There is no “I” in IPM; it’s all about Team.

By: Janet A. Hurley

Integrated pest management (IPM) is like football. In football, it takes a team to win or lose a game. No single person is the breaking point. Successful IPM requires people management and teamwork. A solid IPM program requires several groups of people to work in conjunction with one and another, and to practice the basic principal that no one person is responsible for everything. Taking ownership of one’s actions and helping others is a basic principle of advanced society. IPM and the indoor air quality (IAQ) program use these principles and embrace the famous Ben Franklin quote, “an ounce of prevention is worth a pound of cure.”

Administrators may not understand the varied roles of an IPM/IAQ program. They might believe that they have an effective IPM program because there is a designated IPM Coordinator, a licensed pesticide applicator, and inspections. However, this philosophy will fail in the end because others within the district will not realize that they have an active role in maintaining their school building. School buildings take a lot of abuse from faculty, staff, and students. Large numbers of people moving from one place to another can carry pests with them. Reminding all personnel not to bring insect killer to school is only one small item in the IPM program.

School facilities are like children. They need constant attention and upkeep, yearly physicals in the form of inspections and proper training of employees to keep them running efficiently. While appointing a good IPM Coordinator is critical, the way in which the other players within the district interact and support the Coordinator is crucial as well. Super humans are for the comics and movies. In reality most of us are wearing several hats and managing several areas. Communication is essential to be successful. A work order system is good to have, but it does not replace an occasional conversation between facilities and principals, teachers, and staff.

We can go a long way in maintaining a pest free building by educating school personnel about what signs of pests to look for, ways to identify pest entry ways, and by keeping clutter to a minimum. Teaching school nurses and faculty the indicators that children that could have bed bugs, head lice, or cockroaches at home could help that child in more than one way. As adults we are there to help the young; this is just one way we

Using flyers like this one from Spring Branch ISD can help IPM on employees minds throughout the school year.

can all help.

For food service personnel, conducting periodic training on IPM helps kitchens maintain high scores with local health department biannual inspections. Ensuring that staff understand the importance of routine cleaning of floor drains, deep cleaning of equipment and watching for water leaks will help keep the area inhospitable for pests like drain flies, cockroaches, and ants. Discussing the importance of keeping food storage rooms clear of clutter, the reasons for using plastic storage containers rather than cardboard boxes for long term storage, and cleaning up spills immediately reduces the risk of mice and rats of taking up residence. Making kitchen staff aware of how to report pest sightings is important. It is also important to ensure that this group knows what monitoring devices are and how to preserve them so that if a pest appears they can tell someone.

Mops stored improperly create a good place for cockroaches and ants to thrive.

The custodial department is critical to every institution. Custodial staff are more than just the guy or gal who empties the trash; they keep the building functioning. This group of employees is essential in keeping pests out of buildings by eliminating the food, water, and harborage that pests need to survive and thrive. On the other hand, custodial staff can inadvertently contribute to a pest problem. Keeping a clean, dry, and organized custodial closest goes a long way to keeping cockroaches from thriving in these rooms. At times, custodians will keep the room clean, but unknowingly keep water in the mop bucket or the floor cleaning machine, not realizing that is the

Hanging up the mop properly as shown, and keeping the floor machine empty water help reduce harborage sites for cockroaches.

perfect place for roaches. Hanging the mops properly keeps bacteria from growing in the mop, so that flies and roaches don’t have something to live off of. Working with teachers and students on trash removal and spill clean ups in classroom areas is key to pest control. Training custodial staff on small tips to be on the lookout for inside and outside the building can help prevent pests more than any pesticide application.

Facility maintenance and grounds staff can ensure that work order and preventative maintenance tasks are handled correctly. When training trades workers about IPM, pointing out the importance of sealing up holes, cracks, and crevices is essential in keeping pests out of the building. Illustrating to them that mice can squeeze through an opening the size of a dime, and rats the size of a quarter, can be critical when making a repair or installation into a conduit line. Grounds personnel can help with the IPM program by pointing out potential sites for birds, wasps, moles, yellowjackets or vertebrate pests.

Sealing up the openings around these conduit lines would be more effective than placing a rodent bait station at this location.

Explaining to this group that if they see areas where small mammals can live or insects can nest on or near playground equipment can help prevent a problem in the future.

