Overview of New Rule on Pesticide Use in Schools
Ohio has adopted a set of rules for structural pesticide use inside classroom buildings of schools buildings and perimeter treatments. The rules are designed to reduce exposure risk to pesticides for school children and staff. The Ohio Department of Agriculture (ODA) is the enforcement agency.
The main components of the regulation are defining the three situations for pesticide applications and establishing a prior notification policy and a school contact person. These rules apply if the pesticide is applied by a licensed school employee or a contracted company. A complete version of the rules can be found in Ohio Administrative Codes, or on ODA’s website at: http://www.agri.ohio.gov/apps/odaprs/doc/ipm/901-5-11-15_final.pdf
Three Situations for Pesticide Applications
There are three situations under which pesticide applications are made, based on the time of the application, the type of products used and the proximity of children and school personnel during the application. The situations are:
Applications During Off-School Hours
When an application is made after school hours or during a day when school is not scheduled to be in session, there is no posting, restricted entry or product requirements other than those on the label. An application that is made prior to the school day must allow at least a four-hour re-entry period (unless a longer period is specified by the label.)
Applications During School Hours with Lower Exposure Potential
Certain pesticide product applications can be applied during school hours with no posting or restricted entry requirements. These types of product applications are:
- Manufactured paste or gel bait
- Paraffin-based rodent control products placed in industry-identified, tamper-resistant bait stations
- Termite-baiting stations
- Rodenticides which are placed in wall voids or other areas that are inaccessible to humans and pets
- Dusts in unoccupied areas of the building
- Disinfectants, sanitizers, germicides and anti-microbial agents
Other Applications of Pesticides During School Hours
Restricted entry and posting are required for any other pesticide applications than those listed above that are applied during school hours. No children or staff (other than the pesticide applicator or necessary staff) may enter the treatment area for during the treatment and for either four hours or the minimum time specified on the product label (whichever is longer). The entrance to the area must be posted with:
• A sign that measures at least 8-1/2 by 11 inches
• And, the sign must be printed in at least one-inch letters saying, “Pesticide Treatment Area. Do Not Enter Before (date and time where re-entry will be permitted into the treatment area).
Prior Notification Policy
The school district must develop a policy to provide prior notification of pesticide applications to anyone who requests it. This includes parents or guardians of minor children, adult students, faculty or staff. The school can determine the method of prior notification, such as e-mail or list-serves. Documentation must be kept to show that requested notifications were made according to the policy developed by the individual school district.
Contact Person and Recordkeeping for Notification
A school employee must be designated as a contact person for pesticide applications. The school contact person must maintain the pesticide application information required for notification and the documentation that prior notifications were sent to the persons who requested them. Outside service companies must supply this pesticide application information to the school contact person. The information must be available for inspection during normal school hours.
The school must maintain the information for one year. The pesticide application information that must be kept by the school contact person include:
- Date and time of the pesticide application
- Treatment area
- Target pests
- Brand name and EPA registration number
- Time or conditions for re-entering the treatment area as specified by the label of the pesticide applied, if any is specified.
Additional Reminders Not in This New Rule
Under existing Ohio Pesticide Law all school employees who make pesticide applications must be a licensed commercial applicator or trained serviceperson working under the direct supervision of a licensed applicator. They must keep complete records of all pesticide applications for three years that include more items than those listed above for the notification policy.
Comprehensive IPM plans for schools are optional. However, if schools want to develop an IPM program, the new IPM standards for Ohio must be followed.
For the actual language of the new pesticide in school regulation, please refer to Ohio Administrative Code: OAC 901: 5-11-15 on the ODA website at www.agri.ohio.gov