Applied entomology for places that get inspected

Frazer Applied Entomology is the professional consulting practice of Trenton L. Frazer, MS, Board Certified Entomologist. It advises facilities in regulated and sensitive environments: places where you cannot spray your way out of the problem, where the documentation is the deliverable, and where a third party inspects you.

The practice serves healthcare,K-12 schools,food service,corrections,government facilities, andmultifamily housing. Those sectors share a problem that has little to do with insects: each is governed by a regulatory regime that was not written with pests in mind, and each is surveyed by someone who will ask for a record the facility has never been told to keep.

Credentials

• Board Certified Entomologist — BCE #B3413, General Entomology, certified by the Entomological Society of America Certification Corporation
• MS, Entomology — University of Florida
• Utah Commercial Applicator — #4001-16378
• Verify the BCE credential on Credly·Earner profile

The credential is held by Trenton L. Frazer personally. Frazer Applied Entomology is the practice through which he is retained; the certification is his, not the firm's. That distinction matters to the certifying body, and it matters more to opposing counsel.

What the practice does

Five engagements. Each is written for the facility, not for a 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.

• Compliance program review

  Assessment of an existing pest management program against the regulatory regimes that actually govern the facility, with a written finding.

• Survey readiness

  Pre-inspection assessment and documentation review ahead of an accreditation survey, state inspection, or audit.

• Deficiency response

  Support after a citation: what the finding requires, what a plan of correction must address, and what evidence satisfies a revisit.

• Entomologist of Record

  A named, credentialed entomologist on the facility’s compliance record, with ongoing documentation and survey support.

• Expert witness

  Retained opinion work in entomology and pest management, for premises and facility matters.

Where it works

Healthcare has the deepest proof today. It is the vertical, not the boundary.

• Healthcare

  No explicit hospital pest standard exists in federal regulation, and hospitals are cited for pests constantly. The deepest proof the practice holds.

• K-12 schools

  Utah requires a written school IPM plan with seven named elements. Most states require something; almost none require the same thing.

• Food service

  FDA Food Code 6-501.111 names four means of pest control. Three of them are not pesticide application.

• Corrections

  Pest conditions in a correctional facility are litigable under the Eighth Amendment. The evidence is the sighting log and the dates.

• Government facilities

  Federal agencies are required by statute to use IPM — which reaches how they buy pest management, not just how they do it.

• Multifamily

  Under NSPIRE an inspector does not need to see a live pest, and an active extermination contract is not a defense.

The method

The work starts from primary sources. Name the regimes that actually govern the facility, cite them exactly, state what each one requires, and say plainly where they conflict or go silent — because the silences are where facilities get cited. No explicit hospital pest standard exists in the current CMS surveyor manual, for instance, and hospitals are cited for pests constantly. A program built against a standard that does not exist cannot be defended.

The public demonstration of that method is theHealthcare Pest Reference, a reference work mapping federal, state, and accrediting-body pest requirements for healthcare facilities to their primary sources. It is maintained by the same author and is free to use.

Retaining the practice

Engagements are national and fee-based. Fees are discussed directly; no schedule is published on this site. Contact the practice to describe the facility, the regime that governs it, and what is coming — a survey, a citation already issued, or a matter in litigation.