School Integrated Pest Management & Neighbor Notification
Introduction
There exists a need for a significant reduction in pesticide use in schools. Pesticide applications always have the potential to contaminate the school or work environment and expose staff and students to pesticide residues. The development and implementation of an integrated pest management (IPM) program is the key in achieving pesticide use reduction, while providing effective and economical pest control. The Board of Regents amended Part 155 of the Regulations of the Commissioner of Education and now require the establishment of a least-toxic approach to IPM (§155.4(d)(2)).
IPM is a common sense and economical process that consists of seven basic elements:
- Pest Identification - the current and/or potential presence of specific pests needs to be determined.
- Preventative Actions - structural repairs and maintenance, such as the installation or patching of screens and simple tasks, properly disposing of one's own trash, and removing food items from desks and lockers.
- Establish Tolerance and Action Threshold - a determination that prescribes pest-specific tolerance levels in specific locations throughout the facility above which responsive actions will be taken.
- Monitoring -sticky traps and visual monitoring provide vital information regarding the presence of any pests.
- Response Actions - this includes the use of mechanical, biological, and physical treatments and, as a last resort, least toxic pest specific pesticides.
- Public Notification and Education - a written notification to all parents, guardians, and staff explaining the program and offering them the opportunity to receive detailed information on the IPM program. This includes 48-hour advance notification of any pending pesticide applications required by the Neighbor Notification Law. The entire school community must understand what IPM is, its goals, and why everyone has a role to play in the IPM's effectiveness.
- Recordkeeping - detailed records documenting all aspects of the IPM program must be maintained.
Pesticides should only be considered as a last resort when other methods have proven unsuccessful. Even then, only least toxic and pest-specific pesticides should be used. Any public or nonpublic elementary or secondary school that decides to use a pesticide product as a last resort in addressing a pest problem, must comply with the Neighbor Notification Law (section 409-h of the Education Law) -see page 10 of this guide.
This guideline will provide information and guidance regarding the implementation of a school IPM program, as well as the elementary and secondary school requirements of the Neighbor Notification Law.
What is IPM?
IPM is a process for managing, preventing, and suppressing pests with minimal impact on human health, the environment, and nontarget organisms. IPM incorporates all reasonable measures by properly identifying, monitoring, and controlling pests through the use of cultural, physical, biological, and chemical control methods to reduce pests to acceptable levels. Pesticides must only be used as a last resort, and if pesticides are needed, the least toxic pest specific alternative must always be selected.
IPM is cost-effective and economical. The money that may have previously been designated for employing chemical control methods may now be redirected to other school activities. Public confidence and trust is still another added benefit to an IPM program.
Preventing a pest problem begins with the identification of the pest, determining its source and origin, monitoring its presence, and assessing the risk posed by its presence. Pests include bees, wasps, beetles, ants, flies, as well as rats, mice, or birds. Pests also include weeds, fungus, and microorganisms. All pest populations depend on a suitable habitat, including moisture, food, and shelter. Therefore, IPM's goal is to create an inhospitable and an unfavorable environment for pests by removing their food and shelter, and by restricting their access into building structures. Good housekeeping is the cornerstone for this process. Additional steps include, but are not limited to, promptly removing trash, trimming weeds and grass near structures, sealing and caulking cracks, repairing leaks, installing and/or repairing screens, and regularly vacuuming the facility using a HEPA (high efficiency particulate air) filter system.
A pesticide is a poison specifically created to kill a living organism. Consequently, as previously stated, pesticide products should only be used as a last resort in addressing a pest problem. If a pesticide product is going to be used to control a specific pest problem, the cautious and conservative use of a least toxic and pest-specific pesticide may be employed. IPM must not include any automatic or regularly scheduled pesticide applications. According to the New York State Department of Environmental Conservation/Cornell University IPM Workbook for New York State Schools "pesticides are designed specifically to interfere with life processes; this fact alone is good reason to treat them with respect, and to minimize their use." Since pesticides are designed to poison and kill living organisms, there always exists a possibility that pesticides may affect building occupants.
Pesticide applications may only be performed by individuals currently certified by the DEC as pesticide applicators or by a certified pesticide technician or an apprentice working under the direct on-site supervision of a certified applicator pursuant to DEC Regulation Part 325.7. It is illegal for individuals other than those noted above to apply any pesticide products in a school building or on school grounds. If a school determines that pesticides should be applied, the State Education Department strongly recommends that schools only employ mature individuals who are at least twenty-one years old and are certified by the DEC as a pesticide applicator to apply pesticide products in schools and on school grounds. In addition, the 48-hour advance notification requirements of the Pesticide Neighbor Notification Law must be followed - see page 10 of this guide.
