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Overview of Pest Management Policies, Programs and Practices
in Selected California School Districts:
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Many of California’s public school districts are now involved in reevaluating and improving their pest management policies and programs. Increased public concern regarding children’s exposure to pesticides at school has been a major influence. Public attention has been directed toward school procedures that are based on scheduled pesticide treatments rather than actual levels of pests present.

Parents, community organizations, and advocacy groups have expressed a need and right to know that schools are using pesticides safely and judiciously. As a result, many school districts with outdated policies are making new commitments to reduce pesticide use, to select the least hazardous and most target-specific pesticides when treatments are necessary, and to make more public information available about the use of pesticides on school grounds (Petris, 1992; Riley, 1994; Taylor, 1994).

The California Food and Agricultural Code establishes the Department of Pesticide Regulation (DPR) as the lead agency for pesticide regulation with primary responsibility for regulating all aspects of pesticide sales and use to protect the public health and the environment. DPR’s mission is to evaluate and mitigate impacts of pesticide use, maintain the safety of the pesticide workplace, ensure product effectiveness, and encourage the development and use of reduced-risk pest control practices while recognizing the need for pest management in a healthy economy.

In June 1993, DPR began an initiative to encourage and facilitate the adoption and implementation of integrated pest management (IPM) policies and programs in schools. IPM is an information-based systems approach to preventing unacceptable levels of pest damage. Pest and environmental information are used, along with available cultural, biological, genetic and chemical pest control methods, in the most economical manner with the least possible hazard to people, property, and the environment. It was the Department’s intent to encourage school districts in their efforts to reduce potential exposure of school children to pesticides and increase the use of reduced-risk pest management strategies. In so doing, DPR recognized the need for effective and economical school maintenance programs, and will work within practical constraints. As part of this initiative, DPR’s Environmental Monitoring and Pest Management Branch, in cooperation with the California Department of Education (CDE), conducted a study of pest management programs in California’s public school districts. The purpose was to obtain an overview of current district pest management policies, programs, and practices; to identify policy and program constraints; and to identify the ways that DPR can work cooperatively with CDE to assist school districts in implementing pest management programs based on the principles of IPM.

This report contains the findings of the study, which are based largely on the information obtained from in-depth personal interviews with maintenance managers in 25 California public school districts representing 1,275 public schools. Pest management programs involve the following categories of sites maintained by school districts: schools (buildings and grounds, including stadiums and other sports facilities), administrative facilities (buildings and grounds), and undeveloped sites (such as open fields or abandoned orchards on district property reserved for future development). The number of sites maintained by individual districts varies from 1 to more than 600.

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STUDY DESIGN

The study was conducted in two phases. The first phase was a mail survey of all public school districts in California to determine which districts have written pest management policies and programs and to obtain copies of those documents. Results of the mail survey were used to select districts for phase two of the survey.

The second phase consisted of personal interviews in selected districts based upon their responses to the mail survey. Most districts selected were among those which had sent a copy of their pest management policy and program in response to the mail survey. The following information obtained from CDE was also used in selecting districts for interviews: the district’s designation as "urban", "suburban", or "rural" (Appendix 1, Table A1-2); region of the state; and the number of schools in the district. Interviews focused on identifying current pest control practices, constraints, and areas of technical and procedural support needed to improve pest management. The interviews also attempted to elicit a description of administrative support in each district for IPM. The results were used to identify options available to DPR to assist school districts with establishment, reevaluation, improvement, and implementation of IPM policies and programs. Recommendations to the Director of DPR for the ways DPR can facilitate the expanded use of IPM in California’s public school districts were developed, based on review of district pest management policies and programs, interviews, and various literature sources.

Statistical analyses were constructed to determine if responses by districts in the mail survey were associated with the size of the district, location of the district, and type of schools predominant in the district (elementary, middle, high, mixed, or other). Demographic and other descriptive information about school districts and individual schools provided by CDE were used in these analyses. Statistical analyses of descriptive information and mail survey responses were conducted using SAS (Statistical Analysis for Sciences).

The first phase of the study was completed in March 1994; the second phase in June 1994.

MAIL SURVEY

The mail survey was conducted from December 1993 to March 1994. Before the survey, meetings were held with CDE staff to outline the proposed study, solicit their support, and finalize the survey response postcard and cover letter. Cover letters and self-addressed postcards were sent to the 1,002 public school districts in California. Each district was asked to send to DPR a copy of its pest management policy and pest management program or to indicate on the postcard that no policy and/or program was available. The district pest management policy establishes the district goals which provide the priorities and guidelines for developing the district pest management program. The district pest management program establishes plans for meeting policy goals, and the specifications and procedures that will be used to control specific pest problems. The survey was mailed in early December 1993. Postcard responses and copies of policies and programs were to be returned to DPR by January 25, 1994. Methods used in the statistical analyses of the mail survey data are presented in Appendix 1.

PERSONAL INTERVIEW SURVEY

Meetings were held with CDE to review the proposed interview discussion topics, and to discuss the method of selecting districts for the interview survey. Personal interviews were conducted with the managers of district pest management programs from March to June 1994 in the following school districts (SD):

• Auburn Union SD (Joe Vargas)
• Cajon Valley Union Elementary SD (James Beard)
• Folsom-Cordova Unified SD (Ron Flory)
• Fremont Unified SD (Dean Nissen)
• Fresno Unified SD (Lyn Peters)
• Galt Joint Union SD (Jim Bauler)
• Hayward Unified SD (Thomas Miller)
• Livingston Union SD (Ron Brietzman)
• Lodi Unified SD (Rob Christian)
• Los Angeles Unified SD (Bill Hicks)
• Merced City SD (Dave Douthit)
• Nevada City SD (Don Lucente)
• New Haven Unified SD (Ed Perry)
• Novato Unified SD (Ron Warfield)
• Placer Hills Union SD (Ken Poulson)
• Redding Elementary SD (Rob Abernathy)
• Riverside Unified SD (Merle Bartman)
• San Diego City Unified SD (Ray Palmer)
• San Jose Unified SD (Frank Frietas)
• San Juan Unified SD (George Branson)
• Santa Monica-Malibu SD (David Simpson)
• Sweetwater Union High SD (Diarmuid Coughlan)
• Vacaville Unified SD (Tess Starkey-Owens)
• Waugh SD (Skip Rigby)
• Woodland Joint Unified SD (Larry Patrick)

Topics for each interview were developed by DPR staff and reviewed by staff from CDE’s School Facilities Planning Division during January 1994. Each manager interviewed was asked to provide the following information, with an emphasis on ways to improve the district’s pest management program, and the associated needs and constraints:

