Unlicensed applicators in schools?

It has come to our attention that a bill has recently been introduced in the Texas legislature that would eliminate Texas state requirements for persons applying pesticides in public schools to be a licensed applicator.  HB 3590 was recently introduced by James Frank of Wichita Falls. It's a very short bill, and says merely that "a school district employee is not required to hold a license... to apply at a school building or other school district facility, in a manner consistent with the label, a pesticide that is available for purchase by unlicensed members of the public." [my emphasis]

While I and my fellow extension employees will not take a public position on any state legislation, I think it might be useful to make you aware of the issue.  To be clear about what the bill does, it would allow teachers, custodial staff, coaches, administrative assistants, kitchen employees or any other school district employee to apply insecticides at their own discretion in a school or athletic field.  This would bypass the normal process of pesticide approval and the authority of IPM plans as determined by the IPM Coordinator of the district.

As you think about how you feel about this requirement, here are some things to keep in mind:

• School IPM requirements have been in place in Texas since 1995, and have become widely accepted and followed by school districts throughout the state.  While some school leaders have expressed concern over the IPM restrictions and licensing costs, our data show that safer practices are being adopted by schools and that overall knowledge of IPM and its implementation has increased significantly.
• Licensing and training ensures that pesticide applicators are aware of the risks and rules governing pesticide use.  Licensed applicators are also trained in pest identification and how to determine the best and safest means of managing any given pest.  The rationale behind licensing is that untrained and unlicensed applicators attempting to control pests are less likely to be successful, and more likely to apply pesticides unsafely or unnecessarily.
• Current rules already allow for certain unlicensed school employees to apply pesticides under limited "emergency" circumstances; however some verifiable instruction is required to ensure that the employees understand the pesticide label and how to use a product safely.
• With the exception of a few restricted use pesticides, nearly any professional pesticide product or active ingredient is currently available for purchase by unlicensed members of the public via feed and seed stores, garden centers, hardware stores or online outlets.  Any of these products, if used without discretion or without following label directions exactly, can be dangerous to the health of children and school employees.
• As was pointed out in a 1999 Government Accounting Office report on pesticides in schools: "Children are at greater risk from pesticide exposure than most adults because, pound for pound of body weight, children breathe more, eat more, and have more rapid metabolisms than adults, and they also play on the floor and lawn where pesticides are commonly applied. Children have more frequent hand-to-mouth contact as well." Concern about the safety of school children and the need for a safe school environment was the driving force behind passage of the Texas School IPM regulations in 1991.
• In a recent statewide survey, 88% of school IPM coordinators agreed that the rules and regulations requiring IPM helps their school district provide a safer place for children and staff.

Changes in the rules of the game for Texas PMPs

New rules start as laws passed by the Legislature under
the Texas Capitol dome.  Laws become enforceable only
after rules are drafted and published for public comment by
the lead agency, like Texas Department of Agriculture.

New rules governing the pest control industry in Texas were published last week and are now in effect.  While none of the changes in the "rules of the game" are major, there may be a few things that affect your business or school district.

The rules governing pesticide use in Texas can be complicated, and are passed down to us through two sets of documents.  First, the Texas Occupations Code (TOC) contains  the official list of laws as passed by the legislature pertaining to different occupations, including structural pest control. If you go to this code online, the chapter having to do with pest control is Chapter 1951. Chapter 1951 lists all the state law as passed over the decades that relate to the business of structural pest control.
 
The second, and probably most relevant set of rules to our industry is the Texas Administrative Code (TAC).  The TAC records how the various state agencies choose to interpret and administer the laws. For example, Section 1951.212 of the TOC directs the Texas Department of Agriculture to establish standards for an IPM program for public school districts.  The TAC Sections 7.201-7.205 spell out what the standards are, including requirements for IPM coordinators, pesticide categories, posting requirements, etc.

But wait a minute. How can non-elected bureaucrats in a state agency write rules outside the legislative process?  The answer is that legislators don't have the time or the expertise to write detailed regulations, so they pass their rule-making authority on to Executive branch agencies like the Department of Agriculture.  Of course the rules have to fairly interpret the law, and they must be published ahead of time in the Texas Register so that all of us can review and comment.

Publication of several new or revised sections of Subchapter H of the TAC (Texas Department of Agriculture) marks the end of this process for pest control rules this year.  On December 18 the Texas Register published the results of public comment and listed the final versions of proposed rules originally published on September 18. With this final version, the rules are now considered to be in effect.

Most of the changes were made simply to clarify wording of the old rules.  There was also some reorganization of section numbering, so that old rule citations may no longer apply.  Here are the essential changes:

