Falcon Liability Shield — Healthcare
Four regulatory regimes govern pest management in your hospital. Fourteen documents prove you're meeting them. Your pest control vendor produces one of them: an invoice.
Falcon produces all fourteen. Authored, signed, and sealed by a Board Certified Entomologist, delivered to your compliance file every month — at no additional charge over standard monthly pest service.
DHHS licensing · UDAF pesticide law · The Joint Commission · CMS Conditions of Participation — plus your local health department if you operate a kitchen, and Utah's school IPM rule if there's a school on your campus.
Trent Frazer, BCE #B3413. There are roughly four Board Certified Entomologists in Utah. One is in private practice.
What this costs
Documentation of this kind — a written IPM plan, a property-specific exposure assessment, BCE-signed protocols, an annual program evaluation — runs $3,500 to $8,500 when built as a standalone consulting engagement by a Board Certified Entomologist. Defense counsel bills $400–$600 an hour to audit it afterward.
Falcon includes all of it with monthly pest service. There is no separate documentation charge, no onboarding fee, and no upcharge over what a standard licensed pest control company quotes for the same route.
You are not choosing between a cheaper vendor and a more expensive one. You are choosing between an invoice and a compliance file, at the same price.
What we can and cannot do
Every obligation on this page belongs to your facility. Utah Admin. Code R432-100-39 places the pest-control program duty on the licensee — the hospital. The Joint Commission surveys the hospital. CMS certifies the hospital. No contractor can assume, discharge, or guarantee any of it, and any vendor who tells you otherwise is selling you something that will not survive a surveyor's first question.
What a contractor can do is produce the documentary content for the artifacts you are required to hold, in the format your files and your surveyors expect, signed by someone whose professional certification is on the line.
That is what Falcon does. You hold the file. We build it, sign it, and keep it current.
The fourteen documents
Every citation on this page links to the primary source. Check them.
| Document | What requires it | Does a standard licensed pest control company produce it? | Does Falcon? |
|---|---|---|---|
| Signed, dated services agreement detailing contracted services | Utah Admin. Code R432-100-39(1)(c)The hospital must hold a signed, dated agreement detailing contracted maintenance services. "If the licensee contracts for maintenance services, the licensee shall secure a signed and dated agreement that details the services provided." |
✗An invoice is not an agreement. A work order does not detail contracted services. |
✓In your file before first service, cross-linked to your scope of work. |
| Per-visit pesticide application record with all nine required data elements | Utah Admin. Code R68-7-11(11)Nine data elements recorded within 24 hours of every application, kept two years. Nine elements required for every application: the treated area, target pest, brand name, EPA registration number, mix rate, total amount applied, and the applicator's license number — recorded within 24 hours, kept two years, and furnished "in a uniform format." |
✗They record all nine. For their own UDAF file. Utah does not require them to give you a copy, and they don't. |
✓The same legally-required record, delivered to your compliance file every visit. Formatted for your binder instead of ours. |
| Written campus IPM plan | Utah Admin. Code R432-100-39(1)(d)The hospital must ensure a pest-control program is conducted. "The licensee shall ensure a pest-control program is conducted to ensure the hospital is free from vermin and rodents." A program is a thing you can produce. Applications are not. |
✗Performs applications. Cannot hand you a program. |
✓Policy, roles, action thresholds, monitoring protocol, approved products, non-chemical control hierarchy, escalation pathway, annual review. Authored for your campus, BCE-signed. |
| Device inventory and campus placement map | 42 C.F.R. § 482.41The physical environment must be maintained to ensure patient safety. The hospital "must be constructed, arranged, and maintained to ensure the safety of the patient," with facilities "maintained to ensure an acceptable level of safety and quality." |
✗Knows where their devices are. You don't. |
✓Every device, location, type, and check schedule — mapped, in your file, updated on change. |
| Monitoring and trend log with analysis | 42 C.F.R. § 482.42Infection control issues must be addressed in collaboration with your QAPI program. The infection prevention and control program includes "maintaining a clean and sanitary environment to avoid sources and transmission of infection," and infection control issues "must be addressed in collaboration with the hospital-wide quality assessment and performance improvement (QAPI) program." |
✗Service tickets are point-in-time. Twelve of them are not a trend. |
✓Activity by building, zone, and season, with efficacy trend. QAPI-ready. Infection Prevention Committee-ready. |
| Conducive-conditions and corrective-action report | EC.02.06.01 → PE.01.01.01Interior spaces must be safe and suitable for the care delivered. Among the most frequently cited standards in The Joint Commission's FY2025 hospital surveys. (TJC's manual is proprietary — see the source note at the foot of this page.) |