Teachers and students can contribute to the IPM solution in many ways. Helping them to understand that they play a critical role in the IPM/IAQ program and how IPM contributes to their own personal health and well-being is the key to gaining their participation. Tools such as posters, emails, and simple messages serve to remind everyone there are things they can do to help mitigate pest problems. Classrooms are clutter magnets; however, there are ways to keep the clutter to a minimum. Utilizing plastic storage tubs, metal shelving racks, glass jars for counting beans, and other sturdy storage items will help keep the room organized and easier to inspect when there is a pest problem. Work with students to empty their backpacks, book bags, and other large carry items occasionally. Taking these items outside and dumping them on concrete can help reduce pest’s introductions into the classroom or building.

Finally, to make any program successful, including IPM, communication is essential. For the IPM Coordinator it means communicating with everyone in the district, either through face-to-face training, email, newsletters, or telephone. For the IPM Coordinator, having regular communication with their pest management professional (contractor or in-house) is just as critical as performing a pest control action. When the IPM Coordinator and the PMP talk, they should discuss what applications have been made either at a campus, district, or office building. At the same time, they should also discuss any ongoing pest problems. If the same pest problem is persisting for more than six months, then the coordinator and PMP will need to look at what has been done, what non-chemical control measures have not been met and what alternative actions can be performed to reduce the persistent pest problem. There is always the option to seek additional help from a Board Certified Entomologist, Extension Specialist or other qualified individual that can help you solve your problem.

In summary, as an IPM Coordinator, your job is to support student achievement through maintaining facilities that promote health, school morale, air quality and school success. Through IPM, we can have better schools, better students and a healthier community! So why not start your education program today – share this story with a co-worker.

For additional educational resources, posters, handouts, and presentations visit our school IPM website at https://schoolipm.tamu.edu/forms/ipm-presentations-and-training-tools/

REGULATION ALERT   REGULATION ALERT   REGULATION ALERT

As you are aware, the Texas Department of Agriculture oversees the school IPM regulations as well as pesticide applications.  On, September 18, 2015, TDA placed several proposed changes to the structural pest control rules in the Texas Register.  All new rules must go through the process of being posted to the Register and then allow 30 days for public comment.  You may either go to http://www.sos.state.tx.us/texreg/archive/September182015/index.html

This is your only opportunity to make comments, both positive and negative, on the Regulations, which will govern the pest control industry and school IPM for the next several years under TDA.  Please make this a priority.

Written comments on the proposal may be submitted to Stephen Pahl, Administrator for Consumer Protection, Texas Department of Agriculture, P.O. Box 12847, Austin, Texas 78711 or by email toStephen.Pahl@TexasAgriculture.gov . Written comments must be received no later than 30 days from the date of publication of the proposed amendments in the Texas Register, which means your response must be received by October 18, 2015 if you want to be heard.

Below are some sections that you should pay close attention to.

• 7.122.Applications for Licensing, Registration, Certification, and Approval. This section is designed to tighten up the regulations for licensed applicators.

(a) The application for a business license, a certified applicator license, technician license, or for registration as an apprentice under this chapter must be submitted on a form prescribed by the Department, which may be updated from time to time.

(b) Applications must include all information requested, unless the information is clearly marked as optional.

(c) A license application may be denied if a same or similar license issued to the applicant by this or another state or federal government has been revoked, suspended, probated or denied during the preceding five-year period for any reason that could result in the Department denying licensure or registration. For the purpose of this section, a license is similar if the license was issued for the practice of an occupation in which professional services are normally provided in-person.

• 7.150.General Standards for Use of Pesticides. This used to be the section designated for School IPM that is changing, but this new section is something you should understand if you apply pesticides in TX.

(a) Use of a pesticide shall be made consistent with the pesticide’s labeling. Use inconsistent with the label includes, but is not limited to:

(1) applications at sites, rates, concentrations, intervals, or under conditions not specified in the labeled directions;

(2) tank mixing of pesticides, or using application techniques, or equipment prohibited by the label; or

(3) failure to observe reentry intervals.

(b) It shall be a violation for any person to use or cause to be used a pesticide in a manner inconsistent with any permit or emergency exemption issued by the Department or EPA.

(c) A pesticide shall not be used if the complete label is not available and the pesticide’s identity is unknown. The words “Unknown Pesticide – Hazardous Material” shall be written on the container. The pesticide shall be stored and disposed of in accordance with all state and federal laws.

• 7.151.General Standards for Storage and Disposal of Pesticides. This is another new section that should be reviewed by company owners, operators and distributors.

(a) Storage and disposal of a pesticide and/or its container shall be made consistent with the pesticide’s labeling.

(b) No person may dispose of, discard, or store any pesticide or pesticide container in a manner that may cause or result in injury to humans, vegetation, crops, livestock, wildlife, pollinating insects, or pollution of any water supply or waterway.