• Sec. 7.122 Changes in wording that include giving power to the Department to deny a license to anyone who holds a similar license that has been revoked, suspended, probated or denied within the last five years by another state or by the federal government.
• Sec. 17.127 There are no more fees for providing a continuing education course.
• Sec. 7.141  Rewording of rules pertaining to ID that must be carried at all times by license holders.  Basically, if you have a license you must carry it on your person at all times and show it to any customer or relevant government employee who asks. If it's not legible, then its not a legal ID.  Also, language on vehicle signage has slightly changed to require all marked or unmarked vehicles being used for customer contact or service must have the business license number prominently displayed (magnetic signs are not OK).
• New Sec. 7.150 requires all pesticides be used consistent with the pesticide labeling, and prohibits use of any pesticide missing a complete label when the identity of that pesticide is unknown.
• New Sec. 7.151 prohibits anyone from hurting people or the environment, and making the pesticide owner, the applicator and/or the mixer equally responsible for proper storage and disposal of pesticide containers and contents. It also requires all pesticide containers to be labeled with the name of the pesticide.  And it specifies that hard copies of all pesticides being stored shall be available for inspectors visiting the storage site.
• Sec. 7.152 states that no one may advertise to perform structural pest control services without a license, and that all advertising must include the same business name as is on the license.  This rule was rewritten to ensure that companies not use multiple business names under the same business license, and to clarify that pest control advertising includes online ads such as might appear on sites like Facebook, Craigslist and Angie's List.  
• Sec. 7.193 is a new section number which clarifies who may qualify as a member of the Structural Pest Control Advisory Committee from an institution of higher learning (the position I formerly held, and now is being held by Dr. Robert Puckett).  
• Sections rules for the IPM program for public school districts have been moved to a new Division (7) and renumbered from Sec. 7.150-7.154 to 7.201-7.205.  The biggest changes in this section relate to CEU requirements for IPM Coordinators.  
• Sec. 7.202  School IPM coordinators no longer are specifically required by rule to personally conduct periodic inspections of their school district.  While this remains desirable, taking away this rule frees the coordinator to rely on other trained inspectors to provide inspection reports.
• Sec. 7.204 includes slight wording changes to clarify that outdoor areas treated with a pesticide may be posted at all entry points with a sign in lieu of a lock, fence or barrier tape until the reentry time is over.  This section also allows IPM Coordinators, or their supervised employees, to use non-pesticide containing monitoring devices like sticky traps, to monitor pests without a license.

Perhaps the most significant change heralded by these rules is that expanded CEU requirements for school IPM Coordinators (IPMCs) are now officially in place.  Over four years ago, as a result of Sunset Commission recommendations, the legislature decided that ongoing CEUs would be required for school IPMCs.  Until now, the only CEU requirement was that IPMCs have six hours of department-approved training at the beginning of their appointment.  Under the new rule IPMCs must have six hours of verified, approved training every three years.  While most of these CEU requirements can come from any approved, relevant pesticide CEU class, at least one of the hours must be related to school IPM rules and regulations.  The countdown for existing IPMC's three years will start this January, or for new IPMCs at the date whenever their initial training is completed. Pesticide CEUs obtained in support of a pesticide applicator's license can be double-counted toward the CEU requirements for IPMCs.

After seeing how long it can take the TDA to publish its rules, I don't feel nearly as bad about the stacks on my desk.  

School time and that means L.I.C.E.

Head lice are not your typical pests.  For one thing, they largely afflict children. For another, they have very short lives off their host, so are not considered structural pests. Yet PMPs and school IPM coordinators are frequently asked questions or asked to help with head louse infestations.  So I think it's important for the pest control community to know something about these insects, and the latest treatment options.

When my daughter was in second grade she came home from school with head lice. My wife was horrified, but I have to admit I was a little excited.  "My chance to get experience killing head lice," I thought.  But after the third shampoo treatment, and head lice still showing up, it wasn't fun anymore. Perseverance, and lots of time with the louse comb finally got rid of the problem; but it left me with a greater respect for the head louse as a worthy opponent.

With the new school year, we expect new cases of head lice. And according to a new paper delivered at the American Chemical Society and reported this week in Smithsonian.com, this year's head lice are running with a tougher crowd. In the paper by Kyong Sup Yoon, Southern Illinois University-Edwardsville, Texas is among 25 states tested so far and shown to have head louse populations that are resistant to the most commonly used over-the-counter (OTC) head louse shampoo treatments: pyrethrins and permethrin.  In fact, most of the samples tested by Yoon and colleagues (104 out of 109 samples) showed resistance to OTC louse treatments.

If you work with school nurses at a school district, or are asked by customers about lice treatment, or are simply a parent yourself, it pays to be familiar with the latest treatment options for head lice.  After all, these aren't your mother's lice.

First, many lice problems can still be handled with OTC products. Keeping IPM in mind, however, multiple methods (insecticide plus mechanical control in this instance) are always better than one. Louse combs are a great second tool in the parents' tool box.  These fine toothed combs allow hair to pass between the tines, but not lice. Combing should always be done in combination with use of a louse shampoo.

In addition, new treatment options for lice are now available through your doctor.  These products include ivermectin (Sklice®), spinosad (Natroba™), and benzyl alcohol (Ulesfia®).  These products will likely be more expensive, you you might want to try the OTC route + combing first.  But it's always good to have options.  A recent review article by Drs. Cynthia Devore and Gordon Schutze in the journal Pediatrics does a nice job of reviewing these as well as other options for treating children for head lice.

Devore and Gordon also address the current recommendations for how schools should handle control including whether children should be screened, how to manage a child on the day lice are detected, and whether children should be restricted from school (they argue no).  This paper could be an especially useful resource pass on to your school nurse if you work for a school district.

To spray or not to spray

So are environmental sprays needed to help control head lice infestations in a school or home?  One can certainly find pesticides labeled for environmental louse control. Most professionals say no, sprays are not necessary.

Transfer of lice on furniture from one person to another can certainly occur.  I remember a day when my daughter had head lice.  She was reading a book in our living room chair when she got up to go outside.  I started to take her place when I noticed a live and hungry-looking head louse on the chair back where her head had been pressed.

Despite the occasional transfer of lice via furniture or bedding in this way, spraying of such items is not recommended.  Head to head contact, sharing of combs, scarves and hats during play, are far more important means of transmission; and spraying will not help stop these activities. Simple washing of hats, pillowcases and clothing is a safer and more effective means of dis-infesting these items than pesticide sprays.

Keep in mind that these tiny insects have a very short life span once they are off the human head. Head lice are highly sensitive to desiccation, and according to the CDC live no more than 1-2 days off of a host. Any head lice lurking on a bean bag chairs or coat rack in a classroom, therefore, will not survive a weekend in an empty classroom.

So let's leave treatment of head lice to doctors and parents. But let's be ready to offer advice and provide resources for customers and colleagues battling these adaptable pests.  For more information on head lice see our Extension publication on head lice.