✗Treats the symptom. Documents nothing you can hand a surveyor. |
✓Condition, location, photograph, recommended fix, assigned owner, closure date. Tracked open-to-closed. |
| Pesticide product list with EPA registration numbers and matching SDS set | EC.02.02.01 → PE.02.01.01You must maintain a written, current inventory of hazardous materials, with SDS access. "The hospital maintains a written, current inventory of hazardous materials and waste that it uses, stores, or generates." Staff must have access to Safety Data Sheets for those materials. (TJC's manual is proprietary — see the source note at the foot of this page.) |
✗The products are on their truck. They are not on your inventory. |
✓Formatted to drop straight into your hazardous materials inventory. Updated on every product change. |
| Restricted-use pesticide notification to the customer | Utah Admin. Code R68-7-16(4)A written statement to the customer before applying a restricted-use pesticide. Before applying a restricted-use pesticide carrying a "Danger" or "Danger-Poison" signal word, the applicator must give the customer a written statement identifying the business, the applicator, the date and time, the product, and its EPA registration number. |
✓Utah law compels this one, and they comply. |
✓Provided, and filed — with the standing product list, so you see what enters your building before it enters. |
| Applicator and business licensing file, kept current | Utah Admin. Code R68-7Licensing is mandatory for the applicator. Verifying it is your problem. Utah requires commercial applicators and pesticide businesses to be licensed. EPA's healthcare IPM toolkit recommends facilities require license documentation in the bid specification. |
✗Holds the license. Doesn't file it with you, and doesn't tell you when it renews. |
✓Licenses, categories, insurance, and credentials in your file, refreshed annually. |
| Staff training records with attendance and competency verification | Tracer methodologySurveyors interview your front-line staff, not your vendor. Your people are expected to describe, unprompted, how a pest sighting gets reported, escalated, resolved, and verified. (TJC's manual is proprietary — see the source note at the foot of this page.) |
✗Does not train your staff. Your tracer answer is whatever your team improvises. |
✓Trained on site by the Board Certified Entomologist — Dietary, Environmental Services, Nursing, Materials Management, Facilities. Records retained for survey. |
| Annual written program evaluation | EC.04.01.01Every 12 months you must evaluate each Environment of Care management plan. "Every 12 months, the hospital evaluates each environment of care management plan, including a review of the plan's objectives, scope, performance, and effectiveness." (TJC's manual is proprietary — see the source note at the foot of this page.) |
✗You write it. Alone. From a year of invoices. |
✓BCE-signed, written in exactly that structure — objectives, scope, performance measures, effectiveness determination, next-year objectives. It drops into the binder as-is. |
| Vector and pest infection-control risk assessment | Utah Admin. Code R432-101-12A written infection control plan, reviewed at least annually. "The facility shall have a written plan to effectively prevent, identify, report, evaluate and control infections," and "The infection control plan shall be reviewed and revised as necessary, but at least annually." |
✗Nothing that feeds your infection control plan. |
✓BCE-authored, written to feed your infection prevention plan and Infection Prevention Committee reporting. |
| Seven-topic school IPM plan (if a school sits on your campus) | Utah Admin. Code R392-200-18A school must adopt a written IPM plan containing seven required topics. The plan must contain: a policy statement; implementation and education; pest identification, monitoring, reporting and control; approved pesticides for school use; procedures for pesticide use; a policy for notification of students, parents, and staff; and pesticide applicator requirements. The rule states the plan may be written "by the governing body or the contracted pest management entity," and it must be made available to the local health officer upon request. |
✗Does not know this rule reaches the school building on your campus. |
✓Authored by the contracted pest management entity — the role the rule names by name. |
| On-site pest log at each permitted food establishment (if you operate a kitchen) | FDA Food Code 2022 § 6-501.111Pest presence must be controlled by inspection, method, and eliminating harborage. "The presence of pests shall be controlled to minimize their presence by: (A) Routinely inspecting incoming shipments of food and supplies; (B) Routinely inspecting the premises for evidence of pests; (C) Using methods, if pests are found, such as trapping devices or other means of pest control...; and (D) Eliminating harborage conditions." |
✗Services the kitchen. Leaves no log behind. |
✓Service reports, device map, corrective actions, product list and SDS. Where your health inspector looks, when they ask. |
Services agreement
Signed, dated services agreement detailing contracted services
Utah Admin. Code R432-100-39(1)(c)
"If the licensee contracts for maintenance services, the licensee shall secure a signed and dated agreement that details the services provided."
Standard licensed vendor — An invoice is not an agreement. A work order does not detail contracted services.
