan is gone.
2. Close the affected area if you cannot protect food and equipment. Do not plate around a mouse.
3. Call the PCO for identification and treatment. Do not fog the kitchen yourself.
4. Notify the PIC immediately if the PIC is not already running the response.
5. If the infestation is an imminent health hazard (uncontrolled rodents or roaches in food, widespread contamination you cannot contain), stop service and notify the regulatory authority, the same posture as sewage in 16.2 and 16.4.

Scenario: Cardboard City in Dry Storage

A storeroom keeps flour on the floor in open bags, soda syrup boxes stacked against an unsealed pipe chase, and a drip from the walk-in condensate line. The PIC finds rub marks, droppings, and shredded nests. Spraying the aisle is the wrong answer. The right sequence is seal the chase, get food into containers 6 inches off the floor, fix the leak, pull the cardboard, set wall-line traps with the PCO, and keep bait out of the food room. The exam will offer tracking powder “to see where they run.” Tracking powder in a food area is always wrong.

Exam Traps

• Applying the pest rule to animals and forgetting §6-501.115: service animals belong in customer areas but not in prep, pet dogs on a patio need regulatory authority approval, and institutional-care pets are allowed in common dining areas only outside meal times.

• Employee-applied restricted pesticide or a fogger over food.

• Tracking powder or open bait in prep or storage.

• Traps in the middle of the room instead of along walls.

• Food stored on the floor or in open bags “until the PCO comes.”

• Treating one live roach as a fluke instead of a sanitation and exclusion failure.

• Keeping the dining room open through an uncontrolled infestation.