Tuesday, December 20, 2011

Certification Year One winds down for school IPM coordinators

One of the big changes to school IPM rules during the last legislative session was to expand education requirements for IPM Coordinators (the individual in each Texas school district responsible for overseeing pest control and ensuring the district complies with state regs).  Beginning last January, every IPMC is responsible to obtain six hours of CEUs every three years (See the Administrative Code Rule 7.150 (b)(2)).

The problem is that after a year of the rule we still don't know precisely what qualifies for continuing education units.  Let's review what we do know:
  • Anyone who began duties as an IPM Coordinator for a public school district on or before January 1, 2011 will have until December 31, 2013 to obtain six (6) hours of CEUs.
What we don't know for sure is what exactly qualifies as those appropriate CEUs.  The Structural Pest Control Advisory Committee argued quite strenuously about this topic about a year ago, and some general guidance from that discussion will be used as the basis of whatever rules are drafted in the next few months.  The committee suggestions were: 
  • One of the six CEUs must be in laws and regulations specific to IPM Programs in Schools.  The remaining five credits can be obtained by doing one of the following:
    • Attending one of the TDA-approved training courses for IPM Coordinators (this would be the same 6-hour course taken within the first six months of appointment)
    • Attending any five hours of TDA-approved pesticide CEU training in areas relevant to a school IPM coordinator's duties (e.g., Pest, L&O, Weed control, or General IPM). These CEU classes are pretty commonly available around the state.
    • Attend classes not approved by TDA as long as you send information into the agency and get the class approved within 30 days (see Section 7.135(g) of the Administrative Code for details)
The committee wanted the CEU requirement to be as easy to obtain as possible, but I'm not convinced that we didn't make it too easy.  Specifically, I think coordinators need more than one hour of school IPM rules-specific training every three years. Of course training in herbicide selection, or termite identification or  cockroach biology is valuable for someone in charge of a school pest control program; but ultimately a coordinator's job is administrative, and much or most of it has to do with knowing the laws and regulations inside and out. For schools who contract out pest control, the coordinator may be the only person in the district keeping outside applicators square with the law. 

And these laws and regulations are not especially simple to learn. I find myself learning new things every year when I teach the class; so I'm skeptical that one hour every three years is going to do much to keep coordinators at the top of their game.

I know many of you know this. My proof is the number of repeat attenders we see in the introductory school IPM coordinator training classes I teach each year with Janet Hurley. And my sole consolation is that I know many of you will go the extra mile and get those extra school IPM dedicated classes, regardless of whether you have to.  I'm more worried about the folks who haven't had a refresher course in 5-10 years, and don't see a reason to do so.  

The trouble is that the clock is ticking on these CEU requirements.  One year is passed and we still don't absolutely know what criteria will be used to fulfill the six CEU requirement.  So if you're a Texas IPM coordinator, keep alert for the proposed new regulations. If you have an opinion about the CEU requirements, please let them be known at that time.  And if you think I'm crazy to want tougher requirements, that's OK. But let's think these things through and have a good debate.


Mike Merchant, PhD said...

As I was writing this in a tired, end-of-day, frame of mind, I neglected to thank Mike Kelly of TDA for outlining the basic framework that TDA is working from, based on last year's committee deliberations. Mike is always a big help in clarifying current TDA rules and policies, and is the person I turn to when I need clarity on some obscure point of order. That said, if I got something wrong here, it's undoubtedly my fault for not communicating clearly.

Robert Wood said...


Just giving my opinion here but wouldn't it make more sense to have the 1 CEU for laws and regulations required to renew each year, I would love it if the IRS laws were stable for three years, but things change yearly.

The remaining five CEU's could be split between the TDA-approved training courses for IPM Coordinators, TDA-approved pesticide CEU training, and the "not-approved TDA" could be better filled with online CEU's, or performing training/hosting training with approved testing after.

Robert Wood
City of Santa Fe IPM Manager