How to Enforce IPM

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Enforcing the School Rule
Outline
1. Revisiting the School Rule
2. Reviewing the IPM policy and plan
3. IPM: Practicing
4. Current regulations regarding IPM
Must Have!
Will guide you through
the whole process
Includes detailed
control practices for
common pests
Includes IPM policy and
plan instructions
Has reporting forms
More!
http://www.birc.org/SchoolManual.pdf
School Rule Enforcement
45,460
7,000
12,900
33,300
66,100
13,500
150,000
110,100
5,100
10,400
16,560
~ 551,000
38,300
~ 44,000
Developing an IPM Program
• Educate key decision-makers
• Develop an IPM policy
• Identify roles & responsibilities
• Set management objectives
• Create IPM Plan
• Institutionalize
• Review
Phase 1: Start-Up
Educate Key Decision-Makers
• School board
• Superintendents
• Business
operations
managers
• Principals
• PTA officers
IPM Policy
• Few sentences
to 3 pages
Pest Monitoring - Education - Record Keeping
• Briefly describe
what is expected
“It is the policy of this
school district to use
IPM practices and
principles to manage
pests on school
p r o p e r t y … ”
Advisory Committee - Roles & Responsibilities
• State intent
Pesticides - Notification & Posting - Evaluation
IPM Principles & Practices - IPM Coordinator - Roles
Roles & Responsibilities
Facilities/Grounds
Director
IPM Committee
• Review
• Advise
• Recommend
Custodial - Env. Health - Kitchen
• Oversight
Maintenance - Staff - IPM Coordinator
Parents - Teachers - Grounds - Nurses
Wilson
committee!
IPM Coordinator
IPM Coordinator
•
Is a job for a willing person
•
Runs the day-to-day
program
•
Ensures program success
•
Provides IPM training
IPM Coordinator
•
Primary contact for
pest control issues
•
Provides IPM
expertise
•
Works with pest
management
contractor
IPM Coordinator
Authority to request
• Sanitation
• Cultural controls
• Facility repairs
• Renovations
• Other improvements
to manage and prevent
pest problems
IPM Coordinator
• Pesticide application
notifications
• Maintain the school
District list of allowable
pesticides
• Reports to the school
administration and/or IPM
Advisory Committee
or Site Committee
Administrators & School Boards
•
Know “School Rule”
•
Set tone
•
Support & Encourage
•
Communicate with
Coordinator and
committee
Administrators & School Boards
• Form IPM Advisory Committee
• Designate or hire a IPM Coordinator
• Provide authority to IPM Coordinator
Nurses
•
Have access to SDS
•
Know signs and
symptoms of pesticide
poisoning
•
Know asthmatic
students
•
Keep list of
hypersensitive students
Students & Staff
•
•
Don’t leave food in lockers,
classrooms, and common
areas
Don’t eat & drink in areas
other than areas designated
for food consumption
•
Properly store all food in
pest-proof containers
•
Report pests
Parents
• Understand IPM
program basics
• Express concerns
• Should use IPM
practices in their homes
• Prevent introductions
• Participate
Maintenance/Custodial/Grounds
• IPM Training
• Recognize and correct
pest conducive
conditions
• Communicate with IPM
Coordinator
Kitchen Staff
• Understand IPM
• Understand good
sanitation
• Demonstrate proper food
storage
• Work with County Health
Inspectors
KEEP AREAS
UNDER KITCHEN
EQUIPMENT
CLEAN AND DRY.
Vendors & Contractors
•
Should expect specific
language in bid
specifications and
contracts
•
Must adhere to
school’s IPM program
•
Must prioritize work
that prevents pests
•
Penalties
Pest Management Contractor
Contracts:
Service-based, not necessarily lowest bid
• Accommodate IPM policy
• Consult with IPM Coordinator
• Timely response
• Regular inspections of PVAs
• Detailed record keeping
- pest sightings
- pesticide use
Pest Management Contractor
•
Provide labels and
SDS documents to
school staff
•
Recommend corrections
for pest-conducive
conditions
•
Facilitate proper posting
and notification
Pest Management Contractor
•
Promote least-hazardous
methods to correct pest
problems
• Properly licensed and
supervised by knowledgeable,
trained personnel
• Provide an IPM plan to the
district if required, that is subject
to review by LHOs
How to Develop an IPM Program
• Set management
objectives
• Create IPM Plan
• Institutionalize
• Review
Operational Phase: Stage 1
•
Reduce/eliminate routine
pesticide applications
•
Monitor & establish
thresholds
•
Pesticides applied
at thresholds
•
Spot-treat; use baits
and other least toxic
•
Begin setting pest
management objectives
& strategies
Operational Phase: Stage 2
•
Inspections
•
Site-specific
management
plans
•
Educating
participants
Operational Phase: Stage 3
•
Develop IPM Plan
•
Institutionalize
•
Develop incentives &
rewards
•
Provide ongoing
education
Next Steps
1. Educate Admin & Board
2. Create IPM policy
3. Outline roles and responsibilities
4. Create IPM committee
5. Set pest management objectives
6. Create IPM plan
7. Follow the plan
8. Institutionalize the plan
9. Review and revise the plan
School Health Inspections
Assessing IPM Programs in Schools
School Health Inspections
Look for documentation
•
IPM Policy and plan
•
*School-specific IPM plans
•
IPM Coordinator?
