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General Guidelines (companion document) for Development of an Integrated Pest Management (IPM) Plan
(complying with the Act to Protect Children and Families From Harmful Pesticides)

The law mandates that schools must follow an Integrated Pest Management approach to pest control, and that each school have an IPM plan. An IPM Plan for a school should not be a complicated document. It is simply an overview of a schools approach to pest control.

IPM focuses on preventing pest problems rather than reacting to them. Preventing pest problems in a school entails minimizing pest access to the building and the food and shelter available to it. Consequently, IPM relies heavily on the cooperation and participation of the people who inhabit and maintain the school building, not just the pest control contractor.

You should follow and include in your IPM plan(s) the following:

1). General School Information-Although self-explanatory, your IPM plan should incorporate this important information into each IPM plan (for both the indoor and outdoor plans).

2). School IPM Coordinator, Leader, or Supervisor- The IPM Coordinator is the individual within the facility who is generally in charge of pest control activities for the school. This individual is someone who has the authority and backing of the school administration or management. Finally, this individual will have the primary responsibility for ensuring that the IPM plan is carried out. Ultimately, this person is tied directly to the integration of all IPM activities through the coordination and communication of all parties including but not limited to custodial, building, food service, outside vendors, the pest control contractor, grounds staff, students, parents, and teachers. For example, the school may designate their facility director as the IPM Coordinator.

For an outdoor IPM plan, the IPM coordinator might be the head groundskeeper or athletic director. The IPM Coordinator will typically be the facility manager, or head custodian. A successful IPM program relies heavily on the cooperation of all who maintain and inhabit a building. As such, the IPM Coordinator should have some decision-making authority concerning the maintenance of the school property. If something is occurring in the school, which is contributing, to pest problems (for instance broken screens on windows), the IPM Coordinator should have the ability to have the problem remedied.

The Pest Control Contractor cannot be the IPM Coordinator. The IPM Coordinator must be someone directly employed by the school. IPM plans are essentially public documents. The title of the IPM Coordinator is necessary so that people reviewing the plan understand this person's overall role within the management of the school. A phone number is required so that if readers have questions or concerns, they have someone to contact.

3). School IPM Committee or Team-IPM committee or team members are individuals who have interests/concerns or who are involved in activities directly or significantly related to pest control at the school. For a small daycare facility, the IPM Committee may be composed of just the IPM Coordinator. For a large school, the IPM Committee for an indoor plan might include the school nurse, a representative of the food service staff, a teacher representative, a custodian, etc. Outdoor plans might also include a representative of the school athletic department, a parks superintendent, or others who utilize the playing fields. It is recommended that any pest control, landscaping or turf care contractors hired by the school also be on the IPM committee or team.

Ultimately, the IPM committee or team should designate each member's role, develop a school IPM policy (see # 4), schedule meetings, and agree who will make the final decisions pertaining to pest management decisions.

4). School IPM Policy- Policy statements help set the overall goal of your school regarding pest management and pesticides. Basically, it is a statement of purpose pertaining to your IPM program. It should state the intent of the school administration or management to implement an IPM program for your particular school. Why does your school want to adopt IPM? It should briefly provide guidance on what specifically is expected--the incorporation of existing services into an IPM program and the education and involvement of students, staff, and pest control contractor.

Example: This IPM plan was prepared in response to the Children's Protection Act (Chapter 85 of the Acts of 2000), which requires a written IPM plan for both INDOORS and OUTDOORS. IPM is a common sense approach to pest management that uses a variety of methods to manage pests. Chemical pesticides may be part of this IPM plan. However, considerable effort will be put towards preventing pest problems by controlling conditions inside and outside the school, which may attract and support pests. This plan will improve existing pest control, improve indoor air quality and reduce the amount of pesticide used by the school for the purpose of protecting our children and employees

5). School Pest Problem(s) Description-Proper identification and inventory of your pest problems is critical to understanding its management and the prioritization and selection of the appropriate non-chemical and chemical treatment options. What is your most common pest problem(s)? Is it a new problem or has it been a historical problem? What specific areas inside and outside of the school are being impacted? What time of year do pest problems occur? Is the appearance of the pest problem related to specific structural deficiencies or sanitation problems? Is the current control program working?

