# Your Pest Control Contract Is Not a Pest Control Programme: Why Food Factories Must Own the Trap Data

*By Isaac Muthui, CEO, Tamalaki Business Network Ltd*

Ask a factory manager how pest control works on site, and the answer is often a name and a date: "We have a contractor. They come every month."

That is a service visit, not a programme. The contractor sees the plant for a few hours. Your team sees it every day: the gap under the roll-up door, the torn mesh on the store window, the spilled flour behind the pallets, the bait station knocked over by a forklift. If nobody on your side is watching, writing it down and acting on it, the monthly visit only tells you what went wrong after it went wrong.

This article is for production leads, QA officers, store managers and owners of small and mid-sized food and agro factories in Kenya and East Africa: millers, dairies, bakeries, juice and edible-oil processors, spice and pulse packers, snack makers and feed millers. It gives you an eight-step **pest control checklist** you can run with your team and your contractor. It is operations guidance, not legal advice; confirm specifics with your county public health office and your pest control provider.

## What the rules and standards actually say

Kenya's baseline sits in the [Food, Drugs and Chemical Substances (Food Hygiene) Regulations, 1978](https://faolex.fao.org/docs/pdf/ken106527.pdf), made under the Food, Drugs and Chemical Substances Act (Cap. 254). The points that matter most on a factory floor:

- **Keep the grounds clean.** Regulation 7 requires the grounds around a food plant to be kept free of improperly stored equipment, litter, waste and refuse that may attract, harbour or breed rodents, insects and other pests, and free of badly drained areas. Where the neighbouring land is not yours, you are expected to use inspection, extermination or other means inside your plant to keep pests out.
- **Screen the building.** Regulation 8(2)(e) calls for effective screening or other protection against birds, animals and vermin, including insects and rodents, where necessary.
- **Exclude pests, and use pesticides carefully.** Regulation 12 requires that no animals or birds other than those essential as raw materials are allowed in the plant, that effective measures are taken to exclude pests from food areas, that only the toxic materials actually needed are used or stored in the plant, and that pesticides are used with precautions that prevent contamination of food or packaging material.

The Ministry of Health's [Checklist for Food Hygiene Licensing (April 2023)](https://www.health.go.ke/sites/default/files/2023-05/Checklist%20for%20Food%20Hygiene%20Licensing%20April%202023.pdf) has a dedicated section, "Insect Vector and Rodent Control (pest control)", asking for appropriate preventive measures against rodents, birds, vermin and insects. If you are preparing for a licensing inspection, that is one of the lines you will be checked against.

Internationally, the Codex [General Principles of Food Hygiene (CXC 1-1969)](https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXC%2B1-1969%252FCXC_001e.pdf) sets out pest control systems in section 11.2. It says good building design, maintenance, cleaning, inspection of incoming materials and effective monitoring can minimise infestation and limit the need for pesticides. Two lines are worth pinning on the wall:

- Even if monitoring is outsourced, the food business should **review the monitoring reports** and make sure corrective action is taken.
- Infestations should be dealt with immediately by a qualified person or company, the **cause should be identified**, and **records should be kept of infestation, monitoring and eradication**.

Who may do the work also matters. Under the [Pest Control Products (Inspection and Certification) Regulations, 2024](https://new.kenyalaw.org/akn/ke/act/ln/2024/193/eng@2024-12-27) ([PDF from the Pest Control Products Board](https://pcpb.go.ke/wp-content/uploads/2025/02/The-Pest-Control-Products-Inspection-and-Certification-Regulations-1.pdf)), regulation 12(6) says the person in charge of a pest control service must hold a certificate in agriculture, animal health or a related science and have attended pest control operator training organised or recognised by the Board. Regulation 14 requires a Board certificate for anyone handling or using Restricted Class 1 products for fumigation, and doing so without one is an offence. The [Pest Control Products Board](https://www.pcpb.go.ke/) publishes lists of registered products, including public health products, so you can check what is being used in your plant.