1. a) How does pest management relate to maintenance and operations with regard to policy and program? b) Has your district established a written IPM policy and program and, if so, what benefits have resulted? c) What do you believe is the current level of interest by other public school districts in establishing written IPM policies and programs?
2. What is the district’s line-and-staff organizational structure which applies to pest management program implementation?
3. What are the common pest problems in the district and the effective strategies and practices used for their control?
4. What are the elements of the district’s pest management decision process?
5. Are there problems related to budget planning which act as constraints on the district’s pest management program?
6. What innovative approaches, procedures and techniques have been developed by the district?
7. What is the influence of liability on the district’s pest management program?
8. What are the advantages and disadvantages of contracting with commercial pest control companies, as opposed to handling district pest control in-house with district personnel?
9. What is the district’s approach to pest prevention and what strategies are most successful?
10. To what extent does this district communicate with other districts to exchange pest management information, and how important is this type of communication?
11. How supportive is the community of district pest management activities, particularly with regard to pesticide use on school grounds?
12. Does the district have any particular difficulties regarding current pesticide laws and regulations, such as interpretation, compliance, or keeping current?
13. What is the importance and availability to the district of technical, professional-quality pest management training?
14. What are the district’s sources of technical information related to pest management?
15. Is the district involved with local or statewide professional organizations related to pest management, and if so, what benefits are derived?
16. Are there actual or potential hazards resulting from pest management or other activities on properties adjacent to school grounds and, if so, what approaches are used to minimize the hazards?
17. How satisfied are district personnel with the district’s current pest management program?

The results of the interview survey were not intended to be representative of all public school districts in California. The purpose was to obtain an overview to provide sufficient information, as complete as possible within the scope of this survey, to identify the ways DPR can work cooperatively with CDE to enable school districts with their programs. Most of the information presented represents a summarization of the majority of responses for each discussion topic. Information representing a minority of responses is indicated as such where appropriate.

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MAIL SURVEY

The statistical analyses of mail survey data were carried out to characterize the respondent and non-respondent districts, and establish whether or not a particular type of district was more likely to have responded to the survey. The results of the statistical analyses of the mail survey data are presented in Appendix 1.

A total of 556 districts (55%) of the 1,002 districts surveyed responded to the mail survey. A majority of the respondents (62%) did not have a pest management policy or a pest management program. Six percent of the districts had only a pest management policy and 22% of the districts had only a pest management program. Ten percent of the districts had both a pest management policy and a pest management program.

There was no detectable association between the district variables, such as district size or location, and the response of districts to the mail survey. There was no evidence of biased sampling. The mail survey appeared to provide a fair representation of all school districts in California despite the lack of a formal sampling procedure. There may be differences in unmeasured characteristics such as some common educational backgrounds or even age among the administrators of the districts that lead to a common commitment to their districts having an established, written pest management policy or program. However, this survey was not designed to measure those types of characteristics.

PERSONAL INTERVIEW SURVEY

PEST MANAGEMENT POLICY AND PROGRAM

Each district was asked to describe how the district’s pest management policy and program relates to maintenance and operations, the value of an established written IPM policy and program, and current interest by other districts in establishing a written IPM policy and program.

Background information: CDE does not set policy or procedures for school district pest management or other district maintenance and operations programs. Rather, each district governing board has this responsibility. CDE does provide guidelines to assist district boards with these functions. Guidelines are contained in the 1986 CDE publication entitled Administration of Maintenance and Operations in California School Districts: A Handbook for School Administrators and Governing Boards. The discussion of pest control is found on pages 68-69 of the handbook (Appendix 2).

As indicated by the results of the mail survey, relatively few public school districts in California have an established written policy or program specific to pest management. Most district staff interviewed believe this is largely because activities which support pest management are managed by most districts as buildings, grounds, and custodial maintenance services. The applicable policy statements and procedures are documented within these separate sections of district maintenance and operations manuals. Maintenance includes school building and equipment maintenance, and operations includes custodial maintenance services and grounds maintenance services. Pest management involves the full range of activities that are employed to prevent or mitigate the effects of pests on school grounds.

Most school district staff interviewed agreed on the following benefits resulting from the establishment of a written IPM policy and program in their district:

• The pest management decision-making process is improved. District pest management goals, objectives, and priorities are more clearly defined and provide more effective guidelines for developing the most appropriate actions and procedures for controlling specific pest problems.
• Community relations are improved at both the district and individual school levels. A written IPM policy and program provides a more effective way to educate the general public, and district and school staff. It also helps them respond to questions regarding the potential hazards and benefits of pest control procedures, and when and why pesticides or other alternatives might be used.
• A written IPM policy and program provides district guidelines and procedures for protecting human health and safety and the environment, for immediate response to any problems which do occur, and for proper documentation of district actions.
• Establishing a written IPM policy and program is an important first step in strengthening budget priorities for pest management needs. Historically, the resources needed to support pest management activities have not received high priority in annual maintenance budgets. Consequently, districts are often unable to garner the resources needed to implement strong prevention-based IPM programs (which may involve extensive monitoring, as well as purchase of the materials and equipment long before they are needed so that alternatives are immediately available when pest damage thresholds are reached). Because the best pest management programs are preventive and therefore rarely have emergency or immediate needs, pest management programs, especially without the backing of a written policy, do not compete well for budget priorities with other immediate-need maintenance programs, e.g., asbestos removal.
• There are many federal and state regulations involved with pesticide use. A thorough, written IPM policy outlines all procedures necessary for proper adherence to pesticide laws and regulations, facilitating not only regulatory compliance but also thorough documentation of pesticide use.

District staff believe that there is increasing interest by districts throughout the state in establishing IPM policies and programs. For some districts this involves documentation of a district IPM approach already in place, while in other districts this involves major changes in approach. Increased public concern is a major influence driving policy and program changes. Districts are facing increased public demand for IPM policies and programs. The public expects school district commitment to reduced pesticide use on school grounds, increased availability of public information about when and why pesticides are used, and assurance that the least hazardous and most target-specific pesticides are selected when treatments are necessary.

