Model Pesticide Safety and
IPM Guidance Policy for
School Districts
Center of Expertise for School IPM
&EPA
United States
Environmental Protection
Agency
April 2014

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United States
Environmental Protection
Agency
The US EPA recommends that all school districts implement a policy addressing the safest possible
use of pesticides and the implementation of a coordinated Integrated Pest Management program as
part of a long-term and sustainable approach to mitigating pests and their impacts on children's health.
By publishing a policy, the district leadership establishes his/her commitment to promoting a healthy
environment where students are more productive.
This model pesticide safety and Integrated Pest Management guidance policy addresses not only the
safety concerns when using pesticides, but also focuses on solution-based approaches to mitigate
the reasons pests are in our schools. This is a proactive rather than reactive approach. As a result,
it provides the school district, and its individual school campuses, a sustainable and long-term pest
management alternative to traditional pesticide-only approaches.
This model guidance policy represents the US EPA recommendation for best management practices
for the successful implementation of pesticide safety and Integrated Pest Management in kindergarten
to 12th grade schools, and is not intended to supersede State, Tribal or Local requirements, where
those requirements are more stringent or specific. To find out more about sustainable approaches
to verifiable Integrated Pest Management in schools, visit our web site at: www.epa.gov/pesticides/
ipm.
This model policy is available for use by administrators, educators, parents and others to help inform
the development, adoption and/or improvement of policies for your district. The model policy is
presented in sections in italics. Each section is introduced with background and rationale. For a
modifiable Microsoft Word version of this document, visit www.epa.gov/pestwise/publications.

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Policy Statement
United States
Environmental Proieclion
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These model policy statement opening paragraphs express the intentional commitment by the
school district leadership to provide a safe, clean and healthy environment for students and staff
through the use of reduced-risk methods to lessen pest problems and complaints. It is a commitment
to eliminate the routine application of pesticides by focusing on preventing pest infestations through
improved sanitation and pest exclusion, and making school facilities and grounds unattractive to pests.
Here is an example of how an effective policy might begin:
"It is the policy of {insert name} School District to manage pests in and around schools in a manner
that protects human health, maintains the integrity of school buildings and grounds, and preserves
the environment.
{insert name} School District is committed to the sustainable management of pests through the use of
sound Integrated Pest Management (IPM) that focuses on eliminating pest access to food.[ water and
shelter in and around our schools. This is accomplished through the use of reduced risk pest control
methods with a preference for non-chemical control measures. Sanitation, pest exclusion and habitat
modification are essential to successful long term pest mitigation. Buildings will be regularly cleaned
and repaired in order to prevent pest infestations. All facilities and grounds will be maintained to be
free of trash, debris and clutter. Ornamental plants, turf and desirable grasses will be managed in a
manner that limits animal plant and microbial pest attraction. "
Oversight and Management
Once you have stated your overall commitment, the following statement identifies the district
leadership's approach to managing the district's pesticide safety and IPM program. Oversight and
management of this program can be characterized by support from two separate activities.
The first is establishment of a committee, or a charge to an existing committee, to advise the
i district's leadership on enacting this policy and the risks, costs, and issues of various pest
[management approaches. Pest management activities and their impact on student/staff health and
t safety cuts across multiple school programs and functions. Examples include, but are not limited
| to: school nurse (environmental health, pest-borne/pest associated disease risks, asthma, pesticide
|poisoning), facilities management (pest control, structural integrity, grounds management),
custodial services (sanitation and waste management), food service (sanitation and food
protection), administration (policies, funding, resources, community relations), teaching staff
[(classroom source reduction and student education), coaching staff (sports safety), parents
[(health and safety of students), pest management professional (contracted services), and the
community at large (impact of campus activities on the broader community).
The second is the appointment of an IPM coordinator to provide direct oversight of the day-
-to-day activities of the program. The IPM coordinator should be trained in the principles
of Integrated Pest Management, pesticide safety, pest control contract oversight, record
t keeping, and pesticide regulations. The US EPA recommends a minimum of six (6) to
L eight (8) contact hours of training annually for the IPM coordinator from competent state,
extension, or other agencies. The IPM coordinator is also the key advisor to the committee
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charged with pest management and serves as the primary educator to the district and school
staff on their responsibilities to the district policy and supporting program. An example
oversight and management statement might read:
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"{insert name here} School District will actively manage the pesticide safety and IPMprogram by
establishing a committee whose responsibilities include providing guidance, education, and support
on program procedures and processes. Members of the committee will be appointed by the district
leadership and will include: the district leadership or designee, a board member; IPM coordinator,
registered school nurse, administrative staff member] academic staff member; parent, one at-large
community member, and facility manager. Other members may be appointed to meet the needs of
this policy. The committee will meet semi-annually, or more frequently as required, to address the
components of this policy.
An IPM coordinator will be appointed by the district leadership to provide oversight and
implementation of the pesticide safety and IPM program. The 1PM coordinator is the key advisor
to the district and is responsible for: development and management of appropriate plans, pest
control contract oversight, conduct of training on pesticide safety and 1PM to district and school
staff records management, and providing guidance and recommendations on current regulations,
procedures and products used in managing pest populations. The IPM coordinator will be trained
in the principles of Integrated Pest Management and pest control contract oversight, completing a
minimum of six (6) to eight (8) contact hours of training annually on the subject. "
Annual Pesticide Safety and IPM Plan
The US EPA recommends that all school districts develop and update an annual pesticide safety and
IPM plan that details the components of the school district policy, describes staff responsibilities,
lists all approved products and methods by pest, and discusses monitoring and reporting processes
I for pest infestations, as well as, action levels for the use of pesticides. Pests should be listed by
[order of medical priority or health risk to humans to assist with developing risk assessments and
[ emergency pesticide application decisions associated with particular pest infestations. The plan
should also list any environmentally sensitive areas, such as water protection zones, protected
and endangered species, and culturally sensitive areas that may limit or impact specific pest
mitigation activities. An example plan statement may read:
"The IPM coordinator will develop and submit a recommended pesticide safety and IPM plan
annually to the committee for review and comment. The IPM coordinator will submit the
%al draft, addressing committee comments, to the district leadership for submission to the
board. The plan will address and detail the components of the district policy, list approved
.. low hazard/toxicity products and methods by pest, and discuss the decision-making process
for any pest mitigation effort, to include methods for monitoring, reporting pest sightings,
action levels for the use ofpesticides and a list of all environmentally sensitive areas that
may be impacted by the district's pest management activities. Pests will be listed in order
of medical or health risk importance to assist in prioritizing pest mitigation efforts based
on risk to students, staff and the community. The IPM coordinator, in coordination with

