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