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Integrated Pest Management

Integrated Pest Management Policy Statement

Approved by the Board of Trustees on August 29, 1995

Structural and landscape pests can pose significant problems to people, property and the environment. Pesticides can also pose risks to people, property and the environment. It is therefore the policy of the El Paso Independent School district to incorporate integrated pest management procedures into the maintenance program conducted by our district for control of indoor and outdoor pest problems.

Definitions
Pests are populations of living organisms (animals, plants and microorganisms) that interfere with use of school facilities for human purposes. Strategies for managing pest populations will be influenced by the pest species and whether that species poses a threat to people, property or the environment.

Integrated pest management, or IPM, is a strategy that focuses on long-term prevention or suppression of pest populations using a combination of tactics that minimize the impact of control activities on human health and the health of other, non-target organisms.

An IPM plan is a set of procedures detailing how particular pest problems will be handled by District IPM Staff. The IPM plan for a particular facility will include descriptions of planned activities to reduce pest presence or maintain a pest-free environment. Details within such plans may include needed facilities or landscape improvements, pest-proofing modifications, approved nonchemical and chemical control activities, a pest monitoring plan, education plans and criteria for evaluating the need for control or the success of control efforts.

Pest Management
The District has appointed an IPM coordinator whose duties include the development of IPM plans for both indoor and outdoor school district facilities. IPM plans are designed to accomplish the following objectives:

Reduce any potential human health hazards or protect against a significant threat to the safety of students,staff or the public.
Prevent loss or damage to school structures or property.
Prevent pests from spreading into and adversely affecting the community or to plant and animal populations beyond the site.
Enhance the quality of life for students, staff and the public.

Essential IPM Plan Components
The District's pest management plans will include the following components:

All activities designed to reduce pest populations will be based on an accurate determination of the pest's identity and on knowledge of the pest's biology and life cycle.
Significant, recurring pest problems will be observed and recorded by IPM staff using monitoring methods so that pest populations can be detected and control measures applied to the appropriate sites.
Predetermined action thresholds for important pest problems will be determined by IPM staff, so that results of inspections and monitoring programs can be used to help staff objectively determine when control actions are justified.
The full range of control options including physical controls, mechanical controls, biological controls and chemical controls (including the option of "no action") will be considered when deciding on a pest management action.
Educational activities will be conducted to gain cooperation and understanding among district staff, students and the public.
Record keeping – records of pesticide use shall be maintained on-site to meet the requirements of the State Regulatory Agency and School Board. In addition, pest surveillance data sheets that record the number of pests or other indicators of pest populations are to be maintained to verify the need for treatment.

Pesticide Use in School Facilities
The decision concerning whether or not to apply a pesticide will be based on a review of all other available options and a determination that these options are not acceptable or are not feasible. Cost or staffing considerations alone will not be adequate justification for use of chemical control agents. Efforts will be made to avoid the use of pesticides by adequate pest-proofing of facilities, good sanitation practices, selection of pest-resistant plant materials and good horticultural practices.
When it is determined that a pesticide must be used in order to meet important management goals, the least- hazardous materials adequate for the job will be chosen.

Cooperation with IPM Coordinator
The District will provide administrative support to the IPM coordinator for developing an IPM program that relies on minimal pesticide use. Such support will include efforts to address in a timely fashion, as budgets permit, any structural, horticultural and sanitation modification recommended by the Coordinator to reduce or prevent pest problems. Furthermore, the District will assist the Coordinator in developing and delivering materials and programs for staff, students and the public to educate them about the importance of sanitation and pest control.

Contractual Agreements with IPM Providers
All outside contractors providing pest control services will be required to follow the same IPM standards required for in-house staff. All contracted pest control activities will follow IPM plans based on the IPM components outlined above. The District will take steps to ensure that selection of contractors includes consideration of the contractor's ability to provide satisfactory IPM services in addition to price considerations.

Facilities Planning
The District shall include pest management considerations in facilities planning. Such considerations include, but are not limited to, the planting of well-adapted and pest tolerant plant varieties outdoors; landscape designs that require minimal fertilizer and pesticide inputs; proper placement and types of lighting to reduce pest entry into buildings; placement of dumpsters; storage of pesticide products; and pest-proof design of doors and ventilation systems.

