Applied entomology for regulated facilities.
Hospitals, schools, correctional facilities, and food operations are inspected against rules that barely mention pests. When a surveyor writes a finding anyway, one question decides what happens next: did your program produce the record they asked for?
I review pest management programs, prepare facilities for survey, respond to citations, serve as Entomologist of Record, and testify as a retained expert. Nationwide.
There is no hospital pest standard. Hospitals are cited for pests constantly.
The manual a hospital surveyor actually carries runs 613 pages, and five words never appear in it. Facilities get cited anyway — by inference, under whichever general provision the individual surveyor reaches for. Which provision it lands under decides what closing it takes.
CMS State Operations Manual, Appendix A, Rev. 238. Pest, vermin, rodent, insect, and infestation occur zero times — and zero times in 42 CFR Part 482. Both counts are measured, not estimated.
Hospital pest findings, September 9, 2024 to September 9, 2026. The largest single concentration is tag A-0750, with 27 findings — 22.9% of the total.
Long-term care F0925 over the identical twenty-four months — the setting that does have a pest-specific tag.
In a setting with a named standard, findings concentrate on it and a facility can prepare against a known requirement. In a setting without one, findings scatter across 46 tags and a facility cannot prepare against anything in particular — it can only build a program that answers all of them.
That is the shape of the problem in healthcare, where the evidence is deepest. Every sector the practice serves has its own version of it: a rule that governs the building, an inspector entitled to ask, and a program that either produces the record or does not.
Five engagements
Each one is written for the facility rather than the sector. A survey-readiness assessment works the same way in a correctional kitchen as in a surgical suite, because in both cases the question is what the inspector will ask for and whether the record answers it.
- Engagement 01Compliance program reviewAn assessment of the pest management program you already have, measured against the rules that actually govern your building, delivered as a written finding.Read moreFor facilities directors, risk managers
- Engagement 02Survey readinessA review of the program and the paperwork before an accreditation survey, state inspection, or audit — while there is still time to fix what it finds.Read moreFor quality and accreditation leads
- Engagement 03Deficiency responseAfter a citation: what the finding actually requires, what a plan of correction has to address, and what evidence will satisfy a revisit.Read moreFor risk managers, plant operations
- Engagement 04Entomologist of RecordA named, credentialed entomologist on your compliance record, with continuing documentation review and survey support between inspections.Read moreFor health systems, districts, agencies
- Engagement 05Expert witnessRetained opinion work for premises and facility matters: case review, written opinion, deposition, and testimony. Either side of the caption.Read moreFor trial counsel, insurers, risk counsel
Six sectors, six different answers to the same question
Who inspects this facility, under what authority, and what are they entitled to ask for? Healthcare has the deepest proof today. It is the vertical, not the boundary.
- HealthcareNo explicit hospital pest standard exists in federal regulation, and hospitals are cited for pests constantly. The deepest proof the practice holds.Healthcare
- K-12 schoolsUtah requires a written school IPM plan with seven named elements. Most states require something; almost none require the same thing.K-12 schools
- Food serviceFDA Food Code 6-501.111 names four means of pest control. Three of them are not pesticide application.Food service
- CorrectionsPest conditions in a correctional facility are litigable under the Eighth Amendment. The evidence is the sighting log and the dates.Corrections
- Government facilitiesFederal agencies are required by statute to use IPM — which reaches how they buy pest management, not just how they do it.Government facilities
- MultifamilyUnder NSPIRE an inspector does not need to see a live pest, and an active extermination contract is not a defense.Multifamily
The research behind the practice is public, and it is checkable.
The Healthcare Pest Reference maps federal, state, and accrediting-body pest requirements for healthcare facilities to their primary sources. Same author. Free to use. No engagement required, and what it says does not change based on who is or is not a client.
Every regulatory citation on this site states how far it has been verified — whether the primary source was read and on what date, or whether it is corroborated from secondary sources and still awaiting a primary read. A reader can tell the difference at a glance, which is the point.
There are fewer than 440 Board Certified Entomologists. Trenton S. Frazer is one of them, and Utah's only BCE in independent commercial practice. The credential is held by Trenton S. Frazer personally and is issued to an individual, on examination, by the Entomological Society of America Certification Corporation. Frazer Applied Entomology is the practice through which he is retained. That distinction matters to the certifying body, and it matters more to opposing counsel.
Entomological Society of America
Certification Corporation
How to read a citation on this site
The primary source was read into this repository, on the date shown.
Identifier and substance corroborated; the primary text has not been read. The note says exactly what remains unread.
An engagement has four steps, and the first one is an email
Nobody retains a consultant without knowing the shape of it. This is the shape of it.
You describe the situation
The facility, who inspects it and under what authority, and what is coming — a scheduled survey, a citation already issued with its deadline, an audit, or a matter in litigation. One email. There is no form and no intake sequence.
You get a direct answer on scope
Whether this is work worth doing, what it would cover, and what it costs. If the honest answer is that you do not need an entomologist, that is the answer you get. Fees are set against the scope of the facility and the work, and are discussed directly.
Assessment
On site or on the documents, depending on what the question actually is. The rules that govern the building get named and read from their primary sources first, because a program built against a standard that does not exist cannot be defended.
A written finding
What those rules require, where your program answers them, where it does not, and what closing the gap takes. Written to be handed to a surveyor, a board, or opposing counsel.
Describe the situation.
The facility, who inspects it, and the date that actually constrains the work. If a surveyor has already written the finding, send the finding.
Expert witness inquiries should include the jurisdiction, the posture and any operative deadlines, and the parties for a conflicts check.