Would eliminating Texas' public school IPM requirements affect student health?

New Texas school IPM coordinators get a
lesson in conducting IPM inspections at
East-Central ISD, in San Antonio this week.

On Tuesday the Texas Senate Education Committee held hearings on a bill that relates to school IPM.  Senate Bill 3 (formerly SB 468) is titled "flexibility of the board of trustees of a school district in the management and operation of public schools in the district" deals with several issues relating to efforts to make Texas legislation less costly to school districts.  At the end of the day long hearing (which included testimony from five witnesses who opposed the repeal of school IPM rules and no one specifically in favor), Senator Van de Putte (D- San Antonio) asked Janet Hurley, school IPM program specialist, and I whether in our opinion, repeal of the school IPM legislation would be harmful to childrens' health.

While this is a complex answer to address completely, we both had little choice but to answer yes.  Let me explain why.

Texas' requirement for schools to follow IPM principles and to encourage the use of less toxic pesticides has changed the way pest control is done.  We know, for example, that indoor school environments receive fewer pesticide spray applications today, 16 years after implementation of the IPM law.  Pesticide sprays inevitably deposit residues in places where they can be in contact with children.  One could argue that there is little evidence that proper spray applications pose any significant threat to children's health; but the facts remain that children are more likely to be exposed to potentially harmful spray deposits when they are used more frequently. Most of us would agree that keeping pesticides away from kids is a good thing. This is one of the reasons that the U.S. EPA has pushed schools to consider using IPM for almost 20 years.

A second reason for linking IPM to student health is that repeated research shows that IPM is the most effective way to manage pests.  This has been shown for cockroach control in schools, bed bug control in public housing, and numerous other sites. 

Why is pest control so important? Consider rodents.  Mice and rats spread human pathogens via feces and urine, invisible deposits of which can be found on food preparation surfaces, floors and desks of infested schools.  This is the situation we saw recently in a south Texas school district that obviously did not have a strong IPM program. I can tell you from personal observation that cockroaches are present in many Texas schools (even with IPM, we're not perfect).  Cockroaches are implicated not only in transmission of disease organisms like Salmonella, but also in allergen production. In some areas, cockroach allergies are just as frequent in human populations at house dust mite, cat, and pollen allergies.  These allergens are frequently encountered in school dust samples (Eggleston PA, Arruda LK. 2001. Ecology and elimination of cockroaches and allergens in the home. J Allergy Clin Immunol 107:S422-S429).  Similarly, house flies, fire ants, bats and other pests are among pests targeted effectively by IPM. Failure to control pests in schools is a failure to provide a safe learning environment for our children. 

If you are willing to accept these claims on the part of IPM, the key remaining question is whether IPM practice is likely to decline in the absence of a state requirement.  If the past history of pest control in Texas is any guide, the answer is not highly encouraging. Prior to 1995, when school IPM legislation went into effect, there were a few schools with good IPM programs, but most districts relied on scheduled spray visits.  One study showed that average satisfaction with pest control programs at that time was low (Damon Shodrock MS thesis, 1994).  According to our research, Texas school districts today are 75% more likely to be satisfied with their pest control program compared to 1993, before the law went into effect. We also found that 75% of school IPM coordinators believe that the Texas IPM requirements have resulted in more effective pest management in their districts.

I don't believe the change we've seen in Texas is completely the result of the pest control industry getting better over time.  Although there are few statewide surveys, and evidence is anecdotal at best, I think it's safe to say that non-regulated states have not made as much progress in the past 20 years as Texas. Colleagues from other states jealously note that it is difficult to raise interest in IPM among school administrators who are not required by some mandate to follow IPM standards.  And if you ask any maintenance professionals familiar with school IPM programs, having the support of school administration is key to IPM success in schools.

We were very appreciative of the opportunity to share these statistics with the Education Committee this week and hope that the Education committee and our legislature will make the decision best for the school children of Texas. Also, if you haven't seen it, a Texas Tribune article reported this week on the issue with voices both for and against the legislation. 

Working with health inspectors

Last week I had the privilege of providing IPM training to a group of state and local health inspectors from south Texas.  It was the first time I've had the chance to train health inspectors and it was an interesting experience. 

I learned that being a health inspector is likely to permanently dull your enjoyment of going out to eat.  After all, health inspectors see the (sometimes) scary underbelly of the food services industry.  Even in the restaurants with good records, if an inspector eats out, he or she is wondering how long the salad's been out, if the preparer was wearing clean gloves,  whether the refrigerators are cold enough, and if the dishwashers have been properly trained to disinfect the silverware.  Sometimes ignorance is bliss.

Unlike Larry the Cable Guy: Health Inspector (I've not seen the movie, but the subtitle is "They'll give anyone a badge"), these folks were professionals, very dedicated to their work and making sure the public health is protected.

The other thing I learned was how hungry these health inspectors are for IPM information.  Relatively few inspectors in our group seemed to have a strong understanding of pest management principles, or how the pest control business works. 

One of the more interesting discussions we had concerned the use of sticky cards as monitoring devices in restaurants.  As a PMP, you may have encountered restaurant owners who are unwilling to allow insect sticky cards in their establishment because they are afraid that any insects on the cards might alert the inspector to an insect problem that they might not otherwise know about.  After our training and discussion, everyone in the class agreed that having sticky cards in an establishment was a positive thing, as it showed that the owner cared, and was serious about monitoring the condition of the business.  [Of course sticky cards can be a two-edged sword.  Sticky cards that are not maintained and changed regularly can reflect conditions that no longer exist in the restaurant, and are likely a sign of lack of attention to detail on the part of the technician.] 