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Notification
"Students, staff and parents/guardians will be notified at least 24-48 hours prior to any
pesticide application. For emergency applications where an imminent threat to health exists
(e.g., stinging insects), students, staff and parents/guardians will be notified within 24 hours
after the pesticide application. "
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Environmental Protection
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designated district school nurse, will develop and include appropriate action steps in
the program plan for each pest of public health importance deemed a probable risk by the
committee (head lice, bed bugs, fire ants, etc.). "
Pesticide Safety
The use of Integrated Pest Management does not exclude the use of pesticides, but rather encourages
the use of multiple mitigation approaches, and when deemed necessary those pesticides that pose the
least risk to humans and the environment. Pests that, by their nature and/or numbers, pose significant
risk to human health and safety, structural integrity, or economic loss must be controlled. When
reasonable non-chemical measures do not provide adequate control, pesticides may be needed Since
children are at the greatest risk of exposure to pesticides, the US EPA recommends a careful approach
where pesticides with the least potential for exposure and lowest toxicity are selected.
It is recommended that the use of pesticides be approved by the IPM coordinator and only applied by
State/Tribally certified pesticide applicators who are knowledgeable in Integrated Pest Management.
Students and staff should be notified of all pesticide applications 24-48 hours prior to their application
[except in cases of emergency. Treated areas should be posted with highly visible signs, and pesticides
should not be applied when people are present or expected to be present per the pesticide's label re-
entry statements or for at least eight (8) hours after application of the pesticide, whichever is greater.
Examples of statements addressing the components of pesticide safety might read:
Pesticide Use
"When reasonable non-chemical approaches do not provide adequate control, products that pose
the least risk to people and the environment will be selected, and then only used when and where
pests are present, or expected to be present, as determined by monitoring and action thresholds
and approved by the 1PM coordinator Pesticide applications will not be made on a routine or
regularly scheduled basis. The use ofpesticides with the signal words 'Warning' and 'Danger '
should be avoided. In documented emergency situations where the presence of a pest immediately
threatens the health or safety of students, staff faculty members or members of the public using
i the campus, the IPM coordinator may consider the use of pesticide products that do not fit the
above criteria."
Certified Pesticide Applicators
"Only {insert state/tribe name} certified pesticide applicators trained in Integrated Pest
Management will apply pesticides on {insert name} School District properties. "