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.

What can schools do about mosquito control?

In case you haven't heard, mosquitoes have been big news in Texas lately. This summer has turned into the worst summer on record for West Nile virus (WNV) in Texas, and both Dallas and Houston have resorted to aerial attacks to attempt to stem the tide of the mosquito and the virus.

Now with a new school year starting up, many school districts are asking themselves, "What should we be doing?" Parents will be concerned about their children waiting at bus stops and participating in band and athletics practice.  And let's not forget about Friday Night Lights, and weekly football games.  What responsibility do schools have to take part in community wide mosquito control?  And if you work for a school district, what will you tell parents when they ask what the district is doing to keep their kids safe from West Nile virus?

Source Reduction
Perhaps the most important single thing a school district can do is make sure that school grounds are not contributing to local mosquito problems. It's especially important to check water catchment basins, storm drains, low areas, and equipment storage yards, athletic and playground equipment for places where water might be caught and held. If you do pest control in a school district, expand your vision at this time of year to look for and report potential mosquito breeding sites.

If a suspected breeding site is found, report it to your local health department, or if possible, drain the water or treat with it. Effective mosquito treatments include Bacillus thuringiensis (Bt) dunks or methoprene (Altosid®) granules or briquets.  Both of these are Green category insecticides.

Treating Mosquito Resting Sites 
Mosquitoes are primarily active in the evening and morning.  During the day, adult mosquitoes typically rest in vegetation or other shaded sites. We can use this information to reduce mosquito numbers. Treatment of mosquito resting sites can dramatically reduce bites and biting rates in the immediate area of treatment.

If you know of areas of vegetation, or shaded doorways where mosquitoes are a problem, consider treating such sites with a residual pyrethroid spray. Pyrethroid insecticides like deltamethrin, cyfluthrin, bifenthrin, and lambda-cyhalothrin (Yellow category) can provide up to six weeks control on vegetation or building surfaces. These products can be applied via hand-held pump sprayer, backpack mist blower, or power sprayer to doorways and trees, shrubs and ornamental grass around buildings and entryways.

Such sprays are probably not necessary on most campuses, but in sites with heavy shade and vegetation, and populations of biting mosquitoes, such treatments may be warranted.  If you choose to treat sites like this, remember to post the school 48 hours in advance, and keep students and staff out of treated areas until sprays have thoroughly dried.

Low Volume Treatments

One of the five planes used to apply mosquito
sprays over Dallas County this month. (Photo
courtesy of Dallas Morning News and Tom
Fox/Staff Photographer)

When most people think about mosquito control they think about trucks or aircraft applying a fog or mist. The treatments used by such government agencies are called ultra-low volume (ULV) sprays.  The very tiny particle sizes used in such applications allow better penetration into dense foliage, and generally mean quick dispersal and short life of spray residues.

Most school districts will not engage in ULV sprays, though some cities or mosquito districts may offer the district an option to be included in community-wide spray actions. If ULV insecticides are to be used for campuses or sporting venues, remember to follow posting and notification requirements. Yellow category justifications must generally be filed, because most ULV treatments use Yellow category products like resmethrin or permethrin.  Synergized pyrethrin applications may be considered Green, unless the synergizing additive in the spray concentrate (generally piperonil butoxide) is greater than 5% .

The effect on mosquitoes from ULV-applied sprays is generally short-lived (few hours to a day), so they should be used only on special occasions, such as an hour or more before a sporting event. Wind and weather also have an important influence on the effectiveness of ULV sprays, so be sure to measure and record wind speed prior to application and follow label restrictions carefully.

If your campus has been sprayed as part of a community-wide aerial spray campaign, no special precautions should be necessary.  However some districts have been making a point to let parents know that school play equipment has been washed after spraying.

Education and Awareness
Ironically for schools, one of the most overlooked components of an IPM program is education. Mosquito season provides an excellent opportunity to get mosquito control information out to the community, as well as raise awareness of your district's IPM program.

One of the most important messages that a school can send is the importance of wearing insect repellent when working or playing outdoors. Consider notifying parents and students advising them to wear a good repellent to school, or at evening sporting events.

Many districts have had questions about whether they can allow students to use repellents on school grounds. Personal use of repellents is not prohibited or addressed by state school IPM regulations. Therefore it is up to each district to decide whether students and staff can bring and use repellents at school.  Options include allowing students to bring repellents to a school nurse, and having the nurse apply if needed. Another option might be to allow only cream or non-spray repellent formulations, especially for band and athletic departments in middle and high schools.  The time to decide on the appropriate policy, however, is now, before students return to campus.  For more information on insect repellents, see the excellent repellent guide put out by the National Pesticide Information Center.

As a public service, consider assisting the Texas Department of State Health Services and other local health authorities get the message out about mosquito control.  There are many useful educational materials and websites (see below) that parents should be aware of. School districts can play a useful role in getting mosquito awareness information out to our communities. Consider linking this information in your school district’s website.