Cooperation with Regulatory Agencies
All pesticide storage, transportation and application will be conducted in accordance with the requirements of the:

Federal insecticide, Fungicide and Rodenticide Act (7 United States Code 136 et seq.)
Environmental Protection Agency regulations in 40 CFR
Occupational Safety and Health Administration regulations Texas Structural Pest Control Act (Article 135B-6 of the Texas Revised Civil Statutes) with associated regulations (Title 22, Texas Administrative Code, sections 591-599)
School district policies and procedures, and local regulations

State regulations followed by the District include requirements to notify students, staff and parents about pesticide applications; keeping proper pesticide application records, including copies of labels and Material Safety Data Sheets (MSDS) for all pesticides used on school facilities; adherence to a 12-hour waiting interval between pesticide application and student occupation of treated facilities; use of least-hazardous pesticides according to the pesticide approval process for schools; and licensing of all staff who apply pesticides. No person shall store or apply any pesticide on school District property without an appropriate commercial or noncommercial pesticide applicator's license.

All pesticide applicators must be educated and trained in the principles and practices of IPM and the use of pesticides approved for use in the school District. All applicators must comply with this IPM policy and follow appropriate regulations and label precautions when using pesticides in or around school facilities.

Custodial and Maintenance Department Support

The Custodial and Maintenance Department personnel shall coordinate efforts to make all necessary campus improvements to aid in minimizing pest infestations.

Campus custodial personnel shall routinely inspect their campus buildings noting areas that require repair, i.e., foundation cracks, door thresholds, window seals, ceiling and wall penetrations, and any other situation that can potentially allow access into the school buildings.

The Maintenance Department shall be notified via the District's Maintenance Work Order system of the necessary repairs.

In accordance with Departmental procedures each campus shall be cleaned and maintenance of any trash, debris, and/or unwanted vegetation.

Dining and Lounge areas shall be kept clean at all times. Stored food shall be kept in airtight containers.

In accordance with the District's Garbage Collection Contract and schedule the campus dumpsters shall be emptied and kept in an acceptable condition.

The campus lawns and playing fields shall be maintained in order to prevent the harborage of unwanted pests.

INTEGRATED PEST MANAGEMENT PROGRAM

The services as specified in paragraph A will include the extermination and control of ALL RECOGNIZED PESTS (rodents, roaches, spiders, ants, flying insects (less flies), etc.), EXCEPT pigeons, termites, will be provided on an "As Needed" basis.

A.	SERVICES: This IPM program will require the Contractor to perform four (4) distinct services as follows:
	1. Summer Service
	2. "As Needed" Services
	3. Monthly Kitchen and Cafeteria Services
	4. Pigeons and Termite Services

Summer Service: All installations, except for the EPISD Owned Administrative Campuses, will be serviced as prescribed below, during the periods of June to August. (A meeting with the Contractor will be held in May to coordinate the Summer Service.) Summer Service will be provided by the Contractor in accordance with the district's contract document.

					a.	Building Exterior: All exterior perimeters will be inspected and serviced under the current IPM guidelines. This service will include the exterior wall as well as an area five (5) feet from the building.
					b.	Classroom and Administrative Offices: A complete IPM inspection and service will be performed throughout the installation to include all classrooms, offices, labs, restrooms, closets, storage areas, boiler rooms, gyms and custodial quarters.
					c.	Kitchens and Cafeterias: A complete IPM inspection and service will be performed throughout the kitchens and cafeterias and shall include snack bars, storerooms, restrooms, dining areas, and boiler rooms.
					d.	Pest and Sanitation Checklist: Upon completion of the inspections, the Pest and Sanitation Checklist will be submitted to District personnel with any recommendations to reduce pest populations noted. The checklist will be reviewed by District personnel with Buildings and Grounds issues being addressed by the District's maintenance department.
					e.	EPISD Owned Administrative Campuses: Will be on an "As Needed" Service basis year round.
					f.	Summer Service Warranty: Service Companies will re-service, at no charge, any areas requiring additional services at schools from the date of service until August 11th.
					g.	Service Schedule: Summer Service shall begin two days after the last day of school or June 1st, whichever is later, and shall be completed within 60 calendar days. Summer Service shall be conducted Monday through Friday, from 7:00 a.m. to 5:00 p.m. with the exception of District Holidays, i.e. July 4th.
					h.	Service Coordination: Contractor shall coordinate/schedule the Summer Service so as to minimize the inconvenience to the school operation during the summer and still allow for the application of pest control product. Under no circumstances shall the Contractor conduct product applications when students are present.
					i.	Summer Programs: A number of programs are typically conducted during the summer months. These programs include Instructional Program Summer School, Food Service Programs, Recreational Programs, Fine Arts Programs, Special Education Programs, etc. The custodial staff is on duty from 7:00 a.m. to 5:00 p.m. Food service staff is on duty between the hours of 7:00 a.m. and 2:00 p.m. Instructional staff is on duty at elementary and middle schools between the hours of 8:00 a.m. and 1:00 p.m. Staff at the high school level is on duty between the hours at 8:00 a.m. and 2:00 p.m.