The following key components of an IPM program will be described in this guidance document:
- pest identification
- preventative actions
- establishment of tolerance threshold levels
- monitoring
- response actions
- public notification, education, and the Pesticide Neighbor Notification Law
- recordkeeping.
Pest Identification
It is important to accurately identify any pests which are present, or which might occur at levels of concern. Knowing what pests might cause problems, will influence the course of the IPM program. Proper identification results from a combination of observation, monitoring, and research. This may include noting specific characteristics of rodent droppings; gnaw marks, sightings of pests such as bees or roaches; or the identification of wood or other structural damage.
Pests cannot be properly managed without being familiar with the pest's life cycle, habitat, and natural enemies. Knowing where specific pests live and what they eat, will be the key to eliminating their habitat. For example, cockroaches need access to water and dark places. Equipped with this knowledge, a school may choose to repair water leaks, caulk cracks and crevices, and eliminate clutter to prevent cockroaches from becoming a problem. Flies are attracted to odors. Therefore, by controlling wastes and odors, flies may also be controlled. Simple acts such as frequent garbage disposal and ensuring that refuse cans and dumpsters are securely sealed may significantly reduce the presence of flies and other pests.
Preventative Actions
Structural repairs and maintenance are key preventative actions or cultural controls in IPM. These simple, inexpensive, and often common sense steps will serve as the backbone to the IPM program. According to the Environmental Protection Agency's (EPA) Pest Control in the School Environment: Adopting Integrated Pest Management, the following are examples of these activities:
- Keep doors shut properly when not in use.
- Place weather stripping on doors.
- Caulk and seal openings in walls, cracks, and crevices.
- Install or repair screens on windows, vents, floordrains, and louvers.
- Routinely clean floor drains and grates.
- Fix dripping faucets.
- Sweep and mop floors daily.
- Empty trash baskets daily.
- Vacuum carpeted areas daily using a high efficiency particulate air (HEPA) vacuum system.
- Keep vegetation, shrubs, and wood mulch at least one foot from structures.
- Remove tree stumps and wood debris.
Additional housekeeping and sanitation IPM techniques include:
- Power-wash areas with accumulated debris, such as floor drains, loading docks, dumpsters, and food carts.
- Regularly clean grease from ovens, exhaust vents, and grease traps.
- Ensure that dumpster, recycling, and trash compactor bins close securely.
- Repair cracks and leaks in damaged floors, walls, and roofs.
- Replace moldy ceiling tiles, carpet, and other damaged items.
- Caulk and seal pavement cracks.
- Caulk and seal openings around pipes and conduits.
- Repair and/or replace worn and cracked grout.
- Install and/or repair screens and door sweeps.
- Remove clutter and debris.
- Locate dumpsters and bins away from buildings so that vermin that might be attracted to them are not encouraged to enter buildings.
Sanitation and personal responsibility for cleaning up after oneself are other notable areas to target in launching an IPM effort. Since pests need adequate food, water, and shelter in order to survive, it is reasonable to launch the IPM effort by working to remove these items. The removal of adequate sustenance from the reach of pests may significantly, quickly, and inexpensively reduce a school's pest problem.
The following are some suggested steps in implementing this program. Students and staff should be educated to do the following in classrooms, faculty rooms, offices, and lockers:
- Consume food only in designated areas.
- Clean up and properly dispose of leftover food.
- Do not leave food in lockers or desks.
- Store food and beverages only in designated areas and in tightly sealed containers.
- Promptly dispose of any trash that contains food.
- Keep instructional food items (items used in home & career class) in tightly sealed containers.
- Keep areas in and near refrigerators, vending machines, and microwaves clean and free of spills.
The suggested steps outlined above are just a sampling of some simple inexpensive steps that may be initiated in an IPM program. Most of these activities are largely common sense in nature; however, their impact will be significant in managing and limiting the school’s pest population.
Establishment of Tolerance and Action Threshold
A tolerance and action threshold defines the point at which specific pests can no longer be tolerated, thus initiating a pest-specific treatment action. Tolerance levels may be based on various circumstances including, health problems and illness caused by pests; pest damage that results in monetary loss; or aesthetic damage to plants. Public health threats should take precedence over the other circumstances and factors. For example, the presence of rodents inside a school building poses a potential health threat that must be addressed.
It is important that tolerance thresholds are pest-specific and are not set too low. One fly in a classroom should elicit a very different response than the sighting of a bee's nest on a playground. However, the only way to effectively manage and recognize potential problems is through a regularly scheduled pest monitoring inspection routine.