(c) The applicator, the owner of the pesticide, and/or the person in control of the mixing shall be jointly and severally liable for proper storage and disposal of pesticide containers and contents.

(d) The name on either the pesticide label or the specimen label shall be written on the pesticide container if the name of the pesticide is not on the pesticide container and the pesticide’s identity is known. Nothing in this subsection shall be construed as authorizing the misbranding of a pesticide as defined in §76.023 of the Texas Agriculture Code.

(e) A person storing a pesticide shall maintain the complete label of that pesticide, in hard copy, for as long as the pesticide is being stored. If the complete label is not available and the pesticide’s identity is known, the person storing the pesticide shall obtain a hard copy of the EPA pesticide label.

(f) For every pesticide that is being stored, a hard copy of the complete label, shall be made immediately available for inspection to the Department’s inspector at the site where the pesticide is being stored.

DIVISION 7. INTEGRATED PEST MANAGEMENT PROGRAM FOR SCHOOL DISTRICTS 4 TAC §§7.201 – 7.205 – This will be a brand new section for school IPM, rather than falling under the compliance and enforcement section of the structural pest control rules, school IPM will have its own section under the TAC code.  The TX school IPM rules will remain the same, except there are a couple of changes that many IPM coordinators will be happy to see.

• 7.202.Responsibilities of the IPM Coordinator. You will notice in this section, what is considered continuing education credit for IPM coordinators is clearly spelled out, you will also notice if you are licensed applicator and the coordinator that you can obtain dual credits for both IPM and your license.

The IPM Coordinator(s) shall be responsible for implementation of the school district IPM Program. In addition, the IPM Coordinator(s) shall:

(1) successfully complete a Department-approved IPM Coordinator training course within six months of appointment;

(2) obtain at least six hours of Department-approved IPM continuing education units (CEU) every three years, beginning the effective date of this rule or the date of designation, whichever is later. The three-year period will begin from the date the IPM Coordinator receives initial training after being appointed by the superintendent, or if currently designated and trained as the IPM Coordinator, when this rule revision goes into effect. No approved course may be repeated for credit within the same three-year period. One of the six CEUs must be related to laws and regulations specific to IPM programs in schools. IPM Coordinators may satisfy the CEU requirements through one or more of the following methods:

(A) Completing a Department approved training course for IPM Coordinators;

(B) Completing courses that have been approved in the pest, lawn and ornamental, weed control or general IPM category; or

(C) By submitting information for a course completed, that was not previously approved by the Department, for the evaluation of credit. The information must include the name of the instructor(s), verification of attendance at the course, length of time of the course stated in hours and minutes, a detailed course outline indicating the scope of the course and learning objectives, and the number of continuing education units requested. Additionally, the IPM Coordinator must demonstrate that the course content is appropriate and pertinent to the use of pesticides and the implementation of IPM strategies at school buildings and other school district facilities.

(3) If the IPM Coordinator is also a licensed applicator, the CEUs obtained for the license under §7.134 of this title (relating to Continuing Education Requirements for Certified Applicators) will count towards the six hours of IPM CEUs.

(4) Following the three-year effective CEU period, IPM Coordinators must maintain certificates of completion for one additional calendar year (period through December 31). The certificates are subject to inspection by the Department at any time upon request.

• 7.204.Pesticide Use in School Districts. For this section the wording is almost the same as it was prior to the moving to the new section. However, under item four (4) you will notice one major change – the allowance of the IPM Coordinator to be able to train an unlicensed employee to place out monitoring devices. For years we have been encouraging TDA to implement this change to help schools out, as you can see they were listening.

(4) The use of non-pesticide control measures, non-pesticide monitoring tools and mechanical devices, such as glue boards and traps as permitted in accordance with Division 7 of this subchapter (relating to Integrated Pest Management Program for School Districts), are exempt from posting requirements. The use of non-pesticide tools and devices by unlicensed school district personnel, for monitoring purposes, shall be permitted. Monitoring by unlicensed school district personnel shall be done only as directed, under the supervision of the IPM Coordinator.

As stated at the beginning of this narrative if you would like to see the full set of rules you can visit the Texas Register website at http://www.sos.state.tx.us/texreg/archive/September182015/Proposed%20Rules/4.AGRICULTURE.html#4

What do you need to do, tell TDA if you are happy or not.  For many IPM coordinators you have been patiently waiting for the day when you could legally train someone to put out a monitoring device, tell TDA thank you. If you don’t like what you see, tell TDA as well, your governmental agencies are only as good as the public input they receive.  Remember we can all participate if we just take a few minutes out of busy day to let our government leaders know how we feel.