Needs and Constraints

• District personnel interviewed believe that increased availability of IPM policy and program models would do much to encourage and assist districts with policy and program improvements. Although brief guidelines for policy and program development are included in the 1993 United States Environmental Protection Agency (U.S. EPA) publication entitled Pest Control in the School Environment: Adopting Integrated Pest Management, which DPR mailed to each district in 1994, some of the district pest managers interviewed were not aware of this resource at the time of this survey. Some districts stated the need for an IPM policy model in the CDE guidelines, which could be refined to meet the special circumstances in individual districts.
• Reevaluation and improvement of policies and programs involves a considerable commitment of time and personnel. Districts will generally not attempt this major undertaking unless there are major problems identified as policy- or program-based. The integration of pest management activities with other maintenance and operations functions may complicate the identification of specific improvements needed in the written policies and programs which apply to pest management.
• Most district personnel interviewed agree that a primary constraint to the initial development of an IPM policy or program is the impression that IPM is unaffordable, due to the need for additional monitoring and the purchase of additional equipment and materials in order to have a number of control alternatives on hand.
• Various policies and procedures, other than those specific to pest management, may have a considerable, although indirect, negative impact on the implementation of district pest management programs. One example is the exclusion of pest management considerations in policies and procedures which guide school planning and facility design. Another example is district guidelines for contracting with vendors, which normally do not specify vendor responsibility for ensuring that pests are not introduced to school facilities via infested delivery trucks. Some districts see the need for identifying and reevaluating all district policies and procedures which could negatively affect pest management.

LINE-AND-STAFF ORGANIZATION

Each district was asked to describe line-and-staff organization which applies to pest management.

There are many variations of line-and-staff organization used by school districts to establish sound functional maintenance and operations organizations (Figures 1-4). Pest management personnel are rarely identified in organizational charts. This is understandable because pest management activities cross the lines of all three major disciplines within maintenance and operations (buildings, grounds, and custodial maintenance services).

FIGURE 1

FIGURE 2

FIGURE 3

FIGURE 4

Most districts accomplish pest management objectives within the line-and-staff organizations established for these functions. However some districts have separate line-and-staff organization for pest management programs. It would be difficult to identify a typical approach; each is tailored for the unique combination of district management and site considerations involved. Regardless of organizational structure, districts regard line-and-staff organization as a critical key to the effectiveness of their pest management programs.

Most staff involved with pest management perform other maintenance and operations functions. Generally, only in the larger districts is there an individual whose entire responsibilities are pest management.

Generally speaking, the school principal is responsible for all activities on a school site. Therefore, district staff work with each school principal in scheduling pest management activities. Frequently, these activities must be integrated with other maintenance activities. The involvement of school custodians in pest management activities varies considerably from district to district. Usually, district pest management staff do not have authority over school site custodians, who usually work under the supervision and authority of the school principals.

In some districts, all pest management activities on individual school grounds may be handled by district staff. In others, all activities are handled by custodians and supervised by district staff. Often, pest problems are handled by contracting, with custodial or district staff overseeing operations. Most commonly, school site custodians and district staff work together. School custodians usually handle routine problems. District staff become involved with pest problems which involve a crisis, are large-scale, or require special equipment, materials or additional personnel. If there is the need for special help, such as for people in a correctional work furlough program or for contracted services, then district staff are frequently involved. District staff and management also become involved if parents or community organizations express concern about any pest management activity.

The following examples illustrate line-and-staff organizations that were reported to be very effective:

• A manager in a large district delegates inspection, monitoring, and decision-making to a few IPM specialists who are each responsible for multiple school sites.
• A district maintenance supervisor has delegated the district’s pest management and maintenance responsibilities among three managers. Each has responsibility for maintenance of "green scapes" (turf and landscaping), "hardscapes" (blacktops, concrete, and wood areas), or "custodial" (structures) at all the district’s sites. The maintenance supervisor serves as an overseer, advocate and consultant as needed, but lets them manage without interference. Only structural pest control is contracted out.
• Pest management projects at each school are implemented by school custodians; district staff approve proposed strategies and oversee operations. The district uses full-time pest management specialists as follows: "pest control technicians" for control of horticultural and structural pests, and "power spray operators" for weed control requiring 300 gallon spray rigs and for insect control requiring 600 gallon spray rigs. No pest control is contracted out.
• District staff with pest management responsibilities are classified as "carpet cleaners" and "night custodians". Carpet cleaners have responsibilities at all school sites; each night custodian has responsibilities at four school sites. Carpet cleaners are the only district personnel that apply pesticides. Their pesticide application responsibilities include those necessary for indoor insect and vertebrate pests (excluding applications for structural wood-destroying organisms) and outdoor insect and vertebrate pests. Pesticide application for structural wood-destroying organisms is contracted out. Weed control is considered a maintenance, rather than a pest management activity, and is handled by district "groundskeepers" in the grounds maintenance section. School principals have no authority over pest management activities. The district’s "risk manager" has district-wide pest management authority over all sites.
• Full-time district pest management staff each have total pest management responsibility and authority for three school sites ("site grouping"), which they are required to inspect daily. District staff handle all weed control. School custodians assist district staff with recurring insect and vertebrate pest problems. Only structural pest control is contracted out.
• District staff evaluate and respond to pest control work order requests from individual school sites. All pest control measures are implemented by either district staff or commercial pest control operators. School custodians are not involved with pest population reduction measures such as pesticide application, but are involved with preventive measures such as sanitation and exclusion.
• District staff conduct all pest management activities. No control measures are contracted out. Involvement of school-site custodians is minimal.

Needs and Constraints

• Some districts stated that there is a need for a statewide authority over pest management in all public school districts which can require that each district establish a written IPM policy. This would result in increased public confidence in district pest management programs statewide, while enabling each district to better integrate planning of pest management and other maintenance objectives. Also mentioned as needs for improvement were CDE support for higher budget priorities for the resources which support pest management programs, and CDE support of districts’ professional training needs.
• Some districts stated that stronger district authority is needed at each school site regarding pest management activities.
• Several districts mentioned the need for increased involvement of school principals with district staff in annual pest management planning.
• While nearly every district identified the need for more personnel, the larger districts also identified a need for more highly-trained pest management specialists. Most districts would like to see a greater emphasis on pest management in both the job description and recruiting efforts.

COMMON PEST PROBLEMS AND METHODS OF CONTROL

Each district was asked to describe the common pest problems managed by the district, and effective management strategies and practices.

Most schools are faced with the same groups of weed, insect, vertebrate and plant disease pests. Schools may target pest species individually or group them for control, depending on the site and situation. Generally, the criteria used for selection of pest control alternatives in order of priority are human health and safety, environmental protection, and cost effectiveness. Most districts report that they do not use pesticides designated as restricted materials. A restricted material is a pesticide which generally requires a permit from the county agricultural commissioner prior to possession or use. Pesticides are designated restricted materials through regulations promulgated by the Director of DPR. The criteria established to designate a pesticide a restricted material are listed in the California Food and Agricultural Code, Section 14004.5. They include hazard to public health, workers, domestic animals, and the environment.