Some quick facts about mosquitoes and West Nile virus: 

• The southern house mosquito, Culex quinquefasciatus, is the primary carrier of WNV in most of Texas (different species carry the virus in other parts of the country). This mosquito is a container breeder.  It prefers to breed in small containers or puddles of standing water. 
• Water must stand for 10-14 days to be a problem for mosquito breeding.  It doesn't have to be a lot of water, but this is approximately how long it takes for mosquitoes to complete their life cycle at 85-90 degrees F.  
• Remember stagnant, polluted (stinky) water is the water that Southern house mosquitoes love.  Water where fish are present, such as a pond or permanent stream is not usually a big source of mosquitoes. 
• Not all people are equally attractive to mosquitoes. Body chemistry differs from person to person and some of us smell more attractive to mosquitoes than others.  Don't assume that because you aren't noticing bites that mosquitoes are not active.
• Remember the 4 D’s 
•  DUSK/DAWN- Stay indoors at Dusk/Dawn. This is the time of day that mosquitoes are most active. 
• DEET-Use insect repellents that contain Deet when going outside, especially at times closer to dawn or dusk when mosquitoes are most active. 
• DRAIN - Remove all areas of standing water. Examples are pet dishes, birdbaths, and water dishes under potted plants. Repair faulty French drains. Remove debris from rain gutters. Mosquitoes will breed in this debris since it is normally damp under the debris. Remove all piles of dead leaf material from under trees and shrubs. This also is a breeding site. 
•  DRESS- Avoid being bitten by mosquitoes by wearing light colored long sleeved shirts and long pants when going outside. 

Additional Resources

• Check out the eXtension school IPM action plan for mosquitoes.  If you don't have a plan for mosquito control in your IPM notebook, this may be just for you.
• Need a poster, flyer, or other information to hand out to teachers, parents or students? including a sample letter you can send home to parents? Check out this link.
• The Department of State Health Services website on school resources
• Frequently Asked Questions about aerial spraying for mosquitoes can answer many concerns parents (and customers) have about community-wide mosquito spraying
• Mosquito Safari is an Extension website with general information about mosquito identification, biology and control, including an interactive tour of common mosquito breeding sites. 
• Four new videos on how to mosquito-proof your home

Thanks to Janet Hurley and the Texas School IPM program in assembling much of the information for this post.

A meeting for schools AND PMPs

Past TIPMAPS meetings have included presentations by
Regulatory officials such as then TDA Assistant
Commissioner of Pesticide Programs, Jimmy Bush.

This November will mark the fourth year that Texas school IPM coordinators have gotten together for their annual TIPMAPS (Texas IPM Affiliates for Public Schools) networking and educational conference on integrated pest management for school facilities.  If you want to talk with an enthusiastic group about IPM, this is the place to be.

A handful of PMPs have attended this meeting in the past, but the doors are open to much wider participation. TIPMAPS welcomes pest control contractors to attend and become members, and the meeting could be a great way to make contacts with new school districts as well as building stronger relations with the districts you are already servicing.  In addition, I guarantee that you will gain insight into how school IPM programs operate under the Texas school IPM rules and regulations. Associate membership for pest control professionals, manufacturers and other vendors is $100 per year.  Click here for an application.

The 2012 TIPMAPS meeting will be held November 14-15 in San Marcos, TX at the Embassy Suites.  Vendor booths are two for one this year ($500 for both the Facility Masters and TIPMAPS meetings), and regular registration for the two-day TIPMAPS meeting is $125. The facilities are top-notch, the speakers are engaging, and CEUs are offered; so if your business is involved in servicing Texas school districts, this may be one meeting to get on the calendar early.  Hotel rooms will be limited, so it's recommended to make your reservations early (by Oct 22 to get the group rate) by clicking on this special link, or when calling the hotel directly, by mentioning the group name TASBO/group code TAI (phone 512 805 5340).

To learn more about the conference go to http://www.tasbo.org/about-the-conference-mao-tfm To learn more about TIPMAPS, visit their website at http://tipmaps.org/

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.

The power of appreciation

What do you look for when you hire a new person for a pest control technician's position?  Experience with pest control?  Dependability?  Good driving record?  How about the ability to value other people?

I’m just an entomologist, not a psychologist; but even an entomologist can recognize the power of an appreciative word.  And as an integrated pest management (IPM) specialist, I’ve come to value people who can build a loyal IPM team. 

In its most basic form IPM is about people. This is true on all levels, but especially for IPM programs within large institutions that require the cooperation of many departments and individuals. If you look at dysfunctional IPM programs (yes, they exist) one of the first things you notice is a lack of appreciation for the jobs and accomplishments of others in the organization.  The best programs, on the other hand, have leaders who are able to value and recognize the contributions of others.

I was reminded of this yesterday sitting in on a simple ceremony in the staff kitchen of Memorial Elementary School in Plano, TX. David Lewis and Leo Largaespada, IPM Coordinator and IPM technician, respectively, for the Plano Independent School District (PISD), invited me to attend an appreciation lunch for one of their top kitchen teams in the district. The lunch was a simple affair, but illustrated powerfully a principle that often gets overlooked in our fancy ideas about what IPM is all about.

The most powerful words in IPM tool box may well be, “we appreciate you”. Take a look at the video below and see if you don't agree.

Living to see another day: School IPM in Texas

The Texas regular Legislative Session ended peacefully May 31--at least for school integrated pest management (IPM) programs.

The past few months have been filled with more than a little uncertainty about school IPM in Texas.  As I first reported in March, an initial bill was introduced by State Senator Florence Shapiro (R-Plano) that included  a short provision to repeal all school IPM laws and associated rules in Texas.  By late April, after appeals from environmental groups and some parents and school IPM coordinators, school IPM was shown to have its supporters. However, the situation was further complicated when two additional bills were introduced that mirrored school IPM repeal language from Senator Shapiro's bill.

Now that the dust has settled, it appears that all three bills that carried IPM repeals died quiet deaths. Senate Bills 3 and 468 (Shapiro) died in committee with school IPM repeal provisions, HB 3684 (Callegari) was dead in Calendars Committee after removing the school IPM repeal section, and SB. 1252 (Williams) was also left pending in committee with a school IPM repeal provision. 

According to a long tradition, Texas legislative sessions don't always go away quickly or without an extended session.  Governor Perry has called this week for a Special Session to deal with unfinished school finance and political redistricting issues. And as long as legislators are in Austin it's difficult to say with certainty what may or may not get included in the final legislative bill machine.  Nevertheless, most observers seem to think that school IPM repeal is dead for this session.

