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Sample IPM Policy

Policy #3521.5(a)

MCKINLEYVILLE UNION SCHOOL DISTRICT

DRAFT

Least-Toxic Integrated Pest Management Policy

The McKinleyville Union School District ("District") recognizes that the maintenance of a safe, clean and healthy environment for students and staff is essential to learning. It is the goal of the District to provide for the safest and lowest risk approach to control pest problems, while protecting students, staff, the environment, and District property.

The District recognizes that pesticides may pose risks to human health and the environment, with special risks to children. It is recognized that pesticides may cause adverse human health effects such as cancer, neurological disruption, birth defects, genetic alteration, reproductive harm, immune system dysfunction, endocrine disruption and acute poisoning.

The District hereby adopts the Precautionary Principle as the basis for this Least-Toxic Integrated Pest Management (IPM) policy. The Precautionary Principle states "When an activity raises threats of harm to the environment or human health, precautionary measures should be taken, even if some cause-and-effect relationships are not fully established."

The District hereby adopts a Least-Toxic IPM Policy. This policy shall focus on long-term pest prevention and give non-chemical methods first consideration when selecting appropriate control techniques. The full range of alternatives, including taking no action, will be considered first, with chemical controls used as a last resort, giving preference to chemicals that pose the least hazard to people and the environment and excluding use of the most hazardous pesticides. The District’s long-term goal is the eventual elimination of all chemical pest control methods.

 

A. Elements of the Least-Toxic IPM Policy
  • Establishing pest management area objectives, e.g. kitchens, playgrounds, classrooms.
  • Monitoring to determine pest population levels and identify decisions and practices that could affect pest populations.
  • Eliminating pest habitats to deter pest populations and minimize pest infestations.
  • Utilizing pest prevention methods, such as structural modification, and/or employing progressive non-chemical methods.
  • Employing as a last resort pesticides from the approved list, and, if demonstrated to be necessary, pesticides from the limited use list.
  • Evaluate economic and/or program disruption impacts of proposed actions on a case by case basis.
  • Evaluate and monitor the residual quantity of any applied pesticide not on the Approved Use Pest Control materials List to determine the amount accessible for exposure.

 

Policy #3521.5(b)

B. Decision-making Process

An IPM Committee shall be established within 45 days of the passage of this policy to develop implementation guidelines and oversee implementation of this IPM policy. The IPM committee is an advisory group to the Governing Board, assisting in the decision-making process of a possible addition of a pesticide to the Approved Use Pest Control Materials List, Limited Use List or in the case of public health emergencies. The Committee’s main purpose is to gather information and advise the Governing Board on issues related to the IPM plan. The Committee will also develop a plan for training (see section D below). The IPM Committee will work together and strive towards constructive solutions to IPM issues, keeping the best interests of the children in the forefront of the decision-making processes.

The Committee will include the following members:

  • Assistant Superintendent for Business (IPM Coordinator)
  • Director of Maintenance and Operations and/or
  • Grounds person
  • One Board Member
  • One Site Principal
  • Public Health Officer and/or their designee
  • One Parent appointed by Morris Site Council
  • One Staff member appointed by Morris Site Council
  • One Parent appointed by Dows Prairie Site Council
  • One Staff Member appointed by Dows Prairie Site Council
  • One Parent appointed by MMS Site Council
  • One Staff Member appointed by MMS Site Council

The Committee will consult with outside professionals as needed. They may include but not be limited to: Risk Manager for North Coast Schools Insurance Group, Department of Agriculture Senior Inspector, Humboldt County Vector Control Officer, and Supervisor of Grounds and Landscape Services at Humboldt State University.

The IPM Committee deliberations will be made on a consensus basis. Should the committee not be able to determine a course of action a report will be made to the Governing Board. A quorum of the IPM Committee will be 7 members. As a standing committee of the Governing Board, the rules provided by the Brown Act will be followed.