Weed Control

Weed control is usually the greatest resource commitment in district pest management programs, particularly nonselective weed control along fence lines and other borders, firebreaks, embankments, asphalt areas, and rights-of-way, and in open fields and other undeveloped sites. Weed control is usually handled by district and school staff, rather than contracted to private pest control companies. Wherever possible, mowing, flailing, disking, and hand-grubbing are the preferred weed control methods. Weed control along cyclone fences which are not bordered with mowing strips is a major problem. Some districts are retrofitting older fences with mowing strips to reduce the need for weed control.

The scale of operation is a major consideration in the determination of management strategy. Non-chemical methods are preferred but not always feasible for treating extensive areas or for sites where the use of equipment is hazardous or limited by physical features.

Glyphosate (Roundup®) is by far the most widely used foliar-applied herbicide for nonselective weed control. For many districts, this is the only postemergence herbicide used. Preemergence herbicides are most often used for nonselective weed control along extensive fence lines or other sites which are not in close proximity to school activities or nontarget vegetation. Preemergence treatments are usually used only when personnel and time constraints eliminate the feasibility of the physical, mechanical, or postemergence herbicide alternatives.

In landscaped areas, the need for weed control is minimized by the use of organic or inorganic mulches. Selective weed control is most often accomplished with mechanical or physical methods, although some glyphosate is used for weed control in large landscape plantings.

Selective weed control in turf is not widely practiced on large sites such as athletic fields, where utility rather than aesthetics is the priority. Most turf weed control is approached with preventive strategies, emphasizing maintenance of healthy turf. This involves proper selection of turfgrass species for each environmental setting; proper irrigation, fertilization, drainage, mowing and aeration; and proper selection and placement of ornamentals which will not limit turf growth.

Control of Insects and Other Arthropods

The major insect and other arthropod pests of school buildings and grounds can be grouped for discussion as structural pests, including wood-destroying pests and indoor pests; outdoor nuisance pests; and landscape pests.

1. Structural Pests

   The most troublesome structural pests are the wood-destroying insects, primarily termites; and the indoor pests, primarily ants, cockroaches, spiders, houseflies, fleas, and silverfish.

   Pest prevention strategies for structural pests, both wood-destroying and indoor pests, include frequent inspection and pest population monitoring, moisture control, structural improvements to exclude pests, sanitation in and around structures and refuse containers, and proper facility design and location during the planning stages for new construction.

   School district personnel reported that control of structural wood-destroying insects is always contracted out.

   The most troublesome indoor pests are those infesting classrooms, offices, kitchens and food service areas. For indoor pests, exclusion of food from classrooms is widely practiced and very effective. The emphasis of exclusion efforts is on the sealing of openings around doors, windows, and pipes and conduits which extend through outside walls. Desiccants, repellents, soapy water sprays, and insecticide baits or sprays are the common insecticide treatments.

2. Outdoor Nuisance Pests

   The outdoor nuisance pests are those that pose problems to the health, safety, and comfort of students, staff, and visitors. The most troublesome are wasps, bees, flies, gnats, fleas, and midges.

   Yellowjacket control is usually handled by school and district staff. Food and refuse sanitation provides effective prevention, and pheromone traps or diazinon bait stations are effectively used for control if they can be located where student access can be prevented.

   Even though honeybee swarms are only circumstantial, prompt removal of swarms is necessary. A beekeeper in the area will usually respond upon request and remove a swarm. If a beekeeper is not available, swarm removal is contracted to a commercial pest control company. Concern by pest management staff, administrators, and others about Africanized bees has heightened awareness for prompt pest control action against honeybees of any type.

   Flea problems are introduced by feral dogs and cats. Control efforts are limited to exclusion, and to the capture and relocation of the feral animals to animal shelters.

   Cuban laural thrips are pests of Ficus (Ficus nitida) trees, which are commonly grown on school grounds in Southern California. The thrips are a major nuisance to students during certain times of the year. Thrips control primarily involves selective pruning of the new growth on Ficus which attracts the insects.

3. Landscape Pests

   The most troublesome landscape pests are aphids, whiteflies, elm leaf beetles, thrips, wood-boring beetles, and turf grubs and moths.

   Pests of turf and ornamental plants in the landscape are managed effectively with prevention strategies, beginning with proper plant selection and placement, and maintenance of plant health. Where resource constraints limit this approach, which is usually the case in large areas, direct control measures may be necessary. Not all pest infestations are treated. Should plant health deteriorate substantially, a common approach is to remove the infested plant and replace it with a species which is less susceptible to the pest problem.

Vertebrate Pest Control

School district personnel reported that the major vertebrate pests on school grounds are 1) structural pests, and 2) pests of landscape and other outdoor sites.

1. Structural Pests

   The most troublesome vertebrate pests of buildings and other structures are rats and mice, and various perching and roosting birds. Rats and mice damage food, clothing, documents, artifacts, and structures by their gnawing, urination and defecation. Rats and mice are controlled by structural improvements for exclusion, sanitation in and around buildings and refuse containers, habitat modification and mechanical trapping.

   Pigeons, starlings and other bird species create problems with their roosting, perching, nesting, and droppings on roofs, in attics, and in student activity areas. Bird droppings and nesting can deface and accelerate deterioration of buildings and equipment, clog drain pipes and air intakes, or otherwise interfere with school activities. Swallows create problems by building mud nests under eaves and other structures and by dropping mud and fecal matter onto walkways. Bird pests are controlled primarily by building improvements, nest removal, and the use of roost prevention devices, and exclusion netting and barriers.

2. Pests of Landscape and Other Outdoor Sites

   The most troublesome pests of landscape, turf, playground and other recreational sites are gophers, ground squirrels, and feral dogs and cats. Gophers cause damage by eating plant roots and stems and girdling or clipping tree roots. Their mounds disfigure turf and other recreational sites. Burrow openings pose a hazard to foot traffic or other student activities. Control efforts include mechanical traps, and the use of gas cartridges. Ground squirrels become pests when their burrow systems threaten the integrity of school facilities by weakening structural foundations, and when burrow openings pose a hazard to outdoor activities. Ground squirrels are hosts to fleas which may be infested with plague. Control efforts include mechanical traps and the use of gas cartridges.

   District personnel report that for both gopher and ground squirrel control, trapping and the use of gas cartridges are closely supervised by district staff. Traps are not left unattended. Gas cartridges are used when school is not in session.

   Feral dogs and cats become a problem when their activities disrupt student activities. They are hosts to fleas which can infest classrooms when they are inadvertently introduced indoors by students after petting the animals. Control efforts are limited to capture and relocation to animal shelters.

   Some district personnel report that wildlife species such as skunks and opossums are rarely a problem, while personnel from other districts report that they are regularly faced with a need for wildlife control. They do not use lethal measures but rather live-trapping and relocation, habitat modification, and structural improvements for exclusion.

