For those of you unfamiliar with this committee, think of it as the lite version of the former Structural Pest Control Board in Texas. The former Board consisted of industry, public and university members and was authorized to oversee the creation of regulations, and impose penalties on pest control companies who chose not to play by the rules. The advisory committee has none of the former Board's authority, but simply serves as a sounding board for the Structural Pest Control Service (SPCS) as it considers changes and improvements to pesticide regulations for licensed pest control companies.
That said, last month's meeting was a great example of how the advisory committee process can and should work. The principal chore put before us was to provide input on the new rules on IPM for Texas public schools. The TDA staff at the meeting were respectful of the committee's input and seemed eager to get these new rules written quickly and out to the industry and public for review. For the committee's part, everyone seemed to do their homework, came with good ideas, and were eager to reach consensus on all aspects of the rules.
No one has yet seen the newest draft regulations, but based on my notes, I think I can give a pretty good idea of the probable new structure and wording. That's my way of saying, "don't quote me on this". Everything is tentative until SPCS administrators Jimmy Bush and Jim Muse release the draft regulations--probably later this month.
While some of the changes were minor, there are some significant revisions that will affect the way we do IPM in schools in Texas (and maybe other states) for many years. One problem with the old rules was that there was a lot of confusion about what was meant by "IPM policies" and "IPM programs", both of which were required for all schools by state law. The new rules should be more clear, and spell out more explicitly what is meant by an IPM program.
Although the new rules still eschew an actual definition of IPM (there are almost as many definitions as there are people who try to define IPM), they do spell out what an IPM program should include. The rules will require a school IPM program to contain the following elements:
- a monitoring program to determine when pests are present or when pest problems are severe enough to justify corrective action;
- the use of the least-toxic effective methods available to control pests, rodents, insects and weeds;
- use of non-chemical management strategies where practical;
- a system for keeping records of facility inspection reports, pest-related work orders, pest control service reportes, pesticide application documentation, and pesticide complaints;
- a plan for educating and informing school district employees about their roles in the IPM program;
- and written guidelines (thresholds) for when pest control actions are justified.
They say there are two things you never want to watch being made: sausage and laws. Although we're not lawmakers, I believe the same rule of thumb applies to regulations. In our case there was a lot of discussion over what a monitoring program should look like, whether it should be "regular" or at predefined intervals, etc. We discussed the best wording for least-toxic, vs. least-risk, vs. low risk. Some discussions are inevitably tedious, but the committee's interest and attitude helped make it a lot less painful than other committees I've served on.
Besides defining the essential components of IPM, a few of the other key improvements were retaining most of the Green Category pesticide uses, requiring record retention for two years to make it compatible with other pesticide use rules (originally retention was proposed for five years, but industry objections made an impact here), and reducing the reentry periods from 12 hours to 4 and 8 hours for yellow and red category products, respectively. This last change is important. I am unaware of any scientific evidence to suggest that longer reentry times are needed for student safety, and shorter reentry requirements should make the job of controlling pests much easier for PMPs.
If you have an interest in school IPM regulations, keep alert for the new regulations. I will let you know when they come out. Whatever Texas comes up with will be a good example of a battle-tested model that other states interested in encouraging IPM and reducing pesticide exposure to students can learn from. And that sausage is worth tasting.