- IPM Coordinator -

The Assistant Superintendent for Business is the designated IPM Coordinator. The IPM Coordinator shall be responsible for coordinating school district efforts to adopt IPM techniques, communicating goals and guidelines of the IPM Program to staff and students, providing proper training, tracking pesticide use and ensuring that related information is available to the public, and presenting an annual report to the school board evaluating the progress of the IPM Program. The IPM Coordinator is responsible for all purchasing of pesticides to be used on District sites. Only persons specifically authorized by the IPM Coordinator are permitted to bring or apply pesticides on district sites or property; other site employees and non-employees are not permitted to bring or apply pesticides on district property.

 

Policy #3521.5(c)

C. Product Selection and Use Approval

Products selection will be based on IPM Committee review of the product’s contents, precautions, and adverse health effects. Evaluation of the product shall not be based solely on the Material Safety Data Sheet, but may include current peer-reviewed scientific papers or reports and other available information sources that may include Department of Pesticide Regulation, Environmental Protection Agency, and Extension Toxicology Network publications. The IPM Committee will make product recommendations to the board for final approval.

Products will be divided into three classifications: Approved Use List, Limited Use Products and Banned Use List.

1. Approved Use Pest Control Materials List

The IPM Coordinator shall maintain a list of all pest control materials that the board has approved for use in the schools, along with any restrictions for such use. This list shall be referred to as the Approved Use Pest Control Materials List. The Approved List shall include the following in addition to products approved by the Governing Board:

- Mechanical or Biological Products -

  • Caulking agents and crack sealants;
  • Physical barriers: and
  • Cryogenics, electronic products, heat and lights;

- Chemical Products -
  • Soap-based products;
  • Borates, silicates and diatomaceous earth;
  • Insecticide or rodenticide self-contained baits and traps;
  • Products consisting solely of active and inert ("other") ingredients on the FIFRA’s 25(b) list (40 CFR part 152.24(g)(1) as listed on the Federal Registration (PR) Notice 2000-6;
  • Fertilizer products containing combinations of nitrogen, phosphate, and/or potassium and not containing urea formaldehyde, lead or any amount of chemical pesticide.

 

2. Limited Use Products

A pesticide applicator or district staff may submit a written request to the IPM Committee that a particular pesticide not on the Approved Use List be approved for use for a specific and limited purpose. Limited Use Products may not be pesticides on the Banned Use List. The request must be reviewed by the IPM Committee, signed by the IPM Coordinator, and approved by the Governing Board. The IPM Committee may grant a limited use exemption, not to exceed three months, upon finding that the pesticide applicator has:
    • Identified a compelling need to use the pesticide;
    • Made a good-faith effort to find alternatives to the particular pesticide;
    • Demonstrated that effective, economic alternatives to the particular pesticide do not exist for the particular use; and
    • Developed a reasonable plan for investigating alternatives to the pesticide in questions during the exemption period.

Policy #3521.5(d)

D. Banned Use Products List

The following high health risk pest management products will not be allowed on the Approved List or as a Limited Use Product:
    • Pesticides linked to cancer, (US EPA Class A, B and C carcinogens and chemicals known to the state of California to cause cancer under Proposition 65);
    • Pesticides that cause birth defects or reproductive or developmental harm (identified by the US EPA or known to the State of California under Proposition 65 as reproductive or developmental toxins);
    • Pesticides that interfere with human hormones;
    • Pesticides classified as Toxicity Categories I and II by US EPA;
    • Foggers, bombs, fumigants or sprays that contain pesticides identified by the state of California as potentially hazardous to human health (CFR 6198.5).

Policy #3521.5(e)

4. Emergency Exemptions

The Governing Board may allow trained district staff or a company contracted to provide pest control to the district to apply a pesticide not on the approved or limited use onlyif necessary for the protection of public health, as officiallydirected by Federal, State or County Health Officials. Such exemptions shall be granted on a case-by-case basis and shall apply to a specific pest problem for a limited time

Once a situation is presented to the IPM coordinator and time is of the essence a meeting of the IPM Committee will take place within 72 hours. If the committee cannot determine a course of action and recommendation to the Board within the following 72 hours the Governing board will hold a special meeting to consider the matter.

