6.5 Assessing Pest Control Practices & Employee Behaviors
Key Takeaways
- Blueprint task B.17 requires assessing pest control practices, and tasks B.7 and B.8 require evaluating employee behaviors and hygienic practices.
- Assessing pest control means reading the service reports and device map, not just looking for pests; the absence of sightings is not evidence of control.
- Rodenticide bait stations are permitted outside the building perimeter but not inside food areas, and only a licensed applicator may apply restricted use pesticides.
- Employee behavior is assessed by observation over time, not by asking; handwashing frequency at task changes is the highest-yield single observation.
- Findings about employee behavior must be documented as observed facts with time, location, and action, never as characterizations of the employee.
6.5 Assessing Pest Control Practices & Employee Behaviors
Exam Tip: Chapter 3 covered developing an IPM plan and hygiene policies. This section is about assessing them in the field. The distinction matters because Area B items ask what you would look at and what a finding means, not what the program should contain.
Assessing Pest Control: Read the Program First
Seeing no pests during a two-hour visit tells you almost nothing. Most pests of consequence are nocturnal or cryptic. The program documentation tells you far more.
| Document | What to look for |
|---|---|
| Service reports | Frequency matches the contract; findings are specific rather than "no activity noted"; recommendations from prior visits were acted on |
| Device map / floor plan | Every device numbered and located; devices found in the field match the map |
| Trend log | Catch counts over time by device — a rising trend at the receiving door is actionable intelligence |
| Applicator license | Current, and correct category for the site |
| Pesticide labels and SDS | On file for every product used; the label is the law |
| Corrective action log | Structural and sanitation deficiencies identified by the pest contractor were fixed, not merely reported repeatedly |
The most diagnostic single question: has the same recommendation appeared on the last six service reports? A pest contractor writing "seal gap at rear door" every month for six months is documenting the operator's failure to act.
Reading Pest Evidence
| Evidence | Interpretation |
|---|---|
| Droppings, 1/2–3/4 inch, blunt ends | Norway rat |
| Droppings, 1/2 inch, pointed ends | Roof rat |
| Droppings, 1/8–1/4 inch, pointed | House mouse |
| Rub marks / grease trails along walls | Established rodent runway; indicates ongoing, not incidental, activity |
| Gnaw marks on packaging or structure | Active infestation |
| Burrows outside along foundation | Norway rat harborage |
| Fluorescent trails under UV | Rodent urine |
| Egg cases (oothecae) | Cockroach breeding on site, not merely transient |
| Live cockroaches in daylight | Heavy infestation — populations only forage in light when harborage is saturated |
| Small flies at drains | Drain fly or fruit fly breeding in organic film; a sanitation problem, not a pesticide problem |
| Stored product pest webbing in dry goods | Infested product; check supplier and rotate stock |
Where you find evidence matters as much as what you find. Evidence in a food storage or preparation area is a Priority-level finding; evidence in an unfinished exterior mechanical space is a control opportunity.
Pesticide Use Rules to Verify
- Only a certified, licensed Pest Control Operator may apply restricted use pesticides in a commercial food facility. General use products may be applied by trained staff only in accordance with the label.
- The label is the law. Application inconsistent with the label — wrong site, wrong rate, wrong equipment — is a federal violation under FIFRA.
- Rodenticide bait may be used in tamper-resistant stations outside the building perimeter. Inside food storage, preparation, and service areas, only mechanical devices — snap traps, multiple-catch traps, glue boards where permitted — are appropriate, because a poisoned rodent that dies in a wall void becomes a contamination and odor problem.
- Insect light traps must be located so that they do not attract insects toward food, and so that captured insects and fragments cannot fall onto exposed food or food-contact surfaces. Mount them away from doors and away from exposed food, and use glue-board rather than electrocuting styles over food areas.
- Food, equipment, and utensils must be protected or removed before any application, and surfaces cleaned afterward.
- Pesticides must be stored in their original labeled containers, in a locked area, physically separated from and below food and single-service articles.
Assessing Employee Behaviors and Hygienic Practices
Blueprint tasks B.7 and B.8 are separate: behaviors (what people do with food and equipment) and hygienic practices (personal cleanliness and health).
Observe rather than ask
Asking "do you wash your hands after handling raw chicken?" produces a reliable yes. Standing where you can see the handwashing sink and the raw prep station for fifteen minutes produces data. Position yourself so you can see without directing attention at any one person, and observe long enough to see task transitions.
The highest-yield observations
| Observation | Why it matters |
|---|---|
| Handwashing at task changes | The single best proxy for hygiene culture. Watch specifically for: after handling raw animal food, after touching the face or hair, after handling money, after taking out refuse, after using the restroom, before donning gloves |
| Handwashing technique | Water at least 100°F, soap, at least 10–15 seconds of vigorous friction, thorough rinse, dry with a single-use towel or air dryer |
| Bare-hand contact with ready-to-eat food | A Priority violation. Watch garnish, bread, sandwich assembly, and salad plating |
| Glove misuse | Wearing one pair across multiple tasks; touching face or phone with gloved hands; washing and reusing gloves |
| Handwashing sink accessibility | Blocked by a cart, used as a dump sink, missing soap or towels, water not reaching 100°F |
| Eating, drinking, smoking in food areas | Employee beverages permitted only in a covered container with a lid and straw, stored so it cannot contaminate food or surfaces |
| Jewelry and fingernails | Plain ring band only; nails trimmed, filed, and unpolished unless gloves are worn |
| Hair restraint | Effective restraint required for food employees |
| Working while ill | Watch for coughing, sneezing, visible lesions on hands, and jaundice — jaundice requires immediate exclusion and notification of the regulatory authority |
| Utensil and thermometer handling | Probes sanitized between products; utensil handles kept out of food; ice scoops stored outside the ice |
Interviewing without leading
When you do ask, ask open questions that reveal understanding rather than yielding a yes: "Walk me through what you do when you finish cutting raw chicken and move to salad prep." "What temperature does this need to reach and how do you check?" "What would you do if the sanitizer strip read low?"
Documenting behavior findings
Document what you observed, with time, location, and the specific action, and tie it to the code section. Write:
"At 12:14 p.m., observed a food employee at the sandwich station handle raw bacon with gloved hands, then, without changing gloves or washing hands, place sliced tomato on three sandwiches for service."
Do not write: "Employees are careless and poorly trained." Characterizations are not evidence, they are not defensible in an enforcement proceeding, and they damage the working relationship needed for corrective action. Note also the corrective action taken during the inspection — sandwiches voluntarily discarded, employee re-instructed by the PIC — because on-site correction is part of the record.
An inspector reviews a pest control file and finds that the last six monthly service reports each recommend sealing a gap beneath the rear delivery door. What is the most significant finding?
Which pest control practice is appropriate inside a food preparation area?
Which write-up of an employee behavior observation is defensible in an enforcement proceeding?
Live cockroaches observed foraging in the open during daylight hours in a kitchen most likely indicate what?