Plant Disease Control

With the exception of selective tree pruning for mistletoe removal, the approach to plant disease management of turf and ornamental plants is pest prevention. Efforts involve proper plant selection and placement, selective plant removal and replacement, and proper irrigation, fertilization, pruning, mowing, aeration, and habitat modification to reduce the supporting environment for target pests. Fungicides and other pesticides are generally not used except for treatment of specimen trees.

Each district was asked to describe its district pest management decision process, involving problem identification, problem assessment, and selection of management strategies and practices.

In the districts surveyed, there was much similarity in the pest management decision process. It can be summarized as follows: problem reported, problem evaluated, and decision made.

Problem Reported

Although the reporting process is fundamentally similar in most districts, each of the three elements of the process may be handled somewhat differently. Generally, an on-site custodian, principal, or other school official reports the pest problem to the district office by telephone. In some districts the problem must also be recorded in written form to track the problem as well as its final resolution. In Los Angeles County, for example, a school district uses a triplicate "trouble-ticket" form that documents the identity of the person making the initial report, the plan of action, and the resolution. This facilitates accurate recordkeeping, ensures a response, and informs the necessary parties. Other districts use similar written forms.

Not all pest problems are reported to the district office. Certain pest problems may be handled entirely by school-site custodial staff. Problems reported are those which require, by district policy or other protocol, district involvement or those for which the school requests district assistance.

Problem Evaluated

The first step of the actual decision process in responding to a report of a pest problem is to accurately assess the pest problem. Examples of questions needing answers at this point include: Is there really a problem, or is it simply an over-reaction on the part of the reporter? What is the actual cause of the problem and can the problem be eliminated simply by eliminating the cause? How serious or urgent is this problem? Is a control action actually necessary at this point? Is treatment of the problem within the scope of training, equipment, etc. of my own staff and facilities, or do I need to contract with a pest control company for treatment?

Evaluation of the problem may be accomplished by the pest management supervisor exclusively, or delegated to either a pest control contractor, a district horticultural specialist, or a district pest management specialist.

Some districts have very successfully used an advisory committee approach. The mutual evaluation and decision-making is done by a formal or informal group composed of various combinations of school district staff (pest management supervisor, principal, school nurse, custodian, etc.), parents and other members of the community, and pest control contractors. The involvement of parents and other members of the committee has done much to strengthen public awareness and appreciation of the need for pest control and the considerations involved with management alternatives. This approach has been effective in both large and small districts.

Decision Made

The same individual(s) that evaluate(s) the problem may also make the decision as to what course of action (if any) will be taken to manage the pest problem. The decision to take action and the specific action to be taken may be made exclusively by the district pest management supervisor, by a district specialist delegated by the supervisor, by a designated contractor, or by an advisory committee. The amount of responsibility designated to contractors varies from district to district. In some districts, contractors which the district knows well may be given complete responsibility for selection of the control method used, including pesticide selection, within district policy guidelines. The district pest management policy prescribes approved courses of action that are known to be effective and acceptable by school district staff and the public. The role of policy at this stage helps assure continuity of action, consideration of feasible treatment options and alternatives, credibility with the public and the district staff, and prevents potentially inappropriate, ineffective, or even injurious control actions.

The range of qualifications of decision-makers varies considerably among districts. Some districts require staff with pest management decision authority in any school ground situation to be licensed pest control advisers or certified (Qualified Applicator Certificate holders) in the appropriate categories, whether or not required by law.

Needs and Constraints

• Implementation of district objectives is jeopardized when there is disagreement between district staff and school principals regarding planned measures at individual school sites. School site custodians must often be relied upon by district staff for implementation of district program measures at each school site. School principals have authority over site custodians. Principals are usually not involved with district pest management program planning, and are sometimes unaware of how district projects at individual schools fit into the big picture. Most districts interviewed believe that increased involvement of school principals in annual district program planning is needed. This would result in improved understanding by principals of district program objectives, particularly long-range objectives, and improved understanding by district staff of school site considerations.

Each district was asked to describe budget planning constraints on the district’s pest management program.

Budget Priorities

The activities supporting pest management programs in most districts are integrated with other elements in the maintenance budget. District personnel report that pest management often does not have a high priority in budget decisions. A primary reason is that the best pest management programs are based on pest prevention. The resources and activities which support long-term preventive strategies do not have immediate need or high visibility, but must compete with other maintenance budget items that do. This often holds true even when maintenance budgets receive big increases.

Examples of preventive strategies that often do not receive sufficient budget priority but are very cost-effective over the long-term, include the need for structural changes to eliminate trapped moisture which invites structural wood-destroying organisms; the need for cement mowing strips along fence lines and other borders to reduce the need for herbicide use; changes in landscape plantings to reduce pest problems; and various structural improvements to exclude rodents and insects from classrooms.

Matching Program Objectives with Budget

Many of the district personnel interviewed mentioned the need in their district for a more realistic matching of budget and pest management objectives. Districts may have excellent IPM approaches, but they may not be documented as such in policies and programs. There are seldom adequate resources budgeted for proper implementation, particularly for the pest population monitoring. The districts interviewed believe that establishment of written IPM policies and programs is essential for strengthening the budget priorities needed for effective implementation of the long-term, non-emergency, pest prevention strategies involved with IPM programs.

Personnel and Equipment

Most district personnel interviewed linked the availability of personnel and equipment resources as a primary constraint on proper implementation of their IPM program. They are linked because program efficiency is often determined by their proper balance. While every district would like to have more personnel, the equipment or tools must also be available to match the workforce. Some districts consider personnel and equipment as the deciding factors that determine the feasibility of either a pest management program based on prevention of elevated pest populations, or one based on response to pest damage.

Some districts strongly believe that equipment should always be given higher budget priority than personnel, i.e., get the equipment first; it is easier to find personnel to operate the equipment than vice versa. The right equipment inventory will enable a limited staff to do the work of much larger staff, particularly involving activities such as tree pruning and tree removal, landscape waste recycling, mulching, and mowing.

Each district was asked to describe successful innovative approaches, procedures, and techniques developed by the district.

One of the more intriguing discoveries from interviews with school district staff was the fact that virtually every district visited was doing something innovative or creative to increase efficiency, save money, strengthen its image, or otherwise improve its service to the public. It was not always recognized as an innovation by the persons interviewed. It became apparent that most districts have a lot of potentially beneficial ideas to share with other districts, if there were an effective means of communicating and disseminating the information.