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Record Keeping
Record keeping is critical to analyze, evaluate and determine the efficacy of any pesticide safety
j and IPM program. Well maintained and accurate records provide a means to verify that the policy
[is being followed, identifies historical trends and repetitive issues, and justifies decisions and
[actions taken to mitigate pests. An example of a record keeping statement may read:
"Records will be maintained by the IPM coordinator of all monitoring and mitigation efforts,
j to include all in-house and contracted pesticide applications and copies of the pesticide
(^pUMtofs ' eertificcitjonsfor at least three (3) years after the date of the activity. Records
. documenting the use of all pesticide applications will include the applicator's name, the product
name, the product's EPA registration number, quantity used[ date and time of application,
location, application method and the targeted pest. The IPM coordinator will also maintain
records of committee minutes, training given to staff continued education training taken,
and exterior agency audits on environmental health, sanitation, and safety as they pertain
to pesticide safety and pest mitigation for at least three (3) years from the date given or
published. "
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Environmental Protection
Agency
Posting
"Pesticide application sites will be posted with highly visible signage during and at least 24-
48 hours after all pesticide applications. Postings will be labeled with the date of application, pest
treated for, pesticide used, applicator name, certification number of applicator, phone number of
applicator/company, and date/time reentry is authorized. For emergency applications where an
imminent threat to health exists (e.g., stinging insects), postings must be placed as soon as practical
with a preference to no later than the start of the pesticide application. "
Exclusion
"Pesticides will not be applied when persons, other than pesticide applicators, are present or
are expected to be present. All persons other than the pesticide applicators will be excluded from
the treated site for at least eight (8) hours after the completion of any pesticide application, or as
prescribed by the pesticide label, whichever is longer. "
Exemptions
" The use of insecticide or rodenticide baits in pre-mam factured[ tamper-resistant containers placed
in areas inaccessible to children, insecticide baits in gel or paste form placed in cracks and crevices
inaccessible to children, and antimicrobial pesticides, including sanitizers and disinfectants, are
I exempt from notification, posting and exclusion requirements unless specified otherwise on label
directions. Rodenticide baits in tamper-proof containers are exempt from exclusion requirements,
but must be labeled with all other posting requirements on the exterior of each container. Such
containers should be limited to areas normally inaccessible to children. "

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Training
Training and educati on of personnel are essential to a successful pesticide safety and IPM program.
The US EPA recommends that staff, students, and the general public receive appropriate education
on the subject and program, as well as their responsibilities to the program and how their actions
determine success or failure. Such training and education build a culture of pest-free schools and leads
to sustailiability of the program beyond the presence of a single individual or office.
As stated previously, certified pesticide applicators and IPM coordinators require specific training
related to pests, pesticides, and approaches. But, all others require training and education specific to
the impact their individual activities have on successful pest management.
Custodial and food service staff should be trained a minimum of one (1) hour annually on
the components of IPM and how their efforts towards sanitation impact pest infestations.
Facilities management personnel should be trained a minimum of one (1) hour annually on
the components of IPM and how their efforts at sealing the building envelope and repairing
water leaks impact pest infestations.
Teachers and administrative staff should be trained a minimum of one (1) hour annually on
the components of IPM and how their efforts for clutter removal and general classroom/
office sanitation impact pest infestations.
Students and the general public should be provided direct and supplemental education/
information on the district's program, and how they contribute to success of the program.
All personnel should be trained on how to identify and report pest problems and conditions
that lead to pest infestations.
An example training statement may read:
"Training ofpersonnel is critical to the success of our pesticide safety and IPM program. Staff
students, and the public will be educated about pest problems associated with school settings, the
components of IPM., the district policy, their roles in achieving pest-free schools, and procedures.
Within five (5) months of the district adoption of this policy, the pesticide safety and IPM
committee will agree on a plan to educate, train, and inform these constituencies. When we all
learn to think pests as we go about our daily tasks, we will deny pests access to food, water and
shelter, and make our schools unattractive to pests. "

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Resources
The US EPA's Center of Expertise for School Integrated Pest Management provides leadershi p and
expertise to effectuate the goal of ensuring that millions of children in our Nation's schools benefit
from IPM practices and verifiable IPM programs. The Center may be reached by email at
school i pm@,epa. gov.
Each US EPA Regional Office has a School IPM Coordinator who works with change agents, states,
and tribes to promote verifiable and sustainable IPM programs. Find your Coordinator at
www.epa.gov/pesticides/ipm.
The EPA booklet, Pest Control in the School Environment: Adopting IPM (www.epa.gov/pesticides/
ipm/brochure). encourages and assists school officials in examining and improving their pest
management practices. It identifies ways to reduce the risk of pests and pesticides in school buildings
and landscapes.
EPA's website (www.epa.gov/pesticides/ipm) provides valuable IPM information for administrators
and others with decision-making responsibilities for pest management in and around schools.

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