"As Needed" Services: Requests for pest control services during the school year for school classrooms, administrative offices, gymnasiums, and grounds will be on an "as needed" basis. "As Needed" services will be provided at the request of the District.

Definitions:

1)	Room - Classroom, office, restroom, storage or maintenance area, nurse's office and boiler room.
2)	Gymnasium - Separate athletic buildings on school campuses which include locker rooms, showers, restrooms and boiler rooms.
3)	Grounds Areas - Athletic fields, building lawns, playgrounds, driveways, and sidewalks.

Service for all areas will follow current IPM guidelines. Any request for use of a Red list product must be approved by the District's IPM coordinator(s) prior to use. The service company is expected to totally resolve any pest problems regardless of the number of call backs or number of man hours required for each individual "as needed" service request for the unit price(s) proposed.

Requests for "as needed" services will be made by the EPISD IPM Coordinator(s) ONLY. Persons, other than the IPM Coordinator(s), requesting pest control service will be referred to the designated person.

Kitchens and Cafeterias: To include snack bar, kitchen storerooms, restrooms, boiler rooms, and feeder cottages. Monthly service of each kitchen cafeteria complex. Service companies shall allow that a minimum of three (3) weeks will elapse between each monthly service call. Kitchen and Cafeteria service will be provided at the request of the District.

					a.	Service Calls: Will be made Monday through Friday between the hours of 2:30 p.m. and 4:30 p.m. utilizing current IPM guidelines. Any request to use Red list products must be approved, in writing, by the District IPM Coordinator(s) prior to treatment.
					b.	The kitchen-cafeteria complexes will be serviced eleven months, beginning September 1st. Service companies will bill the cafeteria separately each month, except the month in which the school summer service is performed. For this month the cafeteria charge will be included in the summer service charge.

			4.	Pigeons and Termites Service: Requests for these services will be on an "Additional Cost Service" basis. A written estimate will be required for these additional cost services. The vendor selected for pigeon control must write a letter to The City–County Health Department, and state the location of the pigeons, the control substance to be used, the period of time for which it is to be used, and the resulting effectiveness.
			5.	Work Schedule: Service Companies will deliver to the EPISD Facilities Department, a work schedule for the summer services, to include schools and dates, thirty (30) days prior to commencement of summer services, i.e. May 1st. A work schedule for monthly kitchen service will be delivered ten (10) days prior to the beginning of the following month.
			6.	Sanitation Report: Contractor will complete a Sanitation Report (form provided by the El Paso Independent School District) for each service performed at each installation. Reports are to be forwarded to El Paso Independent School District, Facilities Planning at P.O. Box 20100, El Paso, Texas 79998. Contractor is to telephone (915)887-5105 as soon as possible regarding any major or critical pest control problems. All reports are to be specific and include recommendations for corrective action needed.
			7.	Service Reports: Service representative will provide Owner with a service report for each service call.

					a.	Service Calls: Will be made Monday through Friday between the hours of 2:30 p.m. and 4:30 p.m. utilizing current IPM guidelines. Any request to use Red list products must be approved, in writing, by the District IPM Coordinator(s) prior to treatment.
					b.	Kitchen and Cafeterias: Reports will be signed by the kitchen manager. In her absence the report will be signed by the custodian.

Call Back Service: Repeat service calls for buildings and grounds or as needed for the kitchen and cafeterias will be made at no additional charge when REQUESTED BY THE IPM COORDINATOR(S). Excessive recalls (3 or more) to the same school for the same problem in the same month, may be cause for termination of contract services.

Companies must submit.

1.	A product list of all EPA approved chemicals proposed to be used under this contract.
2.	Current Texas pest control license.
3.	Current Texas license of all applicators and technicians.
B.	Product Labeling: All products must be registered with the Texas Department of Agriculture (TDA) and with the Environmental Protection Agency (EPA). The label must include the EPA registration number and an EPA establishment number. The label must also show whether the product is for general use or restricted use. The label shall include the following basic minimum information:

	1.	The site, crop, or animal to which the product is applied.
	2.	The specified pest or pests controlled by the product.
	3.	The situation, location, and conditions under which the products should be used.
	4.	Rate and equipment requirements.
	5.	How to apply the product.
	6.	When to apply the product.

