Thursday, October 18, 2012

Making Sense of the Notification Requirements for School IPM

We get a lot of questions from maintenance directors, school IPM coordinators, and other school personnel regarding proper notification procedures for school IPM. Following is a set of “Frequently Asked Questions,” which can also be found on our website (http://schoolipm.ncsu.edu), which may help clear up any uncertainties.

When did the notification requirement become effective?

All public schools were required to begin the notification process effective October 1, 2006.

Who must be notified?

Schools are required to notify the parents/guardians of school children, as well as the teachers and other staff in their school system.

Who is responsible for notifying the parents, guardians, and staff at a particular school (or facility) about pesticide applications? 


The school principal (or site director) or the principal’s/director’s designee is responsible for the notification process. Some school districts may designate the maintenance director or IPM coordinator to handle the notifications.

How often must parents/guardians and school staff be notified? 


All parents, guardians, and staff must receive notification once a year (annually) for all scheduled pesticide applications. Most schools send this notification out at the beginning of each school year. Part of the annual notification should include a section informing parents, teachers, and staff of their right to receive 72-hour advance notice of any unscheduled pesticide applications using a non-exempt pesticide or non-exempt method of application.

Must every parent, guardian, and school staff be notified of pesticide applications at every site in the school system? 


At a minimum, parents and guardians must be notified about school buildings, grounds, and sites where their children attend. They may also request notification for any other site(s) of concern to them. Similarly, staff members must be notified for the facility (or facilities) where they work and for any other sites of concern to them. 


Are schools required to post notices in areas of a school/building when it is scheduled to be treated?

 No. At this time, the School Children’s Health Act does not require that schools post notices in areas of school property that may be treated during routine pest control services.

What pesticides, formulations, or application methods are exempted from notification? 


Self-contained baits (such as cockroach bait stations snf ant bait stations), disinfectants, biological cleansers, and pesticides applied to cracks and crevices (i.e., not to exposed surfaces). In addition, all formulations and application methods for products classified by the U.S. Environmental Protection Agency (EPA) as Toxicity Category IV pesticides (i.e., pesticides that do not require “Caution” signal word on the product label) are exempted from notification.

Does the notification requirement apply when we use products purchased at local retail stores?
 

Yes. Notification is required for all non-exempt products (and non-exempt application methods), regardless of whether you use professional products or those available to the general public at retail stores.

Are we required to notify parents and staff about herbicide treatments to football fields or other areas of school? 


Yes, herbicide treatments (both granular and liquid formulations) on school grounds are subject to the notification requirements.

Where does the principal or principal’s designee obtain the information for pesticide use notification purposes? 


The superintendent is required to designate an IPM coordinator for the entire school district. Principals can get pesticide use information from the school district’s IPM coordinators. If your school district does not yet have a designated IPM coordinator, contact the facilities or maintenance director for pesticide use information.


Where can I find sample notification letters or forms? 


Sample notification forms are available at the NCSU School IPM website resource page.

Four sample forms are available: Sample Annual Notification form, Sample Request for Notification form, Sample Emergency Notification form, and Sample Non-exempted Pesticide Application form.

How does the principal determine who wants the 72-hour advance notification? 


The annual notice (Sample Annual Notification form) should be accompanied by instructions for requesting 72-hour advance notification (Request for Advance Pesticide Use Notification form) for non-exempt pesticide applications. The principal (or designee) can then prepare a registry of names and contact information of parents, guardians, and staff requesting the advance notification for future use. Some school districts may find it easier to notify every parent, guardian, and staff member about a non-exempt unscheduled pesticide application any time that one occurs at their school/facility. The advantage of this approach is that it eliminates the need to keep track of who has requested advance notification. This is a matter that your school board may wish to address in formulating its IPM policy.

Note: If no one requests notification of unscheduled pesticide applications, then the school is not obligated to send out notices other than the annual notice.

Is there a specific method of notifying parents, guardians, and staff about pesticide applications?


There is no required method for notifying parents, guardians, and staff about pesticide applications. Annual notifications can be distributed along with other routine information that is distributed at the beginning of the school year. The 72-hour advance notice may pose more of a challenge. In many cases, school districts already have an effective means of notifying parents, teachers and staff about time-sensitive issues. Here are some examples of methods through which schools can notify parents, guardians and staff:
  • Voice-mail: Many schools now use voicemail notification systems to leave messages for parents and staff 
  • Email/text messages to parents and guardians 
  • Bulletin boards: Written notices posted on school bulletin boards (for annual notification rather than as the primary means for unscheduled/emergency applications) 
  • Individual notices (primarily for staff) through inter-office mail, e-mails, and in-house PA/TV announcements 
  • Websites: Pesticide use information can be posted on school websites, although there is no guarantee that users will check the site in a timely manner for specific pesticide applications. The sample notification forms, list of pesticides, MSDS & labels, and other relevant information can also be posted on the website for easy access. 
  • Student-Parent Handbook: Pesticide notification information can be included in school documents (this could be used for annual notification) 
  • Employee Handbooks: Pesticide notification information can be included in school documents 
If we follow all the notification guidelines and the 72-hour advance notification, can the parents, guardians or staff who receive advance notification prevent the school from applying the pesticides? 


If a pesticide treatment is deemed necessary, then schools should work with the parents, guardians, and staff to provide alternate arrangements such as allowing the student or employee to remain home or work elsewhere around the timeframe when the treatment is made. Or the school may try to postpone the treatment to a date when the building will be closed for an extended period of time (for example, a weekend or holiday). Note: Except for true emergencies, rarely is there a need for a non-exempt treatment to take place during school hours. In many cases, an exempt product/application method can be done as a temporary measure. Regardless of the situation, most pesticide labels require (or at least recommend) that the room/area be unoccupied during and immediately after the treatment.

Is notification required for a members of a visiting school attending a sporting or other event or for private athletics organizations (such as youth football or little league baseball groups) using the school’s facilities? 



No. Because these groups are not sponsored by the local school, the school is not obligated to notify them of the pesticide applications but can do so as a courtesy or general policy.

Do the notification requirements also apply to staff at non-school administrative sites? 



Yes. The School Children’s Health Act covers all school district property. As such staff at all school district sites, whether they work in a school or an administrative building must be notified accordingly when pesticides will be applied in their workplace. 


Should parents, guardians and staff be notified in summer when students are not at the school site? 


Parents and guardians do not need to be notified in summer, unless the students are using the buildings, fields or facilities for normal academic instruction (summer school or year-round instruction), or for school-sponsored or organized extracurricular activities. However, staff working year-round in the schools or locations must be notified.


We hope this set of “Frequently Asked Questions” helps clarify the procedures for notification in schools. If you have any questions, please do not hesitate to contact Patty Alder at patricia_alder@ncsu.edu.
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