Districts generally agreed that interdistrict communication among pest management specialists could be a very effective and dynamic way to assist one another by sharing innovations, exchanging advice, comparing notes and ideas on various subjects, making training opportunities known to each other, scheduling the sharing of equipment, answering each other’s questions, etc.

The innovations discussed below fall into several categories: student, staff, and community involvement; community relations; safety; pest management strategy; and cost-effectiveness. In some cases the innovation originates from one district, in some cases more than one.

Student, Staff, and Community Involvement

Some districts have developed innovative programs designed specifically to stimulate student awareness and understanding of their stewardship role in maintaining a safe and pleasant school environment, and responsible action. Districts which have made this effort have seen dramatic results. Successful programs have placed the emphasis on efforts to increase student appreciation of the school landscape and habitat and the need for buildings and grounds sanitation. Students are generally unaware of the pest problems on their school campus. Most major pests are effectively controlled and control measures are usually conducted when students are not on campus. In districts with strong student awareness programs, students are eager to be involved. In several districts, the student awareness program has resulted in reduced vandalism of landscape plantings.

• Some districts have initiated recycling programs on school campuses which have been very effective in stimulating interest of students, staff, and the community in doing what they can to help maintain the quality of the school environment. The program starts with recycling and composting. This improves school ground sanitation, which in turn reduces the supporting environment for various pests. Students and staff become involved by collecting recyclable items, including aluminum cans, paper, garden and landscape waste, and food service leftovers. Garden and landscape waste are composted on school ground sites. The school donates the compost and other items to community organizations and local farms. The effort reduces the quantity of solid waste. This in turn results in cash rewards to the school by local government for the reduced number of garbage pick ups needed at the school.
• A Southern California district has produced video presentations to educate students and staff on Africanized bees. The presentations are aired over a school district cable network.
• A pest management advisory committee, composed of school district staff and knowledgeable members of the community, takes a team approach to solving pest management problems. Thus, since the community is actively involved, the district reaps the additional benefit of giving the community a sense of partnership and shared responsibility with the school district.

Community Relations

• A procedure that has been effectively used to prevent misunderstanding or unnecessary alarm by parents is to send a treatment notice to all parents prior to each planned pesticide treatment. The notices, which fully address many anticipated questions, explain the project, actions planned, the pesticides to be used and their risks.
• A Northern California district pest manager is on the agenda of the regular meetings with school principals and other administrators. The purpose is to keep them fully apprised of current pest problems and control actions. The end result is that principals and administrators become educated about IPM and are prepared to answer questions from the community about their pest management program.
• The "space suit paranoia" usually arises when pesticides are applied, due to the white, attention-drawing, protective clothing worn by applicators. One Northern California district has found a way around this problem by providing staff with less conspicuous khaki-colored protective clothing. Clean protective clothing is provided daily, without charge to district pest management staff. A shower and clothes locker facility is also provided for daily use.

Safety

• District personnel report that most pesticide applications are done in the absence of students. Since many structural pest control applications are done at night, one Southern California district, which has school sites in high-crime areas, has found that two-way radios are an important safety feature allowing its pesticide application staff to be in constant contact with someone who can call for help in emergency situations.
• All measures are taken to avoid pesticide applications on school grounds during school hours or when campus activities are scheduled. When a pesticide application occurs during campus activities (on some school grounds there are activities seven days a week) students will be moved to a protected area (e.g., indoors or asphalted area) away from the target area.
• The district assumes that school children or visitors are on school grounds 24-hours a day, 7 days a week. Pesticide and equipment use and storage precautions are tailored accordingly.
• A 24 hour reentry interval is enforced by the district, whether or not required by law, for all pesticide applications.
• Information brochures or fliers are sent home with students or mailed to parents to notice all pesticide treatments.
• No pesticides designated as restricted materials are considered for use on school grounds.
• Pesticides are purchased only in the amount needed for specific projects, to minimize the amount of pesticides stored in district facilities.
• The district prefers not to use commercially available pesticide formulations that may stimulate student curiosity, such as food baits, bait stations, above-ground traps, or pesticides which leave colored residues. If use is deemed absolutely necessary, the district will closely supervise procedures and will not leave control devices unattended during school hours.
• All pesticide applications are posted, whether or not required by law.
• School staff and students are periodically instructed and reminded that cleaners, solvents and disinfectants may be pesticides and should be handled with the same precautions.
• School and district staff conduct periodic campus facility "walk-throughs" to confiscate all pesticides, cleaners, solvents, and disinfectants brought to school by students, parents or teachers. School employees and students are instructed to leave pesticides (and cleaning solutions and solvents) at home.

Pest Management Strategy

• Districts are working with vendors to insure that delivery trucks do not introduce pests to school destinations. Some districts have reached conditional contract agreements with vendors which designate vendor responsibility for pest exclusion at origin and in delivery vehicles. Some districts refuse to accept delivery if there is evidence of pests in trucks or on containers at destination.
• To reduce indoor pest problems associated with food service preparation areas, one school district has meals for all school sites prepared at one central location and then delivered to the various school sites. Other districts accomplish the same preventive results by contracting out their food service.
• A common problem is poor landscape planning which results in maintenance nightmares for the pest management staff. In several districts landscape planners now consult the pest management staff for input and consequently identify and prevent many future trouble spots before they are designed and installed. District staff took the initiative to promote a larger role for pest management considerations in the planning of landscape design.
• A Northern California school district schedules its turf irrigations based on evapotranspiration rates. This cuts down on excess irrigations, thereby reducing the amount of shallow-rooted and drought damage-prone turf; saves water (the original motivation for this innovation, since water in some districts is metered and very expensive); and dramatically reduces broadleaf weed problems in the turf.
• Instead of spraying chemical pesticides, one Northern California district regularly releases biological control organisms to control specific insect pests of landscape trees.
• Food is routinely restricted from school classrooms in several districts, largely eliminating the source of attraction for a number of structural pests. Only rare exceptions are made for special occasions.
• A program of continual facility inspection and maintenance is done in some districts to suppress pest populations to acceptable levels and to prevent major infestations. The emphasis is on the detection and elimination of moisture and other favorable conditions for structural pests. In one large district, thorough inspection of all facilities on all district sites is accomplished at least once every five years. Landscape plantings are inspected on a more frequent basis.
• In a Southern California district, fleas are monitored in carpeted classrooms during the spring and summer months. District staff monitor for infestations by placing white socks on hands, crawling across the floor, and examining for fleas which have jumped onto the socks.
• A deliberate effort to eliminate pest access to buildings and pest harborage within buildings is a priority in some districts to prevent or reduce the number of structural pest problems such as rodents. Examples include the pruning of tree limbs and other vegetation close to structures, and the elimination of piled debris near building walls.

