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Ch.4: Pest Mgmt: Food & Specialized Facilities

What the exam tests on FD&C Act, defect action levels, six treatment types, and IPM in supermarkets, schools, health care, zoos, and computer facilities.

🎯 Top 5 Traps

1
SANITATION is the most important pest control technique in food-handling — not insecticide, not rodenticide, not baiting. Pesticides supplement sanitation; they don't replace it. The chapter is unambiguous: sanitation is the cornerstone, and any level of pesticide residue in finished food generally constitutes an illegal residue.
2
Spot treatments may NOT exceed 2 SQUARE FEET. This is the ONLY specific size limit on a treatment type in the chapter. Spot treatments cover limited areas where insects walk but won't contact food, utensils, or workers — bases of equipment, undersides, etc. Often allowed only in non-food areas.
3
USDA's List of Proprietary Substances does NOT guarantee a pesticide can be used — the USDA inspector in charge can still prohibit it. An inspector may allow listed pesticides only when the plant is in non-production status. The pesticide label is not always the only applicable law in USDA-inspected meat/poultry/egg plants.
4
Reg 637 requires IPM training BEFORE applying pesticides in schools, day-cares, nursing homes, AND hospitals — all of them. Easy to assume the rule covers only schools or only health care. Cross-references Ch.1 IPM training mandate (Reg 637 Rule 14) + the 4-hour reentry rule (Rule 15) + parental notification rule.
5
SCHOOL pesticide application = unoccupied for at least 4 HOURS (or longer per label) AND school administrators/staff must be informed. Not C (USDA list — that's food plants, not schools). Not D (only nonresidual — false; many residual products are allowed if applied properly). The rule combines two requirements.

🔢 Numbers You Must Know

Number
What It Represents
2 square feet
Maximum size of a single SPOT treatment in food-handling facilities
16 to 18 inches
Required clearance between stored material and walls in food storage areas (FDA inspection target)
4 hours
Minimum unoccupied time after insecticide application in school rooms (Reg 637 Rule 15) — OR longer if product label specifies
1938
Year of the Federal Food, Drug, and Cosmetic Act (FD&C Act) — regulates allowable extraneous matter in food products
4 residual application types
General, Barrier, Spot, Crack & crevice (residual = lasts several hours or longer)
2 nonresidual application types
Space (aerosol/ULF/fog) and Contact (wet spray hitting target). Both are "general insecticide applications."
5 specialized facility types in this chapter
Supermarkets (food-handling), Schools/day-cares, Health care facilities, Zoos/pet stores, Computer facilities — each with distinct constraints
2 areas in food facilities
Food areas (anywhere food is stored or processed) vs Non-food areas (locker rooms, lavatories, machine rooms, boiler rooms, rubbish rooms, garages)
3 federal agencies + 1 state reg
FDA (sanitation in non-meat food), USDA (meat/poultry/egg), EPA (pesticide registration), Reg 637 (MI use)

🔀 Easily Confused

Pair / Group
Distinguishing Feature
Food area vs Non-food area
Food area: anywhere food is stored or processed. Non-food area: locker rooms, lavatories, machine rooms, boiler rooms, rubbish rooms, garages — places food is not normally present (except in transit). Many treatment types are restricted to non-food areas.
Residual vs Nonresidual
Residual: insecticidal effect lasts several hours or longer. Four types: general, barrier, spot, crack & crevice. Nonresidual: effect lasts only during time of treatment. Two types: space and contact.
Space vs Contact treatment
Both are nonresidual general applications. Space: aerosol/ULF/fog — must be applied while establishment NOT in operation; foods removed/covered, surfaces cleaned before use. Contact: wet spray hitting target pest for immediate effect — CAN be applied while establishment is in operation.
General vs Barrier vs Spot vs Crack & crevice
General: broad indoor surfaces (walls/floors/ceilings) or outside; non-food areas only. Barrier: thresholds, entrances, foundation, adjacent soil. Spot: limited areas where insects walk but won't contact food/utensils/workers; max 2 sq ft. Crack & crevice: small amounts into gaps/voids; sprays, dusts, OR baits; allowed in food areas if confined to cracks.
FDA vs USDA jurisdiction
FDA: sanitation standards in most food-handling establishments under FD&C Act. USDA: more stringent regulation of MEAT, POULTRY, EGG, and EGG PRODUCTS plants — frequent inspections; inspector in charge has discretion; List of Proprietary Substances applies.
USDA List vs USDA Inspector approval
List of Proprietary Substances: a pesticide must be on this list to be considered. Inspector approval: even listed products may be prohibited by the inspector in charge or restricted to non-production status. Listed status alone is NOT sufficient.
USDA emergency waiver
USDA may temporarily waive its restrictions on certain pesticides when pest problems are serious — but only under USDA direction. Not the same as the inspector's general discretionary authority.