Put together, a simple floor rule follows: **keep pests out by design and housekeeping, watch for them every day, act fast with qualified people, and keep records that show it.**

## Why "we have a contractor" is not a control

A monthly visit fails in three predictable ways:

1. **Nobody owns the gaps between visits.** A door seal fails on day three. The contractor finds droppings on day thirty.
2. **The report goes in a file, not into action.** Codex is clear that the food business must review monitoring reports. If the report says "activity at station 14" for three months running, someone in your team should have asked why.
3. **The cause is never fixed.** Baiting kills rodents. It does not close the drain they came through or clear the spillage that fed them.

**Illustration (not real customer data):** a maize mill's contractor reports rodent activity at the same two bait stations near the bran store every month. The bait is replaced each time. Nobody links it to the bran bags stacked against the wall with a torn corner, or to the gap under the side door. Moving the stack off the wall and fitting a door brush does more than six months of re-baiting.

## The 8-step pest control checklist

### 1\. Draw the site map and number every device

- Make a simple plan of the site showing buildings, doors, drains, stores and production rooms.
- Mark every bait station, trap and insect light trap with a number, and fix the same number on the device.
- Mark which areas are external, internal non-food, and internal food areas, and agree which device types may be used where. Codex says traps and detectors should be designed and located so they cannot contaminate raw materials, products or facilities, which in practice means no loose bait inside food areas.

Without a map and numbers, "activity found" means nothing. With them, it becomes "station 14, three weeks running".

### 2\. Close the entry points

Codex lists the basics: keep the building in good repair, cover holes and drains, make roll-up doors close tightly against the floor, and screen open windows, doors and ventilators with wire mesh.

- Walk the building every week with a short list: door seals and brushes, mesh screens, drain covers, cable and pipe entries, roof and eaves.
- Log every defect with a date, an owner and a due date, and close it like any maintenance job. Pest-proofing belongs in your [preventive maintenance](https://factoraerp.com/en/blog/preventive-maintenance-basics-food-agro-factories-kenya) plan.
- Keep doors closed when not in use. A propped-open dispatch door undoes a lot of mesh.

### 3\. Take away food, water and shelter

- Store raw materials and finished goods on pallets, off the floor and away from walls, so you can see behind and under them. Codex specifically mentions stacking above the ground and away from walls.
- Clean spillage the same shift. Flour, bran, sugar and grain dust are a food supply.
- Keep waste in covered, pest-proof containers and empty them on a schedule.
- Remove old, unused equipment and clutter from inside and around the buildings, as both Regulation 7 and Codex expect.
- Fix leaks and standing water.

### 4\. Check what comes in

Pests often arrive in the delivery, not through the wall.

- Inspect incoming grain, packaging, pallets and vehicles for live insects, webbing, droppings and gnawed bags.
- Reject or quarantine infested loads and record why.
- Add a pest line to your [supplier intake checklist](https://factoraerp.com/en/blog/supplier-intake-checklist-food-manufacturers-kenya) so the receiving clerk knows it is their job too.

### 5\. Monitor every device on a fixed schedule

- Set a frequency for each device type and area, agree it with your contractor, and write it down.
- At every check, record the device number, date, who checked, and what was found: no activity, bait eaten, droppings, catch, damaged or missing device.
- Review insect light trap catches, not just whether the tube works.
- Train your own team to report sightings between visits on a simple sighting log: where, when, what, who.

### 6\. Act fast on activity, and fix the cause

When activity is found:

- Respond quickly, using a qualified provider for any treatment. Ask for evidence of the qualifications the 2024 Regulations require of the person in charge of the service, and a certificate for anyone fumigating with Restricted Class 1 products.
- Identify the cause: entry point, food source, harbourage or incoming material. Codex expects the cause to be identified and corrective action taken so it does not recur.
- Record what was done, by whom, and when the area was rechecked.

### 7\. Protect product when pests get close

- If there is evidence that pests reached product, packaging or a food-contact surface, place the affected lots on hold and assess them before release. Use the same process as any other [QA hold](https://factoraerp.com/en/blog/qa-hold-checklist-before-batch-leaves-warehouse-kenya).
- Clean and inspect the affected line before restart, as you would under your [line clearance checklist](https://factoraerp.com/en/blog/line-clearance-checklist-food-factories-kenya).
- Record which batches were near the activity. If a customer complaint arrives later, you need to know which lots to look at, which is exactly what a [mock recall](https://factoraerp.com/en/blog/how-to-run-a-mock-recall-food-traceability-kenya) tests.
- Record write-offs of pest-damaged stock with a reason code so they do not turn into an unexplained gap at your next [stock count reconciliation](https://factoraerp.com/en/blog/stock-count-reconciliation-checklist-food-factories-kenya).

