Winter Structural Pest Control Advisory Committee

I just returned from the Texas Department of Agriculture's quarterly Structural Pest Control Advisory Committee meeting.  The purpose of the committee is to advise the TDA and its commissioner on education and curricula for PMPs, examinations, proposed rules and standards on technical issues related to pest control, fees and other issues affecting the practice of pest control in Texas.

Today's meeting was relatively brief, but informative. We met two TDA staffers that work actively behind the scenes on pesticide-related issues.  Rafael Paonessa is in charge of reviewing and approving the structural pest control CEU courses that all license holders must attend each year.  Rafael is the person I deal with to get approval for CEU classes that we offer.  He is always efficient and easy to work with.  He reported on recent overhauls of forms and procedures used in the re-certification program.

The biggest changes in the recertification process are in how course providers handle class attendance records, a subject I wrote about in detail last November.   The most common issue in getting courses approved, he said, is when providers do not provide enough detail about the planned course(s).  It's important to provide enough information for his office to determine whether the course meets department guidelines. It's also important that class content relates directly to pesticide use or pest management. General horticultural topics, or workplace safety topics (unrelated to pesticide safety), for example, will not be approved. The department does conduct spot checks of CEU classes to make sure the content is being covered and does not consist of advertising for a particular product or company.  Detailed information on putting together a course for CEUs is available in the just revised Pesticide Recertification Course Accreditation Guide, which is available online.

A new EPA-mandated Pollinator Protection Icon
will appear on many new pesticide labels.

The other employee we met today was Dale Scott. Dale handles the pesticide product evaluation and registration system at TDA. Many people believe that EPA is THE agency that approves pesticide labels, but in fact all pesticides must also be registered by each state in which they will be sold. This is why not all pesticides are registered, or legal for use, in all states.  Approximately 16,000 pesticide labels are registered in the state at any time, and his office processes about 3,500 new pesticide registration requests every year.

Dale reviewed information about new pollinator protection guidelines that are beginning to appear on pesticide labels. Four neonicotinoid insecticides will be the first insecticides to come under the new pollinator protection label guidelines. Changes to look for include pollinator protection information under all Directions for Use statements, a new bee icon to draw attention to pollinator protection information, and consistent warning label language about applying insecticides when bees are actively foraging.  This is a topic that all pest management companies and technicians should be aware of. Dale promised to make his PowerPoint on the topic available to the committee.

Also, Maron Finley, IPM in Schools specialist in the department reported on the top ten violations found in school IPM program inspections this past year. Most, he noted, related to inadequate record keeping. In order, they included:

1. No written guidelines that identify pest thresholds.  (155 violations, 39% of schools)
2. Not maintaining records showing approvals of Yellow Category pesticides (93 violations, 23% of schools)
3. IPM program records not maintained for the required time period (64 violations, 16% of schools)
4. IPM Coordinator not conducting periodic facility inspections (63 violations, 16% of schools)
5. No system for keeping records of facility inspection reports, pest control service reports, or pesticide applications (57 violations, 14% of schools)
6. No plan for educating and informing school district employees about their roles in the IPM program (54 violations, 13% of schools)
7. No monitoring program to determine when pests are present (48 violations, 12% of schools)
8. No reference [in the IPM policy] to Texas laws and rules governing pesticide use and IPM in schools (40 violations, 10% of schools)
9. IPM Coordinator training not completed within six months of appointment (32 violations, 8% of schools)
10. Name and license numbers of persons applying pesticides not on file (31 schools, 8% of schools)

A more serious violation, which occurred only 10 times, and did not make the Top Ten list, was applications made by non-licensed applicators.  Maron noted that 9 of these violators were small, class 1A to 3A, schools, and that all were in rural communities.  

Several on the committee commented that the overall violation rates seem low, and that compared to when the school IPM program first started, the state has made very good progress.  Nevertheless, everyone agrees that there is more work to be done to increase compliance.  Stephen Pahl expressed the desire for TDA to do more outreach to school administrators.  TASB, TASBO, and TASA are three school-oriented organizations that have ongoing meetings where school IPM talks can be presented.  George Scherer, of Texas Association of School Boards, was present and commented during public testimony that it is possible to get the names and contact information for school board members if needed during the compliance assistance phase of helping a school district.

Arnold Anderson, from Katy ISD, provided testimony on the subject of violations during the public comment portion of the meeting.  He suggested that schools with little experience in IPM should be encouraged to seek out a mentor school district rather than being fined. A suggestion was made that perhaps the TDA could facilitate mentoring by maintaining a current list of districts willing to mentor other districts in their IPM program development.  This might be another way TDA could reduce the number of school IPM violations without having to resort to administrative fines or penalties.

Finally, we were advised today that there is still an opening on the Advisory Committee.  If you know of someone who is not connected directly or indirectly with the pest control industry, and is interested in serving as a public member of the committee (with no pay or travel reimbursement), Leslie Smith is accepting applicants.