What did this legislative session teach me about school IPM?  For one thing it's taught me that no program is a sacred cow. All it takes is a determined person with an agenda to repeal or amend a law, regardless of its merits. 

Another thing I observed this session is the importance of having knowledgeable professionals willing to speak up for a program that is making a difference. I'm grateful for everyone who cared enough about childrens health to speak up for a IPM requirements that have reduced unnecessary pesticide use, helped educate and train school professionals about safer pest control practices, and increased the overall effectiveness of pest control programs around the state.  For all of the coordinators, parents, PMPs and environmentalists who spoke up for school IPM, thanks for being part of the process. You are the ones who make the system work.

Texas school IPM's fate still up in the air

I reported almost two months ago about a bill in the Texas Senate that would repeal our state's school IPM law and associated regulations. Since that time my colleague Janet Hurley and I have talked with many of you about the possible impacts of the repeal.  We also had the chance to travel to Austin and share information about school IPM with the Senate Finance committee.

There have been several legislative developments in the past few weeks.  First, the original Senate bill, SB 12 (changed from the original SB 468, then SB 3) has eliminated any reference to school IPM repeal. Concerns shared with the committee by a citizen and several environmental groups apparently persuaded the bill's sponsor to remove the school IPM repeal from the larger bill, which was written to reduce regulatory burdens on school districts.

Meanwhile, SB 1252 was introduced by Senator Tommy Williams (R-Woodlands).  This bill also called for repeal of school IPM (Texas Occupations Code Section 1951.212).  About the same time, an identical sister bill (HB 3684) was introduced into the Texas House by Representative Bill Callegari (R- Houston).  Both House and Senate Bills were identical in language and called for repeal of Texas's school IPM law.

The Texas Pest Management Association and several environmental organizations (and a number of school IPM coordinators) have contacted the bill's authors to request removal of the school IPM repeal (allowing school IPM regulations to remain as they are now).  They report that both Senator Williams and Representative Callegari have said that they intend to remove school IPM from their bills in response to public input.  However, school IPM language has not disappeared from the online copies of either SB 1252 or HB 3684.  According to David Oefinger, Executive Director of the Texas Pest Management Association, he believes that the repeal of school IPM in both bills will be dealt with as the bills' authors have promised.  However, he notes that "most anything can happen in the waning days of a Texas legislative session." 

The end of School IPM in Texas?

In case you haven't heard, a bill submitted to the Texas Senate earlier this month includes a provision that would eliminate all requirements for schools to follow IPM in our state.  Section 13 paragraph (2) of Senate Bill 468, introduced by Senator Florence Shapiro (R) of Plano, Texas, would repeal Section 1951.212 of the Occupations Code, the section of state law entitled "Integrated Pest Management Programs for School Districts".  The presumed intent of the bill is to reduce costs to Texas school districts in this time of very tight budgets.

In response to a number of inquiries we have had from schools and pest management professionals, I and colleagues have put together some facts concerning school IPM in Texas. We are not advocating for or against the provision of this bill that affects school IPM programs, though most readers of this blog will recognize my belief that the school IPM requirements have played an important role in moving our state's public schools toward a better form of pest control.

When discussing the bill with others, you may find the following information helpful in formulating talking points.  If you need more information, go to the school IPM website, http://schoolipm.tamu.edu. Detailed information about the Texas School IPM model can be found by clicking on the “More Information” button on the right hand side of the page. For specific information about successful IPM programs click on the “Awards and Recognition” button, also on the right hand side of the home page.

Economic Impacts of School IPM Laws

• There is no evidence that the school IPM law and its associated regulations cost school districts significantly more that what they would normally spend on adequate pest control. In a 2005 Texas AgriLife Extension survey of over 500 IPM Coordinators, 53% felt that the IPM requirements had actually reduced long-term costs of pest management. Fifteen percent believed there was no change in cost to the district. Only 18% of districts said that they felt the school IPM regulations had increased the long-term costs of pest control to their district.
• Increased costs in labor and training for IPM programs appear to be more than offset by long-term reductions in pest complaints, reduced costs of chemicals, and reduced costs for transportation (responding to pest complaints), etc.
• Additional school district savings, associated with other IPM programs and likely to be true for Texas schools as well, include reduced liability for pest and pesticide complaints, and healthier work environments resulting in reduced student absences and teacher sick days.
• There is evidence that many schools are finding substantial cost savings with the switch to IPM. Keller ISD, for example, reduced its costs for contractual pest control from $94,000 to $18,000 between 2008 and 2010, due to better management and bringing some services in-house. 
• A 2005 study conducted in nine North Carolina elementary schools compared conventional pest control to IPM for German cockroach control. Conventional pest control cost $16.92 per service at the beginning of the study and decreased to a stable $7.50 in the final months; compared to IPM service which intially cost $12.63 per service and declined to $6.20 per service (Williams, Linker, Waldvogel, Leidy, & Schal 2005).

Health and Safety Impacts Associated with IPM

• According to the Centers for Disease Control and Prevention, asthma is a leading cause of school absence in the U.S. – more than 12 million asthma-related absences per year. Not only is IPM implementation more effective at controlling pests that conventional pest management practices but it can also lead to long-term health benefits, such as reduced exposure to rodent and cockroach allergens, important asthma triggers. For this reason, the U.S. EPA considers IPM to be an important component of its Tools for Schools program advocating for better indoor air quality for schools. 
• The IPM law has resulted in a shift from more- to less-toxic pesticide use in Texas schools. A 1994 Texas A&M University study showed that the two most consistently used insecticides for indoor and outdoor pests in schools at the time were diazinon and Dursban, two broad-spectrum, residual insecticides that were associated with numerous public complaints. In the 2005 Texas AgriLife Extension Service statewide survey conducted ten years after enactment of the school IPM law, insect baits, followed by insect growth regulators and low-toxicity inorganic insecticides such as boric acid (all preferred products under state regulations) were the most commonly used products. This significant shift away from conventional insecticides has not been seen in school districts from other states.
• The school IPM law requires good record-keeping from all school districts. This has resulted in better accountability and provides a way to track improvements in pesticide stewardship not commonly seen in schools in other states.
• In a Maryland study, the Montgomery County Public School System reduced pesticide applications from  5,000 to 600 per year within three years of implementing IPM. Similar reductions have been reported in Texas since implementation of school IPM regulations.