💧 Six Pesticide Treatment Types

Match the treatment to the right area. Wrong choice = label violation + possible food contamination.

Treatment
Type / Use
Where Allowed / Key Spec
General
Residual — broad indoor surfaces (walls/floors/ceilings) or outside
NON-FOOD areas only; only insecticides specifically registered for general application.
Barrier
Residual — sprays, dusts, or granules applied to thresholds, entrances, foundation, adjacent soil
Outdoor pest invasion prevention. Used to keep outdoor pests from entering.
Spot
Residual — limited areas where insects walk but won't contact food, utensils, or workers
Max 2 SQ FT per spot. Often allowed only in non-food areas — check label. Floors, walls, equipment bases/undersides.
Crack & crevice
Residual — sprays, dusts, OR baits applied into cracks/crevices/voids
ALLOWED in FOOD AREAS as long as confined to cracks. Most likely treatment to ensure no residue in food, on prep surfaces, or on packaging.
Space
Nonresidual — aerosol, ULF, or fog
Establishment must NOT be in operation. Foods removed/covered. Food-handling surfaces cleaned before use.
Contact
Nonresidual — wet spray hitting target pest for immediate effect
CAN be applied while establishment is in operation.

🏢 Five Specialized Facility Types

Facility
Distinguishing Concern
Key Pests & Approach
Supermarkets
Increased risk of pest INTRODUCTIONS due to flow of goods; stored-product pests a problem
Cockroaches, mice/rats, flies (esp. Drosophila around produce), stored-product insects, birds. Most of store = food area. Prefer baits, C&C, void dusting over general spraying.
Schools / Day-care centers
Head lice a particular problem; PARENTS must be notified before any pesticide application
Cockroaches, ants, mice, head lice, flies. IPM training required (Reg 637). 4-hr reentry minimum. Inform school administrators + staff before applying.
Health care facilities
Risk of human BACTERIAL INFECTIONS is the primary concern
German + brown-banded cockroaches, ants (esp. pharaoh), mice, flies. IPM plan required (Reg 637). Use low-odor or odorless residual; C&C or limited spot only; keep airborne to minimum; bait wherever appropriate.
Zoos / Pet stores
Risk of SECONDARY PESTICIDE POISONING from animals eating treated pests
Cockroaches, mice/rats, flies, birds, wasps/yellow jackets. Bait formulations preferred (placed carefully); C&C or limited spot residual; dust dry voids; never apply into air around sensitive animals.
Computer facilities
Risk of damage to SENSITIVE EQUIPMENT from infestations AND pesticide applications; prohibiting food highly recommended
German/brown-banded cockroaches, mice, ants, flies/gnats. Use baits and traps over sprays/dusts. Apply liquid residuals safely by painting with a brush. Establish a pest-free buffer zone around the facility.

💡 Memory Hooks

Cornerstone: "Sanitation, not spray." Sanitation is the most important pest control technique in food-handling. Pesticides supplement.
Spot size: "Two square feet — the spot ceiling." Spot treatments cannot exceed 2 sq ft per spot.
Treatment-area match: "C&C anywhere, general nowhere near food." Crack & crevice is the only residual treatment broadly allowed in food areas.
Operating vs not: "Space waits, contact strikes." Space treatments require shutdown; contact treatments can be applied during operation.
USDA list trap: "Listed isn't licensed." Being on the USDA list of proprietary substances doesn't guarantee inspector approval.
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