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. 

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. 

Car Talk radio show tackles wildlife topic

Kieran Lindsey, former Texas A&M University wildlife major,
and now Virginia Tech professor, tackles the subject of
wildlife and automobile maintenance.

Any of you who find yourself out driving around on a Saturday morning, and have happened to tune into an National Public Radio station, have probably heard the show Car Talk. Who would have guessed that two goofy brothers answering car maintenance questions on the radio would have been successful? I wouldn't. Yet they've become an enormous hit with a syndicated newspaper column and with NPR listeners with cars over a certain age.

The Car Talk brothers usually make me laugh. So I was pleasantly surprised a few months ago when I got a call from someone purportedly working for the show, and who needed some advice about pest problems in cars. It turns out that my caller was Dr. Kieran Lindsey, a Texas A&M grad who now works at Virginia Tech and who is moonlighting her wildlife biology skills and knowledge as the "wildlife expert" for Car Talk. An article about Kieran and her new gig just appeared in AgriLife Today.

I'm proud to report that a couple of the issues we discussed are now part of Kieran's Car Talk webpage called Wildlife and Your Car. So for all the times you wake up in the middle of the night in a panic, worrying about spiders or bed bugs in your car, you now have a place to go online. I know I'll sleep easier knowing that Car Talk has all the answers about what to do should be car is invaded by snakes, rats, goats and cats. Oh, and don't forget the perennial worry about what will happen to your dog in the front seat should your airbag deploy.

Given the current state of the Texas budget and the economy, Dr. Lindsey gives me great hope. If a wildlife biologist can get a gig advising people how to keep wildlife out of their cars, perhaps there's a place for an unemployed Ph.D. entomologist in the new economy.

New EPA pesticide sales report available

It's been several years since EPA issued one of its reports on annual pesticide sales and use.  I find these statistics interesting, if for nothing more than quoting in general talks on pesticides or for literature reviews preliminary to asking someone for money.  So I am glad to see that budget cutbacks haven't completely eliminated this service, and we have some more recent figures to study (2006-2007). 

If you had to guess what pesticide was used more than any other by the Government/Industry/Commercial sector, what would you guess?  The answer, according to this report is the herbicide 2,4-D, followed by the popular glyphosate, or Roundup®.  Insecticides barely make the top ten list, with malathion and sulfuryl flouride (Vikane®) coming in at positions 9 and 10, respectively.

The report illustrates the dramatic decline in organophosphate use, as well as the overall decline in pounds of insecticide used by the commercial/governmental sector.  Interestingly, the overall amount of pesticides used in the home and garden sector has been pretty steady over the past 20 years. 

The value of the pesticide market in the U.S. for 2007 was $12.5 billion.  Within the commercial/governmental/industry sector (which you belong to) the pesticide market was worth $1.9 billion, and the insecticide market by itself, $709 million.

To read the entire report, click here http://www.epa.gov/opp00001/pestsales/

PBO in the news

A recent study in the March issue of the journal Pediatrics [vol. 127(3): e693-e700] reports on a correlation between pre-natal exposure to the common synergist piperonyl butoxide (PBO) and delayed mental development among 3 year-old children.  In a review of the article, e! Science News reported the author as saying that the drop in IQ points [among children whose mothers had higher PBO exposure] is similar to that observed in response to lead exposure.  Megan Horton, of the Mailman School of Public Health and lead researcher, said the drop, while not severe enough to affect a child's overall function "...is  educationally meaningful..."  Going a little further out on a limb, she added that it "...could shift the distribution of children in the society who would be in need of early intervention services".

The results of this study should be considered preliminary, and certainly indicate the need for more research.  Similar to the study on ADHD that I reported on last year, the data shows a correlation, but does not indicate a cause and effect relationship.  Further studies may or may not substantiate the correlation.  Furthermore, the authors note that this is the first study to ever look at the health effects of PBO on humans (previous studies, presumably having been done only on laboratory animals).

The paper brings up an interesting issue with regard to the pest control industry.  What criteria should we use to make decisions about the kinds of pesticides we use in our business?  Should a new study impact the way we use chemicals?  Or should we always just follow the lead of the EPA when it permits or restricts use of a pesticide? 