	In addition, all pesticide labels must include the words "Keep Out of Reach of Children." All highly toxic pesticide product labels must also include information for physicians on proper treatment for poisoning.
	It is understood that under the requirements of federal and state law is the provision that the use of products inconsistent with their respective label directions is a violation of the law and the contractor may be subject to penalties under federal and state law.
C.	Special Labeling: It is required that labeling directions are strictly followed. Certain products are prohibited for use in specific areas. Products labels as such, i.e. not for use in school buildings, cafeterias, food handling areas, etc., will be specifically adhered to and are not allowed for use in these prohibited areas.
D.	MSDS: Material Safety Data Sheets shall be supplied to the District by the Contractor on all chemicals/pesticides intended for use in extermination services for EPISD prior to their application. MSDS shall be kept in Facilities Planning at EPISD Education Center – Boeing.
E.	Asbestos Location Awareness: Each visiting Contractor is required to review the existing Asbestos Management Plans on file at each school. Contractor is required to review and understand in detail the location of asbestos containing material (ACM) as defined by the existing plans. Contractor is required to sign a waiver at the site stating Contractor has reviewed the plan(s) and understand it and assume responsibility for the training of Contractor's own personnel complying with AHERA guidelines and regulations. It is mandatory Contractor understand this waiver and accept responsibility for Contractor's personnel.
F.	Identification Tags: The certified applicator and the certified technician are required to wear and present their identification badges showing registration with the Texas Structural Pest Control Board including social security number and category registration. All services contract personnel are also required to carry an EPISD identification tag issued by the District's Media Center. The cost of the EPISD badges is borne by the District. All personnel are required to sign-in at the Principal's office upon entering the premises.
G.	Equipment: Equipment must be maintained in a condition that will provide safe and proper pesticide application. All application equipment is subject to inspection by an EPISD official at any time during normal operating hours.
H.	Containers: The product label shall determine the proper container which the product shall be transferred/ filled with and sprayed from. All containers must be thoroughly cleaned prior to transferring/filling the product into the container. Thoroughly cleaned means "Absolutely no residue of any product previously in the container," except in the case when the same identical product is being used. The mixing of products is strictly prohibited and the application of any mixed products is justification for immediate termination of the contract. In the event of any questionable application, or reasonable suspicion, a certified laboratory will be employed by the District, to take a sample, analyze and determine the end product used by the Contractor.
I.	Product Application: The Environment Protection Agency (EPA) classifies the use of pesticides as either Restricted or General. A restricted use pesticide or a state limited use pesticide may be applied only by or under the direct supervision of a certified applicator. The product label governs. In some cases, the product label requires the actual physical presence of the certified applicator.
J.	Product Application: Disposal of pesticides is governed by the labeling of the product. If the label does not instruct the proper disposal method, the Contractor must contact the TDA or EPA, whichever governs. Any pesticides intended for use in extermination services for the EPISD but not used shall remain the property and responsibility of the Contractor. The Contractor retains chain of custody of the product and it is the Contractor’s responsibility to dispose of the product in a lawful and appropriate manner.
K.	Records: The Contractor shall be responsible for maintaining a pest control logbook or file or each building or site specified in this contract. These records shall be kept on school district property (normally in the Principal's office or some other convenient site) and maintained on each visit by the Contractor. Each logbook shall contain the following items:

		1.	Pest Control Plan: A copy of the Contractor's approved Pest Control Plan for that facility, including labels and Material Safety Data Sheets for all pesticides used in the building, brand names of all pest control devices and equipment used in the building and the Contractor's service schedule for the building.
		2.	Service and Complaint Logs: A logbook for recording service visit activities, complaints from staff concerning pest sightings or pesticide applications. Forms should show times in and out and must be signed by the Contractor at each service visit.
		3.	Service Report Forms: Customer copies of the Contractor's Service Report Form, documenting all information on pesticide applications, pest sightings, sanitation/environmental status and building maintenance needs.