### 8\. Control the chemicals and review the trend

- Keep only the pest control products you actually need, stored away from food and packaging, in labelled containers, with the product name and its registration details on file. Regulation 12 limits toxic materials in the plant to what is needed and requires precautions so pesticides do not contaminate food or packaging.
- Keep a record of every treatment: product, where, quantity, who applied it, and the date.
- Once a month, review the device logs with the contractor: which stations show repeated activity, which defects are still open, which areas need more devices or fewer.
- File the site map, device logs, sighting log, contractor reports, treatment records and corrective actions together. That file is what Codex means by records of infestation, monitoring and eradication, and it is what you show an inspector or an auditor.

## Habits that make pest control stick

- **Numbered devices on a map.** Activity always has a location.
- **Your team watches daily.** The contractor visits; you live there.
- **Every report gets read.** A finding without an action is just paper.
- **Fix causes, not symptoms.** Seal, clean and declutter before you re-bait.
- **Pest-damaged stock gets a reason code.** Losses you can explain are losses you can reduce.

## Where an ERP helps

A map, a clipboard and a disciplined contractor can run this checklist on one site. It gets harder when you have several stores, many devices, frequent deliveries and lots to trace.

FactoraERP tracks production batches and lots, stock status including QA holds, non-conformance records and stock adjustments with reason codes. That means a pest finding can be logged as a non-conformance with an owner, tied to the lots that were nearby, the affected stock can be held, and pest-damaged stock can be written off with a reason code instead of disappearing. See [factoraerp.com](https://factoraerp.com).

## Free download: eTIMS readiness checklist for factories

Hygiene records, stock records and invoices increasingly have to tell the same story for Kenyan manufacturers. If you want a free **eTIMS readiness checklist for factories**, sign up for the FactoraERP Insights newsletter at <https://isaacmuthui.substack.com>. You will get practical operations notes for food and agro manufacturers. No spam; unsubscribe anytime.

## FAQ

**What should a pest control checklist for a food factory include?**\
A numbered site map of devices, weekly checks of entry points, housekeeping and storage rules, inspection of incoming materials, a fixed monitoring schedule, a response and root-cause procedure, a rule for holding product when pests get close, and records of chemicals, treatments and reviews.

**Is a monthly pest control contractor enough?**\
A contractor is useful, but Codex CXC 1-1969 says that even when monitoring is outsourced, the food business should review the monitoring reports and make sure corrective action is taken. Your own team has to watch, report and fix causes between visits.

**What does Kenyan law require on pests in food plants?**\
The Food, Drugs and Chemical Substances (Food Hygiene) Regulations, 1978 require clean grounds that do not harbour pests, screening against birds, animals and vermin where necessary, effective measures to exclude pests from food areas, and pesticide use that does not contaminate food or packaging. Confirm specifics with your county public health office.

**Who is allowed to provide pest control services in Kenya?**\
Under regulation 12(6) of the Pest Control Products (Inspection and Certification) Regulations, 2024, the person in charge of a pest control service must hold a certificate in agriculture, animal health or a related science and have attended pest control operator training organised or recognised by the Pest Control Products Board. Fumigation with Restricted Class 1 products needs a Board certificate.

**Can we use rodent bait inside production areas?**\
Codex says traps and detectors should be designed and located so they cannot contaminate raw materials, products or facilities. Many factories therefore keep toxic bait outside or in non-food areas and use non-toxic monitoring devices inside. Agree the layout with your qualified provider.

**What records should we keep?**\
The site map, device check logs, sighting reports, contractor reports, treatment records with product and quantity, corrective actions, and any holds or write-offs linked to pest activity.

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*Isaac Muthui, CEO, Tamalaki Business Network Ltd*

*Originally published at* [*factoraerp.com*](https://factoraerp.com/en/blog/pest-control-checklist-food-factories-kenya)*.*