Ultimately, and from a legal point of view, the EPA is our guide.  The EPA has hundreds of toxicologists trained to look at studies such as these and determine whether there is enough data to justify a change in label requirements.  However, the process of revoking a use, or a pesticide, can take years. 

The biggest question I had about this study concerned the mothers' exposure to PBO.  Piperonyl butoxide in itself is not toxic to insects.  Rather, it is added to a few insecticides--most notably pyrethrins--to prevent insects from detoxifying the actual insecticide.  It turns out that pyrethrins, by themselves, are great at quickly knocking down, but not killing, most insects.  Adding PBO to pyrethrins merely keeps insects down for the count. 

Most pyrethrins formulations, including a number of over the counter (OTC) consumer products, contain PBO in low concentrations--usually less than 5%.  In recent years, however, some professional products have included higher percentages of PBO (e.g., 60%).  I've never fully understood the reason for the popularity of this mixture, given that PBO is non-insecticidal and that only small amounts of it are needed to synergize pyrethrins.  From what I can gather informally, PBO mixtures are being used increasingly by frustrated PMPs for bed bugs.  But I've always been under the impression that only a small percentage of residential pesticide applications by professionals used PBO.  It was surprising to me therefore to read that PBO was detected in 75% of personal air samples collected in the study. 

The study assumes PBO was used as a synergist with permethrin; however, permethrin is not normally sold with PBO.  Unless a lot of New York PMPs are using this combination (perhaps in bed bug applications?) I am skeptical that this use pattern is common throughout the country.  It's also possible that the PBO is coming from use of OTC products by the householders themselves.  Or there might be some non-pest control source of PBO.  In any case, it seems like one of the first regulatory steps would be to find out where PBO exposure is coming from. [Any insights in this regard from readers would be welcome!]

In the meantime, in my opinion it would be prudent to consider limiting use of products with high percentages of PBO in accounts with pregnant women or infants.  I'm not convinced yet that PBO is posing a health risk to the unborn or very young; but in most cases there are good alternatives. Our industry should be placing highest value on customer safety, so why don't we take a proactive lead on this one?

Entomological Society posts bed bug info

While most of us were waking up to snow and ice earlier this month, a number of researchers and government officials trekked to Washington, DC for the second National Bed Bug Summit. Unfortunately, this was a meeting I had to miss; but the good news is that the presentations have been made available through the Entomological Society of America's (ESA's) new urban entomology network site.  

If you are interested in reviewing some of the PowerPoint presentations from the Summit, click on the following link: http://esanetworks.org/group/urbanandstructuralentomologists/forum/topic/show?id=6295836%3ATopic%3A2808&xg_source=msg

The links provided are merely Acrobat (pdf) copies of presentations made at the meeting, but you can get an idea of the flavor of the event by scanning the slides.  There is no narration, so you don't get the full content of the presentations, but there is still considerable information in the slides.  Also, you might want to contact the speaker directly if you have a specific question about a presentation. This method is sure a lot easier than negotiating long lines at airports during blizzard season.

An open letter to PETA

One of our Texas school districts recently received the following letter:

Dear Superintendent ___:

I am a director with PETA’s Cruelty Investigations Department. I hope this email finds you well. Thank you for speaking with my cruelty caseworker... regarding the use of glue traps by the ___ Independent School District. As he mentioned, the Centers for Disease Control (CDC) warn against glue trap usage due to the disease risks they pose. Glue traps are also exceptionally cruel. If lethal methods are insisted upon, the D-Con Ultra Set Covered Mouse/Rat Traps http://www.d-conproducts.com/traps/ultra-set.html  and Victor Electronic traps http://www.victorpest.com/store/rodent-control/electronic-mouse-trap are cost-effective, easily obtained, sanitary, and far less cruel.

May we hear from you that the ___ Independent School District has joined the countless businesses, corporations, and school districts that have sworn off using cruel glue traps? 

Now glue boards, by themselves, are not my favorite way to control rodents.  As commonly deployed, they do not typically kill the animal quickly, they need checking regularly and they may not leave a good impression on a customer who discovers a captured rodent on a glue board still alive.

I have less sympathy, however, with the argument that killing rats and mice is unethical.  When house mice, roof and Norway rats invade a home, school or business, there's no question in my mind who has to go.  It is more unethical, in my opinion, to release these pests (that prefer and are drawn to human habitations) back into the environment where they are likely to become another person's problem.