6). School IPM Information Flow and Training-Communication is critical to the success of any IPM program especially a back and forth information flow. Your IPM plan should discuss your communication information flow. Describe how pest problems specific to your school will be reported. Indicate the type of method that will be used and specify location of a pest and/or service log? Indicate who in the school will be responsible for responding to the sanitation and building repair problems that are identified through inspection reports.

For example, if a kitchen staff member observes immature roaches in the cafeteria, s (he) should know whom to inform so that corrective actions can be taken. Conversely, the pest control contractor who observes pest conducive conditions should know who to inform such as the IPM Coordinator

Talking with the pest control contractor, maintenance, grounds personnel, food service workers, housekeeping staff, students, and interested parents about pest sightings, how to report these sightings, depends on a back and forth information flow.

Training is another essential element of your IPM plan. You should identify the individual(s) providing the training. You should indicate the employees or staff who will receive training. Your IPM plan should discuss the subject matter of training as well as the frequency of training.

Example: If the maintenance personnel do not recognize that non-chemical sticky traps are used as monitoring devices, these important tools may be thrown away. This action is contrary to IPM.

Example: Sanitation should not be viewed as only the maintenance personnel responsibilities. If students and staff are shown the connection between food, water, clutter, and pests, they are more likely to take sanitation seriously.

Describe the content and format of IPM related training. Also, describe specific training that particular individuals will receive.

Example: "The school or pest management contractor will provide an IPM training seminar to all facility staff on an annual or as needed basis. The training will include the information about the Children's Protection Act, Why IPM is important, pest reporting procedures, pest identification, monitoring, thresholds, sanitation, prevention actions such as stock rotation, use of service/pest log, and general pest reduction methods.

Some training will cover specific subject matter and only require the attendance of particular staff responsibilities. For example, (Joe Jenkins Head Custodian would attend a source reduction through sanitation training session. Jill Rogers, Food Service Director might attend IPM training on kitchen environments. John Downs, Waste Disposal Contractor Supervisor might attend a dumpster and waste disposal management session.

7). School Chemical Pesticide Use-Chemical pesticides should not be used unless both the pest has been identified and its presence verified. Chemical pesticides should only be used by a licensed or certified pesticide applicator (never by a teacher or unlicensed individual). Finally, chemical pesticides are generally used when other control methods are not effective or practical in resolving a pest problem. Discuss the use of chemical pesticides in your IPM plan. If you do not use pesticides, your plan should highlight this circumstance. Indoors, the law permits only certain pesticides such as baits.

Outdoors, your IPM plan must identify the product names and Environmental Protection Agency (EPA) numbers of those chemical pesticides you anticipate to use. This includes any potential emergency situation for example stinging insects. You can consult with your pest control contractor to assist you in listing the products that might be used.

8). School Non-Chemical Options-Your IPM plan should discuss those methods and practices that do not require the use of chemical pesticides such as Pest Proofing, Sanitation/Housekeeping, Trapping, and Light Management. These methods are long-term remedies to pest problems and ultimately prevent pests.

Example: Vacuuming can be an important part of a sanitation program removing food debris that pests may feed on. Also, it is a physical control that meets the objective of removing pests such as spiders or vagrant flies in sensitive areas such as classrooms or kitchens. Another example, might be installing a door sweep to exclude pests from certain areas such as a storage area. Finally, caulking and sealing of cracks and opening around pipes and utility wires can help exclude ants and roaches.

9). School IPM Program Evaluation-Your IPM plan should be a dynamic and working document. It should be evaluated on an on-going basis such as every three months or at least once a year. Is the IPM program working? What changes are needed if necessary? Your IPM plan will change over time as pest management performance fails or succeeds. It may also change as the result of new chemical pesticides and pest control technologies that are introduced to the marketplace. When an IPM plan does change, the entire plan must be resubmitted.

10). School Record keeping and IPM Plan Location*-Keeping good records such as pesticide use, service reports, logbook, posting and notification, emergency waivers etc and maps (especially for outdoor chemical uses) in a central location on site is essential to make available when requested.