•
SDS sheets
•
Pesticide application records
•
Pest sighting logs/reporting forms
•
Pest monitor forms
•
List of sensitive/asthmatic students
Look for common IPM practices
•
Monitoring program
•
Door sweeps
•
Pest access
•
Food storage/access
issues
•
Harborage issues
•
Dumpster
placement/use
Look for common IPM practices
•
Sanitation issues
•
Drains
•
Mop storage
•
Education of staff
Using Existing Codes
Within current health regulations
there already existed
the ability to enforce IPM in schools…
Using Existing Codes
392-200-2(3).
“…if the Executive Director or the LHO determines
that conditions in any school are a threat to the
health of persons using the school, the Executive
Director or the LHO may order correction of any
condition that impairs or endangers the health or life
of those attending schools.
The Executive Director or LHO may allow temporary
measures to ameliorate the problem for up to a year
until the governing body can make a permanent
correction.”
Using Existing Codes
392-200-7(3): Plumbing must be maintained mechanical
392-200-7(10): Solid wastes shall be kept in durable, easily
cleanable, insect-resistant and rodent-resistant containers that
do not leak and do not absorb liquids. cultural/sanitation
392-200-7(10): The gov. body shall direct school personnel to
clean and repair or replace all waste containers at a frequency
that will prevent odors and prevent insect and rodent
attraction. education/cultural
Using Existing Codes
392-200-7(10): Waste materials stored on the premises must
be located to minimize access to insects, rodents, and other
animals and not cause a nuisance. cultural
392-200-7(10): Tight-fitting lids, doors, or covers shall be
provided on waste containers, etc. The lids, doors, or covers
shall be kept closed except when emptying or filling. Must be
maintained in good repair. Containers with drains shall have
drain plugs in place except during cleaning. cultural
392-200-7(10): Waste shall be disposed of often enough to
prevent the development of odor and minimize the harborage
of insects or rodents. cultural/sanitation
Using Existing Codes
392-200-8(1): Floors, walls, and ceilings shall be clean and in
good condition. sanitation/mechanical
392-200-8(7): Custodial closets should be kept clean…
sanitation/cultural
392-200-9 Health and safety
The gov. body shall ensure that specific safety directions
accompany substances that are deemed potentially harmful or
hazardous… Directions shall include proper use, storage,
handling and disposal and the potential risks or hazards. SDS
must be available when requested by PHOs education
Using Existing Codes
392-100. Food Sanitation Regulation
• 4.5.59 Outside Receptacles – Refuse, Recyclables and
Returnables.
• 4.5.63 Storage Areas, Redeeming Machines, Receptacles
and Waste Handling Units – Location.
• 4.5.64 Storing Refuse, Recyclables, and Returnables.
• 4.5.67 Covering Receptacles.
• 4.5.68 Using Drain Plugs.
• 4.5.70-71 Cleaning Receptacles.
Using Existing Codes
392-100. Food Sanitation Regulation
• 4.6.15 Outer Openings – Protected.
• 4.6.16 Exterior Walls and Roofs – Protective Barrier.
• 4.6.40 Repairing – Physical Facilities.
• 4.6.41 Cleaning – Frequency and Restrictions.
• 4.6.45 Drying Mops.
• 4.6.50 Controlling Pests.
• (ii) Routinely inspecting the premises for evidence of pests;N
• (iv) Eliminating harborage conditions.
Using Existing Codes
392-100. Food Sanitation Regulation
Enforcement mechanisms
• Administrative actions
• Inspection report notice of violation
• Timely correction
• Criminal enforcement actions
• Civil enforcement actions
• Criminal, civil and administrative penalties
Be Educators!
Resources
utahpests.usu.edu
ryan.davis@usu.edu
Resources
•
USU Extension: ryan.davis@usu.edu
•
USU School IPM Website:
http://utahpests.usu.edu/schoolIPM/
•
National IPM Institute Website:
http://www.ipminstitute.org/school_directory.htm
•
Go to “links and resources”
•
eXtension SIPM Website:
http://www.extension.org/pages/20295/pest-managementaction-plans-for-schools#.VCR2iksiqf0
What IPM is
•
Is a process…not a miracle
•
Management based on
education/communication
•
Supported
•
Partnership
•
Empowerment
What IPM is NOT
•
A job for the unwilling
•
A low-bid process
•
Out of sight, out of mind
•
A chemical pesticide
program to prevent pests
from entering schools
•
A no-pesticide option
Tips for Developing IPM
•
Mandate training
•
Develop a resource list
•
Build library
•
Change over time
•
Share the process
•
Communicate
•
Publicize
•
Involve community
Health Department’s Take
•
IPM Policy and plan
available upon request
•
*Site-specific IPM plans
•
SDS sheets
•
Pesticide application
records
•
Pest sighting
logs/reporting forms
•
Pest monitors and pest
monitor forms
Health Department’s Take
•
Sanitation issues
•
Food storage/access
issues
•
Pest access and
harborage issues
•
Dumpster
placement/use
•
Drains
•
Mop storage
•
Education of staff
Health Department’s Take
There are many
enforceable rules in health
codes
R392-200: School Rule
R392-100: Food Handling
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