Cost-effectiveness

• Some school districts have made cooperative arrangements with other districts and with local agencies such as parks departments to make training more affordable and to share the use of expensive equipment. Agencies make their in-service training available to other local agencies if applicable to their work, resulting in costs savings to each agency in money budgeted for training. Several local agencies in many communities have similar training needs related to pest management. For example, training needs for weed control in turf, landscaped areas, and rights-of-way are often very similar for school districts and parks departments. Likewise, cooperating agencies have saved capital investment dollars by sharing equipment with other agencies, especially expensive equipment such as large volume, truck-mounted spray rigs, and large trucks used for hauling landscape waste and mulch.
• Several districts make use of free hand labor on special projects when it is impractical to use mechanized equipment, such as weeding steep slopes, etc. Some use correctional work furlough program personnel made available through local law enforcement agencies. Some districts have made arrangements to utilize personnel from the California Conservation Corps. Some districts use student interns. Interns acquire hands-on practical landscape maintenance experience such as learning how to design, install, and repair landscape irrigation systems.
• One large Southern California school district which maintains hundreds of structures has enabled pest management staff, by providing the time and funding the necessary training, to become licensed structural pest control operators (PCOs). This allows districts to use their own personnel to perform structural inspections for wood-destroying insects, and to handle their own guarding of tarped (for treatment) structures following fumigation. The law requires continuous monitoring by appropriately licensed personnel to ensure that the permissible exposure limit (PEL) is not exceeded following structural fumigation (Title 8, California Administrative Code, Section 5155, Airborne Contaminants). Using licensed district personnel, districts have more confidence in work quality and consistency, and can perform these functions more economically than by contracting. The resulting cost savings allows more frequent inspections, which in turn strengthens a district’s capabilities for a preventive approach to structural protection against termites and other wood-destroying organisms.
• One Northern California district has arranged to have tree maintenance companies dump its wood chips for free at the school district headquarters site. The chips are then used as mulch for weed suppression in district landscape sites. The labor to spread the chips at the landscape sites is usually free also, in the form of assistance by individuals in the local work furlough program.
• A Southern California district uses a triplicate "trouble-ticket" system which facilitates tracking and documentation of pest problems and actions taken. Trouble tickets are submitted to the district office by school-site custodians or administrators, explaining a site-specific pest problem. District staff visit the site and investigate the problem. The problem assessment results and action (or no action) taken are thoroughly documented on the tickets.
• A Northern California district not only documents pest control actions in writing, it maps them as a part of the record as well. Having a record of precisely what areas were treated improves the quality and precision of documentation and facilitates future pest management decision-making in the same areas.
• In a large Southern California district, the district supervisor delegates inspection, monitoring, and decision-making to a few IPM specialists who are each responsible for multiple school sites.

Each district was asked to describe the influence of liability on the district’s pest management program.

Central Role

Liability is a major consideration during pest management policy and program development, program documentation and recordkeeping, and pest management decision-making, and in district decisions regarding licensing and certification, professional training, public relations, and contracting. Districts want to take every precaution to avoid litigation initiated by concerned parents, community organizations and advocacy groups regarding adverse health, safety, or environmental impacts from pesticide use. In addition, districts realize that litigation based upon perceived health or safety hazards is possible, no matter how extensively precautions are taken to reduce potential risks.

Contracting

Districts which have the least fear of litigation are those which are 1) most assured that all procedures, especially involving pesticide use, will be properly implemented and thoroughly documented, and 2) assured that the public has confidence in their personnel and procedures. These districts also make every effort to insure that they have all the current information concerning pesticide laws and regulations, pesticide risk assessment, and hazard mitigation. However, these efforts can involve a considerable amount of district staff time.

District contracting with pest control companies which have excellent reputations for thoroughness with safety procedures and recordkeeping is one of the most effective tools used by districts for liability protection. Contracting increases public acceptance of pest control on school grounds, largely due to the licensing and professional training required of pest control advisers and operators employed by contractors.

Note: School districts cannot transfer pesticide use liability to contractors. Districts are responsible for pesticide use on school property, whether pesticides are applied by a pest control company or the district.

Precautionary Measures

Liability has some influence in strengthening district incentives to keep updated on changes in laws and regulations, meticulously document program activities, attend frequent professional training seminars, and generally go beyond legal requirements with every safety precaution. There is a growing trend for districts to obtain liability insurance coverage from joint power authorities (JPAs) such as the School Insurance Authority (SIA) in Northern California. The purpose is to take advantage of not only the economical insurance rates but also the aggressive risk reduction training programs provided by JPAs for their member districts. However, nearly all insurance carriers, including JPAs, exclude pesticide use from liability coverage (policy exclusion clauses). As a result, districts go to considerable lengths to ensure that their decisions are sound, that all regulatory measures are followed, and that procedures are carefully documented.

Some districts believe that the best way to reduce the potential for litigation is to develop better ways of obtaining all of the pesticide information and updated regulatory information needed for thorough program documentation, especially regarding pest management decision-making, risk assessment, and hazard mitigation.

Needs and Constraints

• Although liability may appear to have some positive influence as a built-in watchdog on district pest management programs, there is a negative impact. In effect, school districts are faced with the problem of going to the considerable effort and expense involved with program improvement, whereas the potential for expensive litigation would be reduced with less district involvement with pest control. Liability, therefore, creates a disincentive for districts to improve their pest management policies and programs and is a constraint to the more widespread adoption of IPM in districts throughout the state.
• Liability can reduce pest management program effectiveness in situations where district staff are reluctant to implement program measures, because the negative consequences of potential litigation appear to far outweigh the benefits of pest control.

Each district was asked to describe the advantages and disadvantages of contracting with commercial pest control companies, rather than handling district pest control in-house with district personnel, and types of contract arrangements.

There is a wide diversity of district perspectives with respect to contracting for various pest control activities, primarily pesticide applications. On one extreme are pest management supervisors who want nothing to do with contracting, who wish to directly supervise all pest management activities in their district. On the other extreme are those supervisors who prefer to contract out all related activities. Between these extremes are districts which prefer contracting only for specific projects, such as for the control of classroom insect pests.

Advantages

Contracting is often a more economical approach to pest control than utilizing district personnel. This is especially true in situations where districts are faced with hiring additional personnel or requiring existing staff to work overtime hours. These additional personnel requirements are necessary for large projects on school grounds, particularly those involving pesticide use that are most safely done in the absence of students. This often requires district personnel to work overtime during evening, early morning, or weekend hours when school is not in session.

Contracting is also a more economical approach for individual projects than the retention of staff on a continuing basis whose special qualifications are only required infrequently. The cost of the continuing education training necessary to maintain the level of technical expertise for district staff which is equivalent to that of licensed pest control advisers is an additional burden.