Monitoring
While education is the human key to IPM, monitoring is the engineering key to the IPM program. According to the EPA, monitoring is the "regular and on-going inspection of areas where pest problems do or might occur. Information gathered from these inspections is always written down." The identification of pests and the location of their habitat and food are essential steps in IPM. Monitoring also provides a window into the world of the pest, the size of their population, their entry route into the building, as well as sanitation or structural problems that may have permitted their entry in the first place. Both visual techniques and monitoring traps may be used in this investigation.
Visual monitoring techniques essentially involve an individual using simple tools such as a flashlight or magnifying glass to physically identify the presence of any pests, pest droppings or pest parts; a plastic bag to collect specimens; and an inexpensive camera to document pest damage and evidence. In lieu of a camera, simple sketches may also be made to further document the situation.
An essential component of an IPM program is the identification of the pest’s point of entry into the building. The location of the pest, its point of entry into the building, and follow up actions should be recorded for future reference and monitoring. A map or diagram clearly indicating the exact effected area may be helpful in future follow up activities. For example, it is noted that ants are entering the building through a crack in the floor. An IPM technique for addressing this situation would be to thoroughly caulk the crack in order to block the ant’s future entry into the building. This same crack will then be monitored in follow up IPM investigations. Still another example of visual monitoring involves locating animal droppings in and around a garbage dumpster. The dumpster has no lid, smells of spoiled food, and is usually filthy. An IPM technique for handling this situation may be to replace the dumpster with a new unused one with a lid. Another option may be to install a lid on the existing dumpster and thoroughly power-wash the inside and outside of the dumpster. The areas surrounding the dumpster will then be monitored in follow up IPM investigations.
The use of sticky and pheromone traps are another effective method for determining the extent of a potential pest problem. Traps are used to monitor a variety of insects, mites, and rodents. Sticky traps are generally glue covered cardboard surfaces that trap pests. Prior to placing them in strategic locations throughout the building, the traps should be dated and numbered for future reference. The traps may be placed in areas such as under sinks and stoves, in food storage areas, and behind toilets. Additionally, mechanical traps may be used to monitor rodent populations. Key information should be compiled based on what is found on the trap, such as the quantity of pests caught, the location of the pests on the trap, and whether adults and/or nymphs were captured.
Pheromone treated traps attract specific target insects, such as a wide variety of beetles and moths. Pheromones are the natural physical scents which insects use to communicate and attract each other. Since insects are often attracted by odors, pheromone treated traps are an effective method of monitoring specific target pests. Traps should never be placed in areas readily accessible to students where they may be disturbed, moved, or tampered with.
Should pest monitoring and/or traps disclose a pest problem, then a systematic approach to managing the target pest, which focuses on long-term prevention or suppression with minimal impact on human health, the environment, and nontarget organisms, should then be implemented. This approach may utilize cultural, physical, biological, and chemical pest population control methods to reduce target pests to acceptable levels.
Response Actions
IPM response actions include the use of mechanical, biological, and physical treatments and, as a last resort, least toxic pest specific pesticides. The use of vacuums, screens, caulk, and traps are examples of mechanical and physical controls for managing pests such as flies, ants, and termites. For example, a strong vacuum, including a crevice attachment, can suck cockroaches, their droppings, and their eggs from cracks. A tablespoon of cornstarch in the vacuum bag will ensure the pest's death.
Other physical controls may include screening windows, vents, and other openings in combination with weatherstripping or silicon or mildew-resistant caulk to insure an even tighter fit. Caulk may also be used around baseboards, wall shelves, cupboards, pipes, sinks, and toilets to control pests such as cockroaches and ants. Additional examples of mechanical and physical controls include physically removing stinging insect nests; controlling flying insects with sticky traps; vacuuming crawling insects; and trapping rodents.
A physical control for weeds may mean pulling the weeds up by hand or controlling them with various heat treatments. Raising mower height also reduces weeds. According to the EPA, "the taller the grass can be kept, and the denser the canopy, the greater the interception of available sunlight. By keeping the soil shaded, weed seeds are less likely to germinate."
Biological controls, such as pheromone-specific traps which attract insects
into a sticky trap, and least toxic pesticides may sometimes play a useful
role as a last resort in an IPM program. The blanket and automatic application
of any pesticide product should never be used as part of IPM. Pest specific
least toxic pesticides that concentrate on long-term prevention or suppression
with minimal impact on human health may be applied as a last resort in handling
a pest problem. EPA designated biopesticides, products derived from natural
materials such as animals, plants, bacteria, and certain minerals, may be
useful tools in these circumstances. Information on these products may be
found at www.epa.gov/pesticides/biopesticides/ 
.
