In my opinion, the Texas Department of Agriculture has done a good job listening to schools and the pest control industry, as well as our concerns in the public education sector. That said, I encourage anyone with concerns about the impact of these rules to participate in the public comment period.
These public comments do make a difference. In fact, the comments made during the last round, when the rules were first published, forced the agency to go back to the drawing board and review what they had proposed. The second version, represented by today's rules, is much improved.
We have 30 days from today to get comments and suggestions about the new rules to the TDA. Written comments are the preferred method, and probably the only chance to be taken seriously by the process. Send your comments to Mr. Jimmy Bush, Assistant Commissioner for Pesticide Programs, Texas Department of Agriculture, PO Box 12847, Austin, Texas 78711.
New since the last advisory committee is a definition of IPM for schools. This was something I noted in my last blog on the subject had been avoided until now. I think they did a good job with the definition. To recap then, some of the most important impacts these rules will have on the way we do pest management in Texas schools include:
- all school IPM coordinators (IPMCs) will be required to attend training on a regular basis (a minimum of six hours every three years);
- the definition of IPM is made more clear under the new rules and will require all schools to
have monitoring programs, keep an organized record-keeping system, develop an education plan for school district employees, and have written thresholds for important pests;
- non-pesticide control measures will be exempt from posting requirements;
- the existing criteria for Green category pesticides will be retained and clarified;
- the reentry interval for students after pesticide applications will be shortened from 12 to 4 hours in most cases, and reentry for Green category products will be allowed as soon as sprays have dried;
- outdoor areas of pesticide application will require posting at time of application for duration of the required reentry interval.