Policy #3521.5(e)

E. Training

Training of personnel is critical to the success of an IPM program. Staff, students, pest managers and the public shall be educated about potential school pest problems, the Least-Toxic IPM Policy, and procedures that will be used to achieve the desired pest management objectives. The District will participate in training provided by the Department of Pesticide Regulation as mandated by the Healthy Schools Act 2000.

Policy #3521.5(f)

F. Contractors

All pest control companies contracted by the District shall follow all provisions of the policy.

 

G. Notice, Record-keeping and Reporting

In compliance with and in addition to the notification, posting, and record-keeping requirements mandated by the Healthy Schools Act, the District will notify parents, employees and students of all pesticide applications using the following guidelines:

  • The district will provide annual notification to parents or guardians in the Registration Packet distributed at the beginning of each school year or upon enrollment. Notification will include:
    • The IPM Policy statement;
    • The Approved list of pesticide products;
    • The availability of IPM activity records in the main office of each school; and
    • A request that parents or guardians notify the school principal if they believe that their child’s health and/or behavior would be influenced by exposure to pesticide products.
  • The Approved List and Banned List will be conspicuously posted annually in the main office of each site and remain posted throughout the year.
  • Applications of products not on the approved list will be preceded by a 72-hour notification of parents or guardians and school staff, except for public health emergencies as determined under section C(4) above. The IPM committee may require notification of Approved List products.
  • Notification will be by US mail and will include:
    • The product name and active ingredient and CAS number or EPA registration number;
    • Target pest;
    • Date of pesticide use;
    • Signal word on the label indicating the toxicity category of the pesticide;
    • Contact for more information;
    • Half-Life of the product (the longer of the two lives provided: 1. as listed on EXTOXNET (Extension Toxicology Network) or the product MSDS fact sheet);
    • Availability of further information at the school’s main office and district contact person;
    • Website resources for additional information including potential side-effects.
  • Records of each pest management action shall be available upon request to the public and kept at the school site for a period of at least four years. As required by the Healthy Schools Act, each record shall include the following information:
    • Name and address of the school site;
    • Location of the pesticide application;
    • Target pest;
    • Date and time the pesticide or management action was completed;
    • Pesticide product name/manufacturer;
    • EPA/California registration number from product label;
    • Total quantity of pesticide product used (in lbs., oz., pt., qt., gals.);
    • Rate of use per acre;
    • Dilution;
    • Size of the area treated;
    • Application method (i.e. ground, air or other);
    • Application equipment used;
    • Re-entry period if applicable; and
    • Name of the pesticide applicator.
  • Signs shall be conspicuously posted around any area where pesticides not on the Approved List are to be applied in a non-emergency situation at least 72 hours before and remain posted for the full life of the pesticide or until monitoring indicates non-detectable levels.
  • In the event of an emergency as determined above in Emergency Exemption (Section 4), posting will go up as soon as possible but at a minimum at the time of the application. Signs shall include the information listed in Notice, Record-keeping and Reporting (Section G.4.).

 

Legal Reference:

  • FOOD AND AGRICULTURE CODE, 11410-15206.6–Pest Control Operations and Agricultural Chemicals
  • CALIFORNIA STATE CONSTITUTION–Right to Safe Schools Article I, Section 29 (c)
  • CODE OF REGULATIONS, TITLE 8

3. Employer’s Obligation to Provide Safety Information

1. Construction Safety Orders, Lead Standard

  • UNITED STATES CODE, TITLE 7

136 et seq. Insecticide, Fungicide and Rodenticide Act
  • HEALTHY SCHOOLS ACT OF 2000
  • GOVERNMENT CODE 54950 et seq.

 

 

 

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