Unfortunately, biopesticides are not yet available for all pests. In the
absence of such products, it is important that schools be very careful not
to use any products which are known, probable, or possible carcinogens,
neurotoxic organophosphates, or pesticides classified by the EPA as having
high acute toxicity.
DEC regulates the registration, distribution, sale, commercial use, purchase, and application of pesticides throughout New York State. Article 33 of the State Environmental Conservation Law and Part 325 of DEC regulations dictate the rules relating to the application of pesticides. Pesticide applications may only be performed by individuals currently certified by the DEC as a pesticide applicator or by a certified pesticide technician or apprentice working under the direct on-site supervision of a certified applicator. The State Education Department strongly recommends that schools only employ mature individuals who are at least twenty-one years old to apply pesticide products in schools and on school grounds, who are also certified by the DEC as a pesticide applicator. DEC law requires that the applicator must provide a copy of the pesticide label to the building owner prior to the actual application.
DEC further requires the person applying a pesticide to possess a copy of the label for the product, which is being applied at the time of the application, as well as their current DEC applicator certification card. It is illegal for any individual other than those noted above to apply any pesticide products in a school building or on school grounds. Specific questions relating to the DEC pesticide regulation may be directed to DEC regional offices throughout the state.
The State Office of General Services has issued a state contract for "Pest
Control Through Integrated Pest Management " for IPM vendors and contractors.
Questions on the state contract may be directed to the State Office of General
Services; Services and Technology Group; Contract Administration; Corning
Tower; Empire State Plaza; Albany, New York 12242. (http://www.ogs.state.ny.us/purchase/snt/awardnotes/71010s940019spec.htm )
Public Notification, Education, & the Neighbor Notification Law
Education is essential to an effective IPM program. IPM will only succeed if the entire school community understands, supports, and consciously works to make the program a success. The EPA recommends that a "school IPM program should include a commitment to the education of students, staff, and parents. This education should include not only the teachers, but also school nurses, cafeteria employees, and housekeeping and administrative personnel as well." The school health and safety committee, required by Commissioner's Regulation §155.4(d)(1), is an excellent starting point for this process. The committee's district officials, staff, bargaining unit and parent representatives should be enlisted to promote and advocate for IPM's successful implementation throughout the school community. Everyone should have a clear understanding of his or her role in the IPM program. Whether their individual role simply entails cleaning up after themselves, caulking cracks, or removing food from their lockers and desks, it takes the entire school community to effectively implement and maintain an IPM program. Informational brochures, public presentations and assemblies, and notices to parents, students, teachers, and staff are all techniques to communicate IPM awareness news to the school community.
Notification to the school community of potential pesticide applications is an additional component of IPM education. The Pesticide Neighbor Notification Law, Section 409-h of the Education Law, has formalized the notification process and provides specific direction on when and how the notification must take place. The Neighbor Notification Law, effective July 1, 2001, applies to all public and nonpublic elementary and secondary schools and details specific parties who must be notified, as well as the times and circumstances related to such notification.
This requirement states that schools provide a written notice to all parents, guardians, and staff at the beginning of each school year that includes the following points:
- a statement that pesticide products may be used periodically throughout the school school year
- a statement that schools are required to maintain a list of parents, guardians, and staff who wish to receive 48 hour written advanced notice from the school of an actual pesticide application.
- the name of the school representative to contact for further information.
At least 48 hours prior to an actual application, an additional written notice must be disseminated to all parents, guardians, and staff that have registered to receive the advanced application notification. This notification must explain the following:
- the specific date and location of the upcoming pesticide application;
- the pesticide product name and EPA product registration number;
- the name of the school representative to contact for further information.
The 48-hour notice must also include the following statement:
If a public health emergency exists which does not allow for the full 48 hour prior notification, the school must still make a good faith effort to notify those on the 48 hour list prior to the application.
The 48 hour notification registry and written notification provides parents and staff an opportunity to receive an accurate and timely accounting of what pesticide products have been and will be used in school buildings and on school grounds.
The following applications are not subject to prior notification requirements:
- a school remains unoccupied for a continuous 72 hours following an application;
- anti-microbial products;
- nonvolatile rodenticides in tamper resistant bait stations in areas inaccessible to children;
- nonvolatile insecticidal baits in tamper resistant bait stations in areas inaccessible to children;
- silica gels and other nonvolatile ready-to-use pastes, foams, or gels in areas inaccessible to children;
- boric acid and disodium octaborate tetrahydrate;
- the application of EPA designated biopesticides;
- the application of EPA designated exempt materials under 40CFR152.25;
- the use of aerosol products with a directed spray in containers of 18 fluid ounces or less when used to protect individuals from an imminent threat from stinging and biting insects including venomous spiders, bees, wasps, and hornets;
In general, a school district can avoid the 48-hour notification process by designing an IPM program that is restricted to the above noted items.
