Opportunity to Reduce Pesticides Used in Texas Schools

HB 2458 abolished the Texas Structural Pest Control Board (SPCB) so its functions will be placed under the Texas Department of Agriculture (TDA).  Texans for Alternatives to Pesticides (TAP) views this as a chance to make positive changes.    

We have an opportunity to change the board makeup, address conflicts of interest, board leadership and training.  Texans must take this opportunity to talk with elected officials so that the appointees chosen by Todd Staples, the Commissioner of Agriculture, are knowledgeable about Integrated Pest Management (IPM) and the health risks associated with pesticide use.  This new Advisory Board will be charged with writing new rules and regulations for the pest control industry.  This is the time to strengthen pesticide regulations.

TAP Recommendations to the Texas Department of Agriculture

Include a definition of IPM: IPM is a managed pest management system that: (a) eliminates or mitigates economic and health damage caused by pests; (b) minimizes the use of pesticides and the risk to human health and the environment associated with pesticide applications; and, (c) uses integrated methods, site or pest inspections, pest population monitoring, an evaluation of the need for pest control, and one or more pest control methods, including sanitation, structural repairs, mechanical and living biological controls, other non-chemical methods, and, if nontoxic options are unreasonable and have been exhausted, use least toxic pesticides. (Beyond Pesticides, 2004) (See PDF file)

Recommendations for School IPM based on the Pesticide Report Card:  Texas Schools Score from A to F in the Integrated Pest Management Program

http://www.consumersunion.org/food/pest_info.htm

• Mandate types of pesticides to be used, and restrict use of highly toxic pesticides.  Create a product or chemical list of acceptable pesticides to give all school districts clear guidance.

• Remove the emergency clause.  There is not enough evidence to show that schools need an emergency clause.  And given that it may be invoked at the school’s discretion, there is much room for abuse.

• Eliminate pesticide application when children are in school.  Ten to fifty-foot buffers will not adequately protect children and undermine the law, creating a situation where pesticide applicators decide when and where to apply pesticides at their convenience rather than for the safety of the children.

• Prohibit regularly scheduled, or “calendar,” pesticide applications as part of IPM.  It is possible that districts are spraying pesticides on a regularly scheduled basis.  Calendar applications are not using integrated pest management.

• Reclassify the Green List All pesticides that get classified as Green must also bear the signal word Caution. Under the current regulations the Green List category allows for botanicals with no more than a 5% synergist. Botanical pesticides include all pesticide products that come from nature.  Under the current regulation that allows products like rotenone, nicotine, and some other concentrated products usable under the Green category. These products have the signal word of Warning or Danger, it is our belief that Green should signify low-toxicity. This simple change to wording in the regulation will allow schools to always make the smart choice when it comes to using a pesticide when necessary.

• Require schools to use standard reporting formats issued by the Department for all school districts to follow, including:
• Chemical name
• Active ingredient
• Chemical company name
• EPA registration number
• Description of the pest problem (that includes numbers of pests or other indicators of pest populations)
• Justifications for use
• Percent solution (when applicable) and amount used
• Application technique
• Application site or area
• (If Yellow or Red List) approval form or notation of when the approval form was issued and how many applications have been made since

Policy will need to drive schools towards a more comprehensive practice of the principals of IPM if it is to take place.

In general, we recommend that TDA and the Advisory Committee:

• Conduct a statewide assessment of all school districts.  The information collected by Consumers Union in 1999 indicates that a more thorough look is necessary.

• Ensure that IPM Coordinators in all school districts are adequately trained.  Currently there are trainers and resources already available from Texas Cooperative Extension and if they are not adequate, we advise that the board work with other agencies to develop programs to further train district coordinators in IPM.  (This way the board can work with TASB and others)

• Pest Control Companies contracting with school districts and inspectors must take the same training as IPM Coordinators.

• Develop materials and policies that support school districts in educating other staff, teachers and parents about the effectiveness of IPM.

• Provide the Southwest Technical Resource Center with support, either through extension or funding two additional employees.