Quality of Pest Control

• Texas schools have indicated greater satisfaction with their pest control programs, both in-house and contracted, since implementation of the school IPM law. According to the 2005 Texas AgriLife Extension Service study, schools were 75% more likely to be satisfied with their pest control program compared to 1993, before the law went into effect. In addition, the study found that 75% of school IPM coordinators believe that the state IPM requirements have resulted in more effective pest management in their districts.
• Similar conclusions were found in a 2001 survey of 292 school districts by the then Structural Pest Control Board. In this survey, a substantial majority of schools felt that IPM had resulted in pest control equal to or better than pest control services before the IPM requirements went into effect.
• Research consistently shows that whenever IPM is implemented in the urban environment it tends to result in better pest control, generally with the use of less hazardous pesticides and less contaminating application methods. There is now nearly universal agreement among regulatory officials, academics, facilities managers, architects and pest management professionals that IPM represents the best available management approach for dealing with pests. 

Other considerations

• Texas’ law and regulations strike a balance between encouraging use of less hazardous products and methods, and allowing schools the freedom to do what they need to manage pests. Under current rules, Texas schools can use any pesticide they deem necessary.
• Many school IPM coordinators report receiving greater support for their programs from district administrators because of this law. 
• Some school district superintendents may be under the mistaken impression that repeal of the school IPM law will save the district money for the training and licensing of school district employees to apply pesticides. However, eliminating Section 1951.212 will not eliminate the need for use of licensed applicators to apply pesticides in schools. For safety purposes all pesticide applications made to restaurants or other food processing establishments, apartments, day-care centers, hospitals, hotels, warehouses, government buildings and schools must be made by licensed individuals (Occupations Code Section 1951.051).
• Requiring school IPM coordinators to be trained has resulted in schools being better-educated consumers of pest control services. Many districts demand better service, switching to higher quality service providers or bring pest control services in-house at reduced expense. Nationally the trend is for states to require more, not less, training for school pest management personnel.
  

To learn more about what you can do about this bill, contact your local professional association.  The Texas Pest Control Association, Texas Association of School Boards, or the Texas IPM Affiliates for Public Schools are each developing position statements on SB 468.  This is a vitally important issue that needs the attention of anyone involved in school health and IPM-related professions today. 

Bed bugs go to school

Treating school classrooms for bed bugs should be
a last resort, and only if the pests are known to be present.

A recent incident in a New Jersey public school made headlines, and got me thinking about right and wrong ways to deal with bed bugs in schools.  In the story, two bedbugs were found on the book bag of a student on a school bus, resulting in an immediate inspection of the school and "fumigation" of the bus.

Without actually detecting bed bugs in the classroom, the story says that a "specialized exterminator" (I wish we could lose that name) was called in to treat the surfaces where bed bugs could take refuge in the affected class. Later, a bed bug sniffing dog was called in to clear the classroom. Similar incidents with similar aggressive responses are being reported throughout the country.

If you read the story you can see the incident from the perspective of a school superintendent. The superintendent wants to be able to get up in front of the media and confidently say, “We’ve taken care of the problem.” To this superintendent, this meant that they had involved the highest authority to affirm that the school viewed the problem seriously (State Board of Health—who likely didn't really want to get involved) and gotten professionals to identify the pest and deal with it quickly (by “fumigation”).

This may be good PR, but it's not the ideal IPM response. Eventually schools, I think, will find this sort of approach unsustainable. This will occur when bed bugs start showing up more routinely in schools. State Boards of Health will no longer accept calls about bed bugs, the maintenance department’s pest control budget will become strained from all the extra, premium-priced service calls, teachers will get tired of having their classrooms “sealed off” unnecessarily, and those dogs will get doggone'd expensive. And inevitably, parents will soon begin to worry about their kids' exposure to pesticides.

The main problem with the approach reported in story is that some schools are over-reacting to what will certainly become a relatively routine pest problem. Schools want a guarantee that they are bed bug-free, something that is very difficult in real life.  Professionals know that if they really treated every surface where bed bugs could hide, it would require a major investment of labor and time (one I hope you would be charging for). Such efforts would certainly not be warranted without first determining that there was an actual infestation.

By the way, this brings up our use of the terms infested and infestation. I think it’s better, when it comes to bed bugs, if we reserve use of these terms to situations where bed bugs have settled in and are reproducing as a result of a consistent and available nighttime food supply—something that will probably not be very common in the average public school. I recommend that we start referring to isolated bed bug sightings as detections, not infestations.

We aren’t told what “fumigation” referred to in this story, though it was certainly not a real fumigation job involving fumigant gases. At its most harmless level, the treatment was likely an application of a non-residual, contact insecticides to cracks and crevices around the backpack areas and the student's desk. It might have been an aerosol ULV application to the bus (not very effective against bed bugs in good harborage). At it's worst, the treatment may have been haphazard spot treatments with residual pyrethroids, which could easily result in contamination of surfaces where kids might have contact.  None of these treatments, as they are commonly applied, provide an absolute guarantee of no more bed bugs. 