Finally, all schools must also provide additional written notification to all parents, guardians, and staff three times each year to inform them of any pesticide applications that have occurred. Notification must occur at the following intervals:
- within ten days of the end of the school year;
- within two school days of the end of winter recess;
- within two school days of the end of spring recess.
Notifications must include the following information for the period since the previous notice:
- the dates and locations of pesticide applications;
- the products used for each application which required prior notification;
- information on emergency applications;
- a reminder that persons may add their names to the 48-hour notification registry.
In addition to the requirements specified in the Pesticide Neighbor Notification Law, it also recommended that schools post a notice concerning any actual pesticide applications at the entrance of the building. A posted notice will serve to inform individuals not on the 48-hour registry and visitors to the building of the applications.
Recordkeeping
Education, people, cleanliness, and pest monitoring are key elements of IPM. However, accurate and detailed recordkeeping is what ties the entire program together. Careful IPM recordkeeping leads to better-educated and informed decision-making in managing school pest problems. According to the EPA, "accurate records of inspecting, identifying, and monitoring activities show changes in the site environment (reduced availability of food, water, or shelter), physical changes (exclusion and repairs), pest population changes (increased or reduced numbers, older or younger pests), or changes in the amount of damage or loss."
The types of pests, their physical location in the building or on school grounds, the quantity found, the season, the time of day, as well as exact circumstances surrounding their presence are all critical to IPM recordkeeping. A building-specific logbook, including a floor plan indicating the locations of pests, traps, and monitoring devices, should be carefully maintained. Follow up actions and activities must also be carefully maintained. Copies of pesticide labels, MSDS, as well as the date, time, and pest-specific pesticide application locations must also be recorded. Finally, the name of the applicator and a photocopy of their DEC certification should also be retained. Information on pesticide products must also be recorded pursuant to Occupational Safety and Health Act (OSHA) regulations. All IPM and pesticide application records should be made available for inspection to anyone who wants to review such materials.
The State Pesticide Reporting Law (PRL) (Chapter 279 of the Laws of 1996) mandates pesticide applicators and technicians, including school districts who employ certified applicators, to record and report, at least annually, all pesticide applications to DEC. This reporting requirement includes pesticide applications that have been performed by DEC certified school personnel. The annual report must be sent to DEC no later than February 1 of the year following the calendar year for which the report is submitted. The information and records maintained for each pesticide application must be retained for at least three years. The information which must be maintained includes: the EPA registration number of the pesticide which was applied; the product name; the quantity of each pesticide used; the date on which the pesticide was applied; and the location of the pesticide application by address (including the five-digit zip code). The pesticide dosage rate, the method of application, the target organism, as well as the place of application must also be recorded. Questions pertaining to this law should be directed to the: DEC Bureau of Pesticides Management, Pesticides Reporting Section at 1-888-457-0110 (toll-free from within New York State).
Conclusion
Thank you for working to make New York State's schools healthful and safe through the implementation of effective IPM programs. Through the diligence and commitment of all members of the school community - parents, staff, and students, IPM will result in healthy learning environments.
RESOURCES
American Lung Association | 212.315.8700 | www.lungusa.org/
BOCES Health and Safety Offices | Contact the State Education Department
NYS Integrated
Pest Management Program, 315-787-2353.
Healthy Schools Network | 518.462.0632 | www.healthyschools.org
IPM Institute of North America | 608.232.1528 | http://www.ipminstitute.org/school.htm
National IPM Network | http://www.csrees.usda.gov/nea/pest/pest.cfm.
NY Coalition for Alternatives to Pesticides (NYCAP) | 518.426.8246 | http://www.crisny.org/not-for-profit/nycap/nycap.htm
State Department of Health (DOH) | 800.458.1158 | http://www.health.state.ny.us/
State Department of Environmental Conservation (DEC) | 518.457.0300 | http://www.dec.state.ny.us/website/dshm/pesticid/pesticid.htm
State Education Department (SED) | 518.474.3906 | www.emsc.nysed.gov/facplan/
State Office of General Services (OGS) | 518.486.7323 | www.ogs.state.ny.us/purchase/snt/awardnotes/71010s940019spec.htm
U.S. Environmental Protection Agency (EPA) | 703.305.7090 | http://www.epa.gov/pesticides/ipm/
University of Florida IPM Program | http://ipm.ifas.ufl.edu/