For these reasons, I have drafted a response to the PETA (People for the Ethical Treatment of Animals) letter and offer it here for your consideration and use, if you think it might be helpful for your district or business.

Dear PETA:

Thank you for your concern about the ethical treatment of animals.  Most of the people I know share many of your concerns and have no desire to cause unnecessary pain or suffering of any animal, including those that we consider pests.  Nevertheless, we may have a fundamental difference of opinion about the necessity to kill and eliminate rodents from human living environments.

Live rodents have serious aesthetic, economic, and health impacts on schools.  Any rodent activity in our facilities is considered highly unacceptable by our staff and our community.  Rodents damage school property via their chewing activity--which also puts schools at increased risk of fire (due to shorts caused by damage to electrical wiring).  Perhaps most importantly, rodents contaminate classrooms, offices, food and food preparation surfaces with their feces and urine. Rodents are implicated in the transmission of over 55 human disease pathogens. A single house mouse produces 50 to 75 droppings and over 3,000 micro-droplets of urine daily. These potentially bacteria- and virus-contaminated feces and urine droplets are dispersed wherever the mouse travels in a classroom, office or kitchen area. 

Regarding tactics, our district's main emphasis in on preventing rodent infestations.  The highest priority of our rodent control program consists of sealing potential rodent entry points into buildings, and eliminating conditions that are attractive to rodents (clutter, poor sanitation around dumpsters, food spillage, etc.).

Unfortunately, experience has shown that despite our best efforts, some buildings and grounds will become rodent infested.  When this occurs we look for the most effective, economical and humane methods for control. Some of these tactics include snap and multiple catch traps, solid and liquid baits, tracking powders, glue boards and glue trays.  It's important to note that none of these tactics by themselves provide complete control of rodents.  For this reason we use an integrated approach.

Our district's pest management program is based on a strategy known as integrated pest management (IPM).  The IPM concept recognizes the limitations of single tactic approaches to pest control, and tries to make use of simultaneous, multiple control tactics.  Glue boards and glue trays are not the principal method used by our district to control rodents.  Glue traps tend to be less effective for house mice than snap traps, and rats are more difficult to catch and contain on these devices.  Nevertheless, glue traps have useful applications.  For example, glue boards may be the most effective choice in tight quarters where snap traps cannot fit.  They are also useful in combination with multiple catch traps, where they facilitate cleaning and rodent removal.  In addition, glue boards help contain biohazards such as the carcasses themselves, feces and ectoparasites (e.g., fleas and mites) carried by many rodents. 


When glue boards are used, our staff makes every effort to check them frequently. Any live animals found trapped in glue are killed quickly and humanely. Glue boards are only deployed and monitored by licensed professionals on our staff or by licensed contractors. We presume that the CDC recommendations you refer to are the ones directed to homeowners who do not have the same level of training and professionalism as our staff. Our staff are trained to place and service traps in a manner that minimizes the risk of disease transmission (use of gloves, putting glue boards inside bait stations and inside multiple-catch traps, etc.). 

Thank you for your suggestion concerning electronic traps.  These traps have great potential for rodent control programs--especially for mice. They can certainly supplement, but not replace all other lethal methods in an IPM program.  It is also important to understand that electrocuting traps do not guarantee immediate kill for rats.  In addition such traps are up to 60 times (rats) and 150 times (mice) more expensive than snap or suffocation traps, according to one evaluation. Nevertheless, some of our colleagues find that electrocuting traps with wireless alert capabilities can be worth the higher cost by eliminating the need of labor expenses for repeated visits to check empty traps. We will continue to evaluate the use of these traps, as we do for all control options.

We believe that our efforts in preventing rodent problems first, and correcting infestations quickly, is the most humane approach to rodent control.  We will continue to search for and evaluate better methods to do this, and welcome any additional ideas or suggestions you might be able to provide.

If your district or pest control business is not currently using the IPM approach to managing rodent control, if it is not emphasizing prevention, and if it is not checking glue boards and multiple catch traps frequently, perhaps it's time to make some changes.  But don't doubt for a moment that when you trap and eliminate rodents you are providing a useful service to your community.  To do anything less would be cruel indeed.