A school district in Texas recently went through a similar incident in several of its classrooms. The response of this district, well trained in IPM, was to do a visual inspection of the room, alert the parents of the child, and have their pest management contractor put out two carbon dioxide bed bug monitors over the weekend to confirm that bed bugs were not present. Monitoring, not pesticide application, is probably the best first response to reports of “hitchhiking” bed bugs on a school backpack.

This same school district has determined that in cases where the children are likely to continue to come to school with bed bugs, their backpacks will be zip-loc™ bagged during the day as a precaution. This district recently held a district-wide training for its school nurses about bed bugs, and also sends informational letters out to parents in classrooms where bed bugs have been detected.

We're still learning about the best ways to deal with bed bugs in schools, and doubtless we will come up with better protocols. In the meantime, we should avoid over-reacting to what will become an increasingly routine problem.  And this means educating superintendents and school principals about the facts of life when it comes to bed bugs.

North Carolina study shows health benefits of IPM in schools

Just a short note about this story by Rosemary Hallberg at the Southern IPM Center.  I don't always have time to blog about all these great stories, so it's nice when someone else does the job for me.  Check out her article at http://ipmsouth.com/2010/03/05/study-shows-ipm-reduces-cockroach-allergens-in-schools/

Benny Mathis

I would be remiss if I didn't pass on the sad news of Benny Mathis' passing this month. The facts are that Benny Mathis, 63, former executive director of the Texas Structural Pest Control Board, died on Dec. 15, after a short battle with cancer.

As reported by PCT Media Group, "Mathis had been involved in the pest control industry since 1968. As Executive Director of the Texas Structural Pest Control Board, Mathis administered the laws and regulations governing pest control operators. Mathis worked diligently on implementing the Texas School IPM program. His active role on the penalty policy, legislative support, speaker of continuing education in major meetings with Texas Pest Control association, Texas A&M and Texas Tech left a major impact on the industry."

What's not reported is the kind of person Benny was. I have seldom seen a regulator afforded as much respect and friendship by people in the industry. He seemed to have a way of making people on both sides of an issue feel listened-to and important. Personally I had a lot of respect for Benny because of the way he embraced school IPM regulations back in the early 1990s. School IPM laws were the classic unfunded mandate, a burden on Benny's agency. The state in essence said, "We're giving you this incredibly challenging new law to enforce, and we want you to do it with your underpaid, overworked staff. See ya."

A lot of bureaucrats would have found a way to do the minimum, skirt the intent of the rules to ensure minimal disruption of the status quo. But Benny worked hard to make sure that regulations were in line with the intent to change how pest control was done in schools, and backed up his commitment with enforcement (even fines!) of school districts that did not play according to the rules. In my opinion, Benny is one of the reasons Texas has a strong school IPM program today.

Countdown to School IPM Conference

I just have to brag on the new Texas group, Texas Integrated Pest Management Affiliates for Public Schools (TIPMAPS). The group is so new it doesn't have a web page yet, but this hasn't kept these folks from getting over 10% of the school districts in the state to register for a first-of-its-kind conference on IPM, to be held at the Embassy Suites in San Marcos, TX on November 18 and 19.

As the newest affiliate chapter of the Texas Association of School Business Officials (TASBO), TIPMAPS is a fledgling group. The conference is their first open event and will focus on a variety of pest management issues facing school IPM coordinators. The concept of an association for school maintenance officials with pest control duties is novel and sets the bar for other states wanting to see IPM take root in their public school districts.

I've just been looking through the list of badges for the meeting and I count 107 different public school districts represented among the approximately 180 early registrants. This represents more than 10% of the approximately 1030 school districts in the second largest state public school system in the nation.

Speakers for the meeting will include some of the state's own school IPM coordinators, along with speakers from industry and the Extension Service. The highlighted speaker for the conference is Dr. Bobby Corrigan, or Dr. Rat, as he's known in New York City where he oversees one of the largest rodent IPM programs in the world.

The last day of the conference will include an organizational meeting to discuss membership dues and formation of regional chapters. Online registration is now closed, but it's not to late to attend. On-site registration will be available for $100. To see a schedule and map to the conference hotel in San Marcos, go to the Texas AgriLife Conference Service website.

New Rules for Schools

The new proposed rules that will govern how Texas schools conduct their pest management programs were published today in the Texas Register. The rules can be found online at http://www.sos.state.tx.us/texreg/sos/PROPOSED/4.AGRICULTURE.html#95

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.

I am proud of the way Texas schools and PMPs got involved in the rule making process over the past 12 months. I think the end result is that our school IPM regulations are more reasonable and ensure that pests and pesticides are one less worry for people concerned with the safety of our kids. And what's good for our kids is good for all of us.

Advisory Committee Spells out IPM for Texas Schools

Two weeks ago, on January 29th, I had the privilege of serving on the Structural Pest Control Advisory Committee meeting to discuss changes to Texas pesticide regulations. This was our third meeting since the committee formed last year, and school IPM was the principal topic on the agenda.

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.

In my opinion, if we can bring schools into compliance with this rough definition of IPM (and I think we've come a long way already), Texas schools can become a model of good institutional pest management for all school districts and even for PMPs around the country. I especially like the fact that Texas recognizes the importance of good recordkeeping and education as part of an effective IPM program.

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.

Bed bugs pose threat to schools?

Some school districts are beginning to worry about bed bugs. About a year ago the Bracken County School District in Kentucky closed their doors for a day to make sure no stray bed bugs were left behind following a find of a single bed bug in classroom. The bug was supposed to have come from a student whose home had bed bugs.

This week the Columbus Dispatch, in Ohio, reports another panic over bed bugs in school classrooms. According to the article, "Researchers and public-health officials fear that tiny, brown, blood-sucking bedbugs are going to spread through schools."