Falcon — In your file before first service, cross-linked to your scope of work.
Application records
Per-visit pesticide application record with all nine required data elements
Utah Admin. Code R68-7-11(11)
Nine elements required for every application: the treated area, target pest, brand name, EPA registration number, mix rate, total amount applied, and the applicator's license number — recorded within 24 hours, kept two years, and furnished "in a uniform format."
Standard licensed vendor — They record all nine. For their own UDAF file. Utah does not require them to give you a copy, and they don't.
Falcon — The same legally-required record, delivered to your compliance file every visit. Formatted for your binder instead of ours.
Written IPM plan
Written campus IPM plan
Utah Admin. Code R432-100-39(1)(d)
"The licensee shall ensure a pest-control program is conducted to ensure the hospital is free from vermin and rodents." A program is a thing you can produce. Applications are not.
Standard licensed vendor — Performs applications. Cannot hand you a program.
Falcon — Policy, roles, action thresholds, monitoring protocol, approved products, non-chemical control hierarchy, escalation pathway, annual review. Authored for your campus, BCE-signed.
Device inventory & map
Device inventory and campus placement map
42 C.F.R. § 482.41
The hospital "must be constructed, arranged, and maintained to ensure the safety of the patient," with facilities "maintained to ensure an acceptable level of safety and quality."
Standard licensed vendor — Knows where their devices are. You don't.
Falcon — Every device, location, type, and check schedule — mapped, in your file, updated on change.
Trend log & analysis
Monitoring and trend log with analysis
42 C.F.R. § 482.42
The infection prevention and control program includes "maintaining a clean and sanitary environment to avoid sources and transmission of infection," and infection control issues "must be addressed in collaboration with the hospital-wide quality assessment and performance improvement (QAPI) program."
Standard licensed vendor — Service tickets are point-in-time. Twelve of them are not a trend.
Falcon — Activity by building, zone, and season, with efficacy trend. QAPI-ready. Infection Prevention Committee-ready.
Corrective actions
Conducive-conditions and corrective-action report
EC.02.06.01 → PE.01.01.01
Among the most frequently cited standards in The Joint Commission's FY2025 hospital surveys. (TJC's manual is proprietary — see the source note at the foot of this page.)
Standard licensed vendor — Treats the symptom. Documents nothing you can hand a surveyor.
Falcon — Condition, location, photograph, recommended fix, assigned owner, closure date. Tracked open-to-closed.
Product list & SDS
Pesticide product list with EPA registration numbers and matching SDS set
EC.02.02.01 → PE.02.01.01
"The hospital maintains a written, current inventory of hazardous materials and waste that it uses, stores, or generates." Staff must have access to Safety Data Sheets for those materials. (TJC's manual is proprietary — see the source note at the foot of this page.)
Standard licensed vendor — The products are on their truck. They are not on your inventory.
Falcon — Formatted to drop straight into your hazardous materials inventory. Updated on every product change.
Restricted-use notice
Restricted-use pesticide notification to the customer
Utah Admin. Code R68-7-16(4)
Before applying a restricted-use pesticide carrying a "Danger" or "Danger-Poison" signal word, the applicator must give the customer a written statement identifying the business, the applicator, the date and time, the product, and its EPA registration number.
Standard licensed vendor — Utah law compels this one, and they comply.
Falcon — Provided, and filed — with the standing product list, so you see what enters your building before it enters.
Licensing file
Applicator and business licensing file, kept current
Utah Admin. Code R68-7
Utah requires commercial applicators and pesticide businesses to be licensed. EPA's healthcare IPM toolkit recommends facilities require license documentation in the bid specification.
Standard licensed vendor — Holds the license. Doesn't file it with you, and doesn't tell you when it renews.
Falcon — Licenses, categories, insurance, and credentials in your file, refreshed annually.
Staff training records
Staff training records with attendance and competency verification
Tracer methodology
Your people are expected to describe, unprompted, how a pest sighting gets reported, escalated, resolved, and verified. (TJC's manual is proprietary — see the source note at the foot of this page.)
Standard licensed vendor — Does not train your staff. Your tracer answer is whatever your team improvises.
Falcon — Trained on site by the Board Certified Entomologist — Dietary, Environmental Services, Nursing, Materials Management, Facilities. Records retained for survey.
Annual evaluation
Annual written program evaluation
EC.04.01.01
"Every 12 months, the hospital evaluates each environment of care management plan, including a review of the plan's objectives, scope, performance, and effectiveness." (TJC's manual is proprietary — see the source note at the foot of this page.)
Standard licensed vendor — You write it. Alone. From a year of invoices.