Another economic advantage of contracting was that it reduced capital outlay for the purchase, maintenance, and storage of expensive yet infrequently used inventories of pesticides, equipment, and protective gear and clothing.

Some districts claim that contracting results in a more efficient use of district personnel, making them available for other maintenance responsibilities. This is due to the often sporadic nature of pest problem flare-ups, and the resulting difficulty involved with planning and integrating the control of pest problems with the other district maintenance and operations activities.

Contracting, if done exclusively, eliminates the need for maintaining a pesticide storage facility, which poses its own potential safety hazards and liability problems.

As mentioned above in the discussion of liability, some district pest managers prefer to use contractors in order to strengthen both district and personal protection against potential litigation involving pesticide use. Contracting in effect transfers pesticide regulatory compliance and pesticide use documentation efforts (not responsibility) to the contractor. Certain districts have experienced considerable improvement in both these areas as a result of contracting.

Still another reason cited for preferring contracted services is improved credibility with the public --school district staff are not associated with pesticide application and any negative images the public may have of applicators.

Disadvantages

Several districts were strongly opposed to contracting for pest management projects. These districts preferred to use in-house labor for all procedures, or at least for all but the most dangerous or complicated jobs which might require staff with unique certification, such as for structural fumigation.

A frequently cited disadvantage of contracting is lack of quality control, i.e., the inability to maintain the close supervision of project activities by pest management supervisors that is possible when work is done with district personnel. Districts with this perspective generally view their district standards as more stringent than those of contractors, concluding that contracting offers no economic advantage in terms of not using district personnel, because close monitoring of contractor activities is still necessary to insure quality control, i.e., adherence to the high district standards.

Some districts do not see the contracting advantage that other districts cite for hiring contractors to apply pesticides during evening, early morning, or weekend hours when students are absent. Although this would seem to eliminate the need for district staff to work overtime, there have been problems with arranging contractor access to school sites during these hours unless district staff are present to assist with access. Consequently, special weekend or evening arrangements may be necessary requiring school staff (on overtime) anyway.

Contracting is most widely relied upon in the smaller districts. Some of the larger districts find extensive contracting to be cost-prohibitive. Large districts are continually faced with large numbers of labor-intensive small jobs, such as backpack spraying for weed control, which can be done more cost effectively by district personnel. Contractors charge relatively high prices even for small projects, due at least in part to the high cost of union labor. For this reason, large districts generally avoid contracting for projects which primarily involve labor. However large districts will contract for such projects when other benefits outweigh the high labor costs.

Some districts are very dissatisfied with the necessity of contracting for structural pest control. This is especially true in large districts with hundreds of structures, where the expense of contracting has prevented adequate frequency of inspection and treatment. Most districts in this situation are actively pursuing alternative approaches to make adequate structural protection affordable. In one case, the district is studying the feasibility of obtaining the required licensing and equipment to handle all structural pest control with district personnel, including inspection and treatment.

Contract Arrangements

District contracts vary considerably with regard to the duties and responsibilities assumed by district pest management staff and by pest control contractors. The following variations were mentioned by district staff:

• The contractor is hired on a periodic, such as annual, basis. The contractor is on-call to perform pest control services strictly on an as-needed basis, e.g., for non-routine or unusual situations.
• The contractor is hired for routinely scheduled preventive treatments. The materials and techniques used are usually selected by the contractor.
• Contracts for individual pest control jobs are awarded on the basis of bids by competing contractors.
• Contractors are hired only for structural pest control. In some arrangements the contractor does everything autonomously, including inspections, monitoring and pest infestation evaluations, and also makes the pest control action decisions. In others, the contractor follows the close and precise directions of the school district pest manager, including pesticide selection.
• Contracts are designed so that the school district pest manager and the contractor work together as a team in decision-making. District staff may assist the contractor with applications.

There are also variations in contract payment arrangements. For convenience, some contracts designed as an on-call arrangement allow district payment by purchase order on a job-to-job basis. Some contracts are designed for payment by an open purchase order which may have a maximum dollar amount for contracted services on an annual basis.

Needs and Constraints

• Many districts are overwhelmed with the number of structures requiring inspection and treatment. Districts are dissatisfied with the expense involved for adequate frequency of structural monitoring for wood-destroying insects, and with the inconsistencies of contractor reliability for structural pest control inspections and tent (tarped for treatment) monitoring. Some districts would like to have their own staff licensed to perform these functions in order to afford more frequent and more reliable inspections.

Each district was asked to describe its pest prevention program and successful strategies used.

The programs of most districts interviewed were strongly based upon pest prevention, a fundamental element of successful IPM programs. Districts generally regard prevention as the key to meeting program objectives for reducing both the need for pesticide use and the amount of pesticide applied when treatments are necessary. A strong pest monitoring program is recognized by most school districts as an essential element of an effective pest prevention program.

Due to time constraints, monitoring conducted by district personnel is usually limited to monitoring for the presence of indoor insect and other arthropod pests (classrooms, food service areas, and storage areas), and outdoor rodent pests. Monitoring for other pests is more often done by contractors.

Districts concentrate prevention efforts on measures that reduce the supporting environment for recurring pest species. Sanitation, exclusion, and improved facility design are successful strategies used for structural protection. Proper plant selection, placement, and care is the major emphasis in landscaped areas.

Recycling programs on campus involving students have improved school ground sanitation and been effective in reducing infestations of various pests. This approach is regarded by districts involved as a very successful prevention strategy.

Some districts report that improvements in long-range budget planning have made an important contribution to improved pest prevention strategies. For example, purchasing the equipment and other materials that may be required to deal with anticipated infestations of common pests long before they arrive enables prompt response when new infestations are detected.

Sanitation

Sanitation is the most successful approach for reducing insect and rodent pests in classrooms. Many schools now have rules that will not permit students to eat or store lunches, snacks, or other foods in classrooms. This has greatly reduced problems with ants, cockroaches, houseflies, gnats, rats, mice, and other pests that are attracted indoors by food scraps, spilled drinks and food wrappers. Closing gaps around pipes extending through walls and trimming vegetation near outside walls are standard prevention strategies.

Most districts place high priority on sanitation in refuse and garbage areas. Frequency of garbage pickup is the major emphasis. However, there are problems in some districts with efforts to encourage more frequent pickups at specific sites. Districts do not have authority at each site for refuse collection or other sanitation practice; this is the authority of school principals or other site administrators.

Exclusion

As mentioned above in the discussion of organizational innovations, districts are working with vendors to insure that delivery trucks do not introduce pests to school destinations