Greg Kesterman, director of the environmental health division for Hamilton County Public Health (Cincinnati, OH, where bed bug problems are growing quickly) is quoted in this week's story as saying, "Anytime an insect has the potential to crawl on a person, and travel with (people), you're guaranteed that you'll see them showing up in a public facility." This is certainly true. Bed bugs have, and will, show up in schools from time to time, especially as infestations in homes become more common.

What I question is the followup worry that steps need to be taken to avoid a "large scale problem" in schools. Are bed bugs really another problem that schools need to be highly concerned about? I doubt it.

While you never want to underestimate nature's ability to cause mischief, the threat of bed bug infestations in schools should be minimal. Bed bugs are principally active in the dark (except in cases of heavy infestations--which would not be the case with the occasional, stealth introduction to a classroom). After dark they need a reliable source of blood to sustain a population and spread. Since people generally do not sleep in classrooms (with possible exception of short afternoon nap times in pre-school rooms), it would be tough going for a bed bug that slipped out of a backpack into a typical classroom from an infested home.

In my estimation there is little risk of actual bed bug infestations requiring treatment in a public school classrooms or auditoriums. Dorms are another issue of course. Also, the risk of one or two bed bugs emerging from of a child's backpack and infesting other kid's belonging is conceivable, but the risk is also probably low. Should PMPs, school nurses and school pest management staff know what a bed bug looks like, and something about its biology and behavior? Sure. Should schools fear they are going to spread through schools and cause a citizen panic? No way.

Cockroaches are far more likely to migrate from a child's backpack and find "Southern Living" in a classroom. And backpack smuggling of cockroaches is at best a minor or occasional source of cockroach infestations in school classrooms.

Concerns about the new school IPM rules

Austin, TX. Today the Texas Department of Agriculture meets to hold public hearings concerning the new rules that will guide the Structural Pest Control Service's regulatory activities for the future. The biggest proposed changes deal with rules governing the way pesticides are regulated in public schools.

Texas has one of the longest-standing and most comprehensive set of laws and regulations governing pesticides and integrated pest management (IPM) in schools in the nation. In the course of the past 13 years that the rules have been in effect, schools in Texas have significantly changed the way they do pest control. A study our office completed in 2007 details some of the shifts. For example, in 1994 the two most common insecticides used by nearly all school districts were diazinon and chlorpyrifos (Dursban®). Today, the most commonly used pesticides include a variety of baits, insect growth regulators and lower toxicity insecticides. Granted, diazinon and Dursban® are no longer registered for use in buildings, but their replacements--the commonly used pyrethroid insecticides--are used frequently by only 13% of school districts. This represents an enormous shift for an industry that has often been slow to change.

Certainly, part of the success of the school IPM rules is due to the way the rules gently encourage the use of less toxic pesticides. Under the system, pesticides are categorized into Green, Yellow, or Red based on a variety of criteria that include signal words, acute toxicity and the likelihood of hazardous exposure. For schools, any green category pesticide can be used at the discretion of the pest control technician. Yellow and Red category pesticides require written justification and approval by either the certified applicator or the school district's IPM coordinator.

By making it a little more difficult to use the more toxic products, while keeping all potential pesticides that might be useful to schools still available, Texas has managed over the past thirteen years to successfully balance opposing interests. Those who were most concerned about children's exposure to hazardous substances have been satisfied, while maintenance and pest management professionals have been left with the freedom to use any pesticide product they determine is necessary to control pests in schools.

As evidence of the success of this system, today one can find virtually no environmental group criticizing pesticide use in Texas schools. Fifteen years ago anti-pesticide lobbyists were a common site in public sessions of the Texas Structural Pest Control Board, protesting the use of a variety of pesticides in schools. Today it is hard to interest community activists (in Texas anyway) in school pest management issues, because there have been so few problems in our schools. By this and other measures, the rules have been a success.

Unfortunately, the new rules threaten to upset this balance in several important ways. Specifically, the TDA is proposing to tighten certain requirements and eliminate some pesticides from the green category. For example, pyrethrins and insect growth regulators will no longer be included in the green category.

Pyrethrins are organically derived compounds that are very commonly used during inspections as a tool to flush insect pests out of hidden harborages. They are also used to provide fast knockdown of a variety of pests including cockroaches, ants, bees, wasps, flies and stored product pests. Their toxicity is in the low range for humans (LD50 values above 1500 mg/KG) and they break down very quickly, making them widely used in restaurants and food manufacturing plants.

Similarly, insect growth regulators are low toxicity (commonly used IGRs have LD50 values greater than 2000 mg/kg) products with a variety of useful applications. They are among the few low-toxicity sprays for long-term population reduction of cockroaches in kitchens, and they provide some of the lowest toxicity control options for fleas, fire ants and mosquitoes. Over 21% of all schools in our study used IGRs on a regular basis.

In addition to restricting the use of these former green category pesticides, the TDA proposes to restrict entry of all non-pesticide applicators into all treated areas for 6 hours after an application is made. What's new here is not that students are required to stay out of treated areas, but also employees of the school. To keep non-authorized personnel out of treated areas, the areas will need to be monitored or secured by fence or lock and posted for six hours.
This requirement goes far beyond EPA standards for re-entry into treated areas (usually until sprays have dried), and will make it significantly more difficult and expensive for schools to treat sports fields, grounds, kitchens and hallways for pest problems.

There ought to be a reason for adding regulations to an already-heavily regulated industry. In this case there appears to be no smoking gun, no pattern of complaints, no illness reports, just a regulatory agency that wants to add rules that no one in the community is asking for.

Before TDA can formally establish and begin enforcing these rules, the state requires the agency to publish them for public comment for 30 days, ending August 3. If you have an opinion on these matters, you will never have as much opportunity to influence the shape of these rules as you do right now. For more information about the rule changes and how to respond, see my July 16th post.