Falcon — BCE-signed, written in exactly that structure — objectives, scope, performance measures, effectiveness determination, next-year objectives. It drops into the binder as-is.
Vector risk assessment
Vector and pest infection-control risk assessment
Utah Admin. Code R432-101-12
"The facility shall have a written plan to effectively prevent, identify, report, evaluate and control infections," and "The infection control plan shall be reviewed and revised as necessary, but at least annually."
Standard licensed vendor — Nothing that feeds your infection control plan.
Falcon — BCE-authored, written to feed your infection prevention plan and Infection Prevention Committee reporting.
School IPM plan
Seven-topic school IPM plan (if a school sits on your campus)
Utah Admin. Code R392-200-18
The plan must contain: a policy statement; implementation and education; pest identification, monitoring, reporting and control; approved pesticides for school use; procedures for pesticide use; a policy for notification of students, parents, and staff; and pesticide applicator requirements. The rule states the plan may be written "by the governing body or the contracted pest management entity," and it must be made available to the local health officer upon request.
Standard licensed vendor — Does not know this rule reaches the school building on your campus.
Falcon — Authored by the contracted pest management entity — the role the rule names by name.
Food establishment log
On-site pest log at each permitted food establishment (if you operate a kitchen)
FDA Food Code 2022 § 6-501.111
"The presence of pests shall be controlled to minimize their presence by: (A) Routinely inspecting incoming shipments of food and supplies; (B) Routinely inspecting the premises for evidence of pests; (C) Using methods, if pests are found, such as trapping devices or other means of pest control...; and (D) Eliminating harborage conditions."
Standard licensed vendor — Services the kitchen. Leaves no log behind.
Falcon — Service reports, device map, corrective actions, product list and SDS. Where your health inspector looks, when they ask.
The single checkmark is real. Utah law compels it and they comply. Everything else on this page, they are not required to give you — and don't.
Also included, and not counted above because no rule compels it: a property-specific liability exposure assessment written for your campus by a Board Certified Entomologist. That is the document your insurance carrier and your defense counsel would ask for first.
How you receive it
Within 30 days of contract
The Onboarding Package
- Property-specific liability exposure assessment
- Written campus IPM plan
- BCE-signed pest protocols by species
- Device inventory and placement map
- Staff training curriculum
- Licensing, insurance, and credentials file
- The signed, dated services agreement
Every month, quarter, and year
The Recurring Stream
- Per-visit service record with full R68-7-11(11) data elements
- Monthly pest activity summary
- Quarterly BCE-signed report with trend analysis
- Annual program evaluation in EC.04.01.01 format
- Annual IPM plan review
- Annual training reconciliation
Delivered three ways: A bound binder with the Falcon Standard seal on the cover, tabbed and ready to hand a surveyor · One-click download from your Falcon Community Command portal · Printed on request, any time, no charge.
Why the signature matters
No Utah rule, no CMS Condition of Participation, and no Joint Commission standard requires your pest control provider to be a Board Certified Entomologist. Falcon will never tell you otherwise.
CDC and HICPAC put it this way, in the Guidelines for Environmental Infection Control in Health-Care Facilities — verbatim, Category II recommendation:
"Contract for routine pest control service by a credentialed pest-control specialist who will tailor the application to the needs of a health-care facility."
A Board Certified Entomologist is the strongest available reading of "credentialed pest-control specialist." That is the argument. It is not that the law requires it.
Here is what the credential actually does. A BCE is bound to a professional standard and a published code of ethics, must qualify by degree and experience, must pass certification examinations, and must recertify. That means the person who authors your IPM plan, signs your annual program evaluation, and writes your vector risk assessment is accountable to a certifying body for the accuracy of what he puts his name on — and CDC and HICPAC recommend contracting pest control for a health care facility through a credentialed specialist who tailors the program to the facility.
A licensed applicator is licensed to apply pesticides. That is a real credential and it is the right one for spraying a building. It is not a credential for authoring the documents your accreditation file depends on.
The entomologist who designs your program is the entomologist who delivers it. There is no handoff between the person who wrote the protections and the person performing the service.
Trent Frazer, BCE #B3413 · Board Certified Entomologist (General Entomology) · MS Entomology, University of Florida · Utah Commercial Applicator #4001-16378 · UDAF Business #4000-000021793 · State of Utah Cooperative Contract MA5191
Start with the audit
A 30-minute Liability Exposure Audit at one of your facilities. A Board Certified Entomologist walks your building and gives you a signed written assessment of what your current pest documentation file contains and what it is missing.
No obligation. No upsell. No charge. If you keep your current vendor, keep the report and hold them to it.