Pest Management Guidelines Proposed For Schools, Day Care Facilities In Tennessee

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 Subject:   Pest Management Guidelines Proposed For Schools, Day Care Facilities In Tennessee
 Date:      Wed, 9 Jan 2002 09:56:32 -0500
From:        Stephen Tvedten <steve@getipm.com>
Organization:     Get Set Inc. (www.getipm.com)

To:     Paul Helliker <phelliker@cdpr.ca.gov>
          Director, State of California, Department of Pesticide Regulation 

cc:    Christine Whitman whitman.christine@epa.gov

Dear Mr. Helliker,  I thought you might like to read the following article:  Pest Management Guidelines Proposed For Schools, Day Care Facilities In Tennessee.

By State Gazette.com 1/4/2002 URL: http://www.pctonline.com/news/news.asp?ID=989/

NASHVILLE — Tennessee legislators have introduced bills requiring schools and day care facilities to adopt Integrated Pest Management (IPM) programs. The two  bills are scheduled to be considered by subcommittees after the General Assembly reconvenes this month.

One of those bills — House Bill 1180/Senate Bill 1566, which requires all public school systems to institute an IPM program — has been referred to the K-12 subcommittee of the House Education Committee. The other bill — Senate Bill 1331 and House Bill 591, which requires an IPM program in day care facilities — has been referred to the small business subcommittee of the Senate Commerce Committee.

The bills may have trouble gaining approval this year. The Select Oversight Committee on Education — a group of senators and representatives who make recommendations to their respective education committees — asked for comments on the IPM program for schools bill Dec. 18. Stephen Smith, the Tennessee School Boards Association's government relations specialist, said no one spoke in favor of the bill.

Smith said the proposed legislation "requires schools to follow very prescriptive and time-consuming reporting procedures. These requirements could place a significant and unnecessary burden, not to mention cost, on school systems and school personnel."

The bill would require schools to give parents and staff members at least 72 hours notice before a pesticide is used in the school building or on the school grounds. The notice is to include: a description of the pesticide that will be used; when and where it will be applied; a description of potential adverse effects of the pesticide; reasons why the pesticide is being used; the name and phone number of a contact person at the school; and an EPA warning that pregnant women and infants should avoid pesticide exposure.

Smith is concerned that the notification requirement could also open school systems to increased liability and litigation if, for some reason, a parent didn't receive the notice. Besides, he said, "We're not aware of any problem ever reported with pesticides in schools."

All schools must follow EPA and Tennessee Department of Agriculture rules on pesticide use. "If there's a problem, we'd rather have them addressed through the rules," he said.

Dyer County School Superintendent Dwight Hedge said all county schools have termite contracts and other pest problems are addressed on an as-needed basis. The school system contracts the services through a pest management company. Hedge said he believes the county school system is the biggest food provider in Dyer County, and therefore, obviously needs to control pests. He doesn't want his options to be limited by excessive state regulations. He pointed to California, which requires schools to use an IPM program. He said he has heard that California schools are overrun with pests because the schools can't use the pesticides they really need.

"I don't see that we need any additional regulations from Nashville on that," he said. "The system we have is working really well. I know pest management has to be an on-going program to manage pests. Apparently what we do works really well. I don't remember any complaints."

Dyersburg School Superintendent Lloyd Ramer said he delegates pest management responsibilities to the maintenance supervisor and was unaware of the IPM recommendations. But, he said he'd be willing to consider them. The school system currently contracts with a pest control company that has been instructed not to apply any pesticides while students are present, he said. Dr. Karen Vail, an urban entomologist with The University of Tennessee Agricultural Extension Service, said most people believe that an IPM program makes sense.

She and other UT professors have developed "Kids, Pests and Chemicals in Tennessee," a program designed to raise awareness about pesticides and their potential effects on children. They held seminars in each region of the state last year. This spring, they hope to have a statewide conference. Vail is skeptical that the General Assembly will pass either of the proposed IPM bills.

"I think many folks don't want a law forcing these rules upon them," she said, noting that they believe the rules will reduce their flexibility in dealing with pest problems. "But, adoption (of IPM programs) has been very slow without them."

Vail worked with the Tennessee Department of Agriculture in 1996 to develop a recommended IPM in Schools program. She said she sent letters to all 149 public school systems and to all county and district extension offices. The idea has been presented to 485 pest management professionals, 189 vocational agricultural teachers, more than a thousand pest management professionals, more than 98 adult agricultural extension agents and others. Copies of  extension publication PB1603, "Managing Pests in Tennessee Schools: Adopting Integrated Pest Management," also was sent to all public and private primary and secondary schools in the state that year.

A follow-up survey in 1997 showed that 11.7 percent of the state's school systems had adopted an IPM program, and most of those schools were in urban areas, she said.

"We've had a hard time getting the attention of schools," she said. Sometimes it takes more than a suggestion, more than a warning. Vail described what happened at a Texas school. To fight an outbreak of head lice, school officials ordered that the school be sprayed with a pesticide usually used on lice-infested cattle. The children complained of headaches and nausea. The school was closed for four days and the building was decontaminated. "We're just trying to prevent a mishap like that," she said.

Well Mr. Helliker, are your California schools really overrun with pests because you will not let the schools use the pesticides they really need? It seems to me you have clearly said that you will only allow the use of "registered" POISONS to "control" pest problems.

I really love Mr. Lloyd Ramer's next comments:  "I don't see that we need any additional regulations from Nashville on that," he said. "The system we have is working really well. I know pest management has to be an on-going program to manage pests. Apparently what we do works really well. I don't remember any complaints."  I have consistently proven that true IPM pest management does not have to be an on-going program to "manage" pests.  This statement of his, is proof that what they are doing in Tennessee is not "working really well", if it was "working really well", "they would not have to keep on "treating".  I would like to point out that if his comment that he does not "remember" any complaints, would change dramatically if he started to notify the parents.  Notification lets the parents clearly see that their child became ill (POISONED) right after (each) spraying of your "registered" POISONS!  This is what scares the h-ll out of the POISON "industry" and apparently some educators.

Safely solve the cause of the various pest problems and you will stop the needless ongoing POISONING of the children! The hundreds of schools that I have worked on no longer use/misuse any "registered" POISONS and they no longer have any ongoing pest problems.

Is it now "legal" to use these safe and far more effective (unregistered) alternatives in your schools that are supposedly now overrun with pests?  If you will now "legally" allow the use these safe, economical and far more effective (unregistered) alternatives, no parents will need to be notified, no "registered" POISONS will need to be routinely sprayed and no children or staff will need to be continually contaminated and you will economically and  safely solve all of your ongoing pest problems!  My Mother taught me true IPM when I was about 4 years old, she said: Stephen, if you will simply shut the door, you will not let in the flies."

Respectfully,  Stephen L. Tvedten


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