	In addition, copies of the above mentioned Service Report Forms should be forwarded by the Contractor to the IPM Coordinator at least once a month.
L.	Damages: Damages, if incurred, will be filed by EPISD against the applicator to the regulatory agency (SPCB) within thirty days of an alleged occurrence. The damage assessment to the land or nontarget organism(s) will be performed by the regulatory agency. Should damage be established, immediate remedial actions shall be the responsibility of the party causing damage.
M.	Pest Control Treatment Notification: The Contractor shall fulfill all obligations with regard to posting, as required by the Texas Structural Pest Control Board. The Contractor will be responsible to post, in a prominent location, pest control signs in fulfillment of obligations under Texas laws and regulations. In the event of emergency application, the District will display the pest control sign in a prominent location at the time of treatment.
N.	Pesticide Application Waiting Period: Pesticide applications shall not be made within a school building if such an application will expose students to pesticide fumes or drift within the next 12 hours. Green list products may be applied at any time if students are not present in the room at the time treatment is occurring. Green List products may be applied to an open area or multi-purpose room if the area within 10 feet of the application site is secured and no students are present within the secured area during the time of application. Yellow list products may be applied to a room if students are not expected to be present for the next 12 hours. All other products may be applied only if students are not expected to be present in the building for the next 12 hours.
O.	Emergency Treatment: The pre-notification provision can be waived if the District and certified applicator sign a statement attesting to the fact that an emergency exists that requires immediate treatment. If such an emergency exists, signs must be provided by the licensee at the time of application. The statement must be kept on file with the pest control use records at the business license location. If the customer is not available to sign a statement at the time of treatment, the customer's name and telephone number shall be noted in the pest control logbook or file.
P.	Complaints: Should the District become dissatisfied, at any time, with pest control services, the Contractor shall be notified in writing by the IPM Coordinator regarding the problems. The notice will detail the problems and site(s) where the problems have occurred. The Contractor will be required to contact the IPM Coordinator to discuss possible solutions and the Contractor will be given a date by which a written response with proposed solutions must be submitted.

MONTHLY KITCHEN SERVICE PROCEDURES

Approximately two weeks into the current month, a monthly schedule for the following month is received from the contractor. Upon receipt, the schedule is copied and mailed to the individual cafeteria managers by the IPM Coordinator. Check to ensure that the scheduled times are between the hours of 2:00 and 3:30 p.m.

48 hours prior to service, the contractor will fax or post the required 48 hour notification in a prominent location in the cafeteria, i.e., manager's office or locker room.

Contractor will arrive at the scheduled time and report to the cafeteria manager or the head custodian. If available, the contractor will briefly interview the kitchen manager to determine problem areas. Also, the "Pest Sighting Log" will be checked by the contractor to determine areas of pest concentrations. Contractor will initial the "Pest Sighting Log" and commence with the service.

Monitoring stations (i.e., glue boards) will be checked and replaced as required. If the monitoring stations contain numbers that exceed the threshold, green list products may be applied at the discretion of the applicator. Under no circumstances are red list products to be used without the written consent of the IMP Coordinator. Yellow list products may be used with written approval from the Certified Applicator.

When service is complete, contractor will obtain an official signature from either the kitchen manager or the head custodian; whichever is available. Also, the "Pest and Sanitation Checklist" and the "Extermination Report" will be completed. At the end of the month, verify that a signature was indeed obtained prior to approving payment.

Any calls from the kitchen manager regarding pest control issues will be addressed immediately by the contractor. This is done immediately to ensure that all district cafeterias are in compliance with health regulations. In the event that a health inspector finds a significant pest problem, the contractor will dispatch a technician immediately to avoid further actions by the health department.

On average, use of the following list should be used to estimate the minimum amount of time to be spent at each cafeteria:

Elementary Schools 45 minutes for 1 technician
Middle/High School 1 hour for 1 technician

AS NEEDED SERVICE PROCEDURES

Receive complaint from school noting type of pest and location. Log complaint into the "Integrated Pest Management Log".

Report problem to contractor. If pests are a health hazard to staff or students, contractor is authorized to apply green list products at their discretion. Under no circumstances are red list products to be used without the written consent of the IPM Coordinator.

In non-hazard situations, contractor will respond by placing monitoring stations where pests were observed. No application of product is allowed at this point.

Between 24 and 48 hours later, contractor re-visits the location to determine if thresholds have been exceeded. The Pest and Sanitation Checklist is completed at this point by the contractor. This checklist will note any areas the contractor feels maintenance issues need to be addressed to reduce pest populations.

If thresholds have been exceeded, application of green list products are allowed. Otherwise, no application of product is allowed.

BILLING PROCEDURES

Contractor should submit invoices, in duplicate, to the IPM Coordinator. With the invoice, the pink copy of the "Extermination Report" and the "Pest and Sanitation Check List" should be attached.

If yellow or red list products were approved for use, a copy of the "Pesticide Approval Form" should be attached.

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The El Paso ISD does not discriminate in its educational programs or employment practices on the basis of race, color, religion, sex, national origin, age, disability, military status, or on any other basis prohibited by law. Inquiries concerning the application of Titles VI, VII, IX and Section 504 may be referred to the district compliance officer, Vincent Sheffield, at 881-2619; Section 504 inquiries regarding students may be referred to Cecilia Whiteman at 881-2527.

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