School IPM in Texas: How to Stay in Compliance with TDA.

With 4.8 million students, Texas has the second largest student base among US states according to the Texas Education Agency. And with 1,237 school districts and charters and 8,435 campuses Texas has more school systems than California. Over 83% of Texas school districts, are public school districts, which are required by Texas law to adhere to the school IPM rules.

School IPM in Texas began in 1991 with the passage of a law requiring that pests in and around school buildings be managed using integrated pest management. This was one of the first laws in the U.S. requiring schools to implement integrated pest management (IPM) as part of their maintenance programs. In 2007, the Legislature updated the law and provided more specific regulatory guidelines. Texas is one of the few states that requires IPM Coordinators in all public schools and mandates that they attend a six-hour training course on the basics of IPM principles and specific state regulations. The Texas Department of Agriculture, the regulatory agency for school IPM, has required an additional six hours of school IPM training since 2009. In 2005, the legislature revised the school IPM rules, standardizing inspections to ensure fairness and that schools would know what they must do to comply with the law. In 2010, the Texas Department of Agriculture implemented a new inspection process for schools. School inspections are now computer-based, utilizing 60 yes or no questions to determine the degree of implementation of IPM requirements in the school. The IPM coordinator for the school district should be able to answer yes to all of them. Schools that answer no to one or more questions are considered in non-compliance. The rules and the inspections parallel one another. Anyone who can follow the rules and understands the principles of IPM can pass a TDA inspection. Unfortunately, many of the school IPM coordinators have little experience with school IPM rules and they are not always prepared for an inspection.

AgriLife Extension school IPM classes, teach the defining principles of IPM, proper inspection methods, pest identification, use of non-chemical control tactics, and basic pesticide science. In addition, coordinators must become familiar with Texas school IPM regulations and a large portion of the training covers materials needed to pass a TDA inspection.

Texas A&M AgriLife Extension faculty tasked with providing school IPM training found, by experience, that equipping IPM coordinators to properly comply with school IPM regulations within a one-day training was not always effective. In 2002, Extension incorporated a two-day school IPM training class to see if additional training would improve school IPM coordinator success in meeting state requirements. As of 2010, the second day of training typically has the same amount of attendees as the first day, additionally the second day allows Extension faculty to instruct class participants on recordkeeping, developing thresholds and other finer points about IPM in a school system.

The non-chemical, preventative components of the school IPM program (sanitation, exclusion, monitoring etc.) reduce pest infestations and allow for early pest detection – so schools can use less pesticide and still do a good job of managing pests. The benefits are improved indoor air quality; greatly reduced potential for students, teachers and staff to be exposed to pesticides; and improved pest control. Many schools report lower costs of pest control. The Extension school IPM program team provides schools with individual assistance with developing and improving their school IPM programs when requested. Many school districts that attend Extension training request individual site visits afterwards to help them prepare for TDA inspections and assistance in IPM adoption. This service is no cost to the school district.

Many school districts struggle with the implementation and adoption process. Often, the IPM program is viewed as “just the pest control program” – with practitioners and administrators failing to grasp the holistic nature of effective school IPM programs. Schools that recognize that what goes on in and around the schools impacts pest survival and population growth inside school buildings. It is important for pest control technicians to understand that there is more to a school pest control contract than making a pesticide application.

Whether you currently have a pest management service provider or have in-house employees who conduct pest control, here are some tips you can use to stay in compliance with the Texas school IPM rules.

Monitor and Inspect:The school IPM rules require that all school districts have a monitoring

Monitoring to asses pest presence is essential, proper pest identification can help with determine the best way to eliminate a pest

program. This program should consist of placing sticky card monitors in areas known for frequent pest problems; such as kitchens, teacher lounges, wet areas, special needs classrooms and other areas identified by either the IPM Coordinator or facility inspections. The school IPM rules clearly state that the IPM coordinator must be able to perform a facility inspection. However, this inspection does not have to be conducted solely by the IPM coordinator. Prior to taking on a new account, every pest management professional should walk the facility. Licensed applicators should inspect both indoors and on the exterior building perimeters looking for pest entryways and noting other conditions conducive to the development of pest problems.

Thresholds and Written Guidelines: In 2009, the school IPM rules were updated requiring the district to have an IPM policy adopted by the School Board, and a written IPM plan, including thresholds specifying when pesticides are needed. Under TDA’s definition of integrated pest management (IPM) {TAC, Title 4, Part 1, Chapter 7, Subchapter H Rule § 7.114}, school IPM Coordinators and contractors must understand target pests and their biology. Schools are responsible for writing a school IPM plan which sets forth the recommended treatment protocol and provides direction as to when and where pesticides are to be used. With the aid of Extension professionals and Urban Entomologists from around the country, AgriLife Extension has developed several pest management plans and a sample written IPM program with thresholds, which can be found on the school IPM website, (under the resources heading). Routine application of a pesticides in a wet area, bus or other area, not specified in the school IPM plan, leaves the district and pest management professional open to TDA interpretation of whether the district is, or is not following school IPM regulations.

Documentation and recordkeeping: According to TDA, the number one violation for technicians, commercial and non-commercial applicators is failure of the applicator to write their name and license number on the service ticket. The service ticket is the pesticide application record and it is the binding document that tells your customer what was done, when it was done, and who did it. For schools this is very important. The school IPM coordinator must furnish copies of these records to the TDA inspector as a part of the school IPM inspection process. The second most common violation is not receiving an adequate copy of either the Yellow or the Red Category justification form. The best strategy is, every time your applicator uses a Yellow or Red Category product, call the IPM coordinator, fill out the form, and submit it to the coordinator. This allows them to include it in their IPM records.

The rule does not require this, but this small step makes a big difference in how well school districts are able to maintain recordkeeping compliance with TDA regulations and stay out of trouble.

Posting and Notification: No matter the account, posting 48 hours in advance of an indoor treatment is the law in Texas. Be sure that you and your staff are getting pesticide application notices to the school IPM coordinator, the business manager of chief administrator of your accounts in time for the required posting to be accomplished. Letting building occupants know when pest management staff will be serving an account is good business practice, not just a rule that you are required to follow. For outdoor pesticide application, the 2009 rule requires that you post a sign at the time of treatment. If you are using Green Category products, the sign must be put up at the time of application but it can be removed once the application is completed. For Yellow Category products (typically herbicides with a Caution signal word, and pyrethroids) the sign must be put up at the beginning of the application and it must remain in place for 4 (four) hours after you have finished the application. Finally, when Red Category products are used – those that have a Warning or Danger signal word, State limited use, restricted use or regulated herbicide – posting notifications must be in place at the time of application and must remain in place for 8 (eight) hours after the application has been completed.

In the months to come, Dr. Mike Merchant and I will be sharing additional information about the school IPM rules in TX. Over the past ten years we have learned a lot about school IPM not just in Texas, but nationally. There is still much to do, to keep our schools safe from pests and pesticides. Everyone involved must work together to have effective school IPM programs, and safe, healthy schools.  (Written by Janet A. Hurley)

New Pyrethroid Label Requirements (for Non-Agricultural Outdoor Pyrethroid Products)

Patty Alder, NCSU, Training Coordinator, Structural Pest Management

In an effort to reduce the potential for runoff and drift that can result from applications of pyrethroids, the EPA has revised the “Environmental Hazard Statements” and general “Directions for Use” sections for pyrethroid non-agricultural outdoor products. Pyrethroids include pesticide products such as “Talstar” (bifrenthin), “Tempo” (cyfluthrin), “Suspend” (deltamethrin), and others. The EPA revisions also apply to “combination products” such as: “Temprid SC,” and “Transport WDG and “Transport ME.” The new requirements also apply to consumer end pyrethroid-containing pesticides, such as “Ortho Home Defense Max” (bifenthrin), Bayer Advance Home Pest Control (cyfluthrin), and others.

With changes to pyrethroid labels it’s important to read the label before you buy the product, use the product or dispose of the product. Remember the Label is the Law

The new environmental hazard statements are specific for different formulations (i.e., liquid, dust, granular, and ready-to-use products). The general “Directions for Use” included in this labeling initiative are considered to be best management and good stewardship practices.

Let’s take a look at some of the new changes:
Requirements for Granular Formulations labeled or intended for outdoor residential uses:

•  “Apply this product directly to the lawn or garden area. Water treated area as directed on this label. Do not water to the point of run-off.”
•  “Do not make applications during rain.”

Requirements for Liquid, Dust, and Ready-to-Use Formulations products labeled or intended for outdoor residential uses:

• “Do not water the treated area to the point of run-off.”
• “Do not make applications during rain.”

Additional Application Restrictions For General Outdoor Surface and Space Sprays, except for outdoor fogging devices:

• “All outdoor applications must be limited to spot or crack-and-crevice treatments only, except for the following permitted uses:

1. Treatment to soil or vegetation around structures;
2. Applications to lawns, turf, and other vegetation;
3. Applications to building foundations, up to a maximum height of 3 ft.

Other than applications to building foundations, all outdoor applications to impervious surfaces such as sidewalks, driveways, patios, porches and structural surfaces (such as windows, doors, and eaves) are limited to spot and crack-and-crevice applications only.”

Although the label changes do not apply to turf (such as athletic fields and golf courses), these new label changes will affect the way you conduct pest management using pyrethroids. The one restriction that will probably impact your usual pest management techniques the most is the limitation of structural sprays to impervious surfaces. If you need to do a perimeter treatment, you are still allowed to apply the product up the foundation wall (to a maximum height of 3 feet) and on the soil and vegetation around the building. The major change applies to outdoor applications to impervious surfaces like sidewalks, driveways, windows, doors, and eaves. For example, in an area where a driveway meets a garage door, you are limited to either a spot treatment (an area no larger than 2 square feet) or a crack-and-crevice treatment in that area because both areas (the garage door and the driveway) are considered impervious surfaces.

Most likely, if you’re applying an exterior perimeter spray, you’re dealing with a pest like ants, millipedes, ladybird beetles, or another equally persistent pest. In those cases, a crack-and-crevice application to those impervious structural surfaces like garage doors, windows, eaves, etc., will provide the most benefit anyway, as those areas are often points of entry for these pests. So, here’s the good news: if you follow the new label requirements, you’ll be using the product in a more efficient manner and the potential for runoff will be reduced. A win-win situation!

(Patty Alder assists school in North Carolina with their IPM programs, along with Dr. Mike Waldvogel)