I learned that health inspectors try to look at the bigger picture when they score an eating establishment, school or day care.  An inspector will not necessarily consider a single cockroach on a trap or on the floor an "unacceptable" infestation.  It takes more infractions than just cockroaches or rodents to shut down a restaurant.  The inspector considers the overall condition of the facility, if the owners are making an effort to solve pest problems and whether they're employing the expertise of a professional. 

A good PMP can make the job of a health inspector easier.  Sticky cards and bait stations should be signed and dated every inspection.  Detailed documentation of what species of pests were observed, what conducive conditions for pests you've noted, pesticide types and amounts used, along with non-chemical controls employed, and the progress of the pest control program can be very helpful to an inspector. 

Health inspectors can be, and should be, the allies of pest control professionals.  After all, the goal of both kinds of professionals should be the same, namely: clean, pest-free and sanitary eating and living places.  I wish for our industry a better and closer relationship with health inspectors.  If you have the chance to meet an inspector don't neglect to ask them questions about how your customer's restaurants are scoring, what their perspectives are on pest control, and maybe provide some information about how your company approaches IPM.  You might gain a referral or two; and you might help them understand your perspective a little better.  

For my part, I hope to do more trainings with these public health professionals.  Wouldn't it be nice to know that your health inspector feels comfortable eating at any of the restaurants your company services?  That would be worth celebrating with a nice dinner out. 

Be careful what you wish for

Many of you know that for more than 15 years many committed people in our state have worked very hard to bring meaningful change to the way we conduct pest control programs in Texas public schools. In 1990 the Texas legislature passed a school integrated pest management (IPM) law requiring all schools to practice IPM by allowing pesticides to be applied only by certified applicators, appointing a trained IPM coordinators in each school district to oversee pest control, and set up a system for encouraging the use of less-hazardous pesticides. Since then, the law has succeeded, in my opinion, through diligent attention to careful and wise rule-making (aided by lots of public and professional input), daily enforcement activity by our structural pest control regulatory agency and lots (and lots) of training.

Today Texas has one of the best records in the country at getting schools to change the way they do pest control. The result has been not only reducing reliance on scheduled pesticide applications and encouraging the use of safer pesticides in schools, but also better pest control. All of these things work together to make schools safer, more pleasant places to work and study.

The process of change has been painful at times, and there have been mistakes made along the way, but it has been satisfying watching people pull together in the spirit of wanting to do the right thing for kids and schools. Part of the satisfaction many of us feel about school IPM in Texas is that we made it work, it is our program, and it works for us in our state with all its glorious fire ants, giant waterbugs and other unique pest challenges.

Meanwhile, other states around the country have struggled to bring an IPM approach to public school programs with varying levels of success. Progress has been slow enough that some have called for a national school IPM program. I agree that some form of federal legislation could be useful in encouraging school IPM implementation--after all state legislation has been the driving force for change in Texas. Such legislation, if passed, should require schools to follow IPM principles, establish training and certification criteria for those who conduct pest control and apply pesticides on school facilities, and let the states figure out the rest.

But that's not what H.R. 4159 the School Environmental Protection Act (SEPA) of 2009, introduced by U.S. Representative Rush Holt (D-NJ) looks like at all. This bill provides an object lesson in the old warning to be careful what you wish for. The bill is a modified version of bills that have been repeatedly introduced over the past several congresses, and which have never made it out of committee... for good reason. Among other things, the bill bypasses the regulatory label approval process used today by the U.S. EPA. It will essentially eliminate the right of schools to use most (I would guess more than 95% of) registered pesticides that are currently in use. It requires schools to notify parents every time a pesticide is used that is not on the (highly restrictive) list of "least toxic pesticides". It will essentially eliminate the ability of schools to use herbicides on grounds or sports fields. It (inexplicably) prohibits schools from using synthetic fertilizer, forcing them to use only more expensive organic fertilizers. It will establish a federal advisory committee that has the power to create a list of approved pesticides for all states. And it does all this without authorizing Congress to appropriate money to spend on IPM education or administration of the program, or for states to pay for enforcement of what will be highly unpopular regulations.

In my opinion, the approach taken by this bill will hurt the progress we've made in Texas on school IPM, and will likely set back progress toward IPM implementation in other states as well. In nearly all aspects of its construction, bill H.R. 4159 is more restrictive than Texas's laws and regulations. Supporters of the bill claim that it will not preempt existing state school IPM regulations, but that is only true when federal law is less restrictive than state law. The fact is that no state or school district in the U.S. have school IPM regulations stricter than this bill.

It seems to me that chances for passage of H.R. 4159 are slim, given the cost and burden it will pose on the nation's schools. Nevertheless the persistent return of this legislation year after year suggests that the blanket anti-pesticide advocates (those who oppose nearly any and every pesticide regardless of its usefulness or benefits) are not ready to give up. The shift in the balance of power in Washington, however, means that what has happened over the past several years may not be a faithful guide to what will happen this year. It is important that professionals who understand IPM read this bill and make their opinions known.

By the way, it's never been easier to read and comment on federal legislation. After a simple registration process, you can make comments on this bill at the Open Congress website at http://www.opencongress.org/bill/111-h4159/text . Using this site you can register your support or opposition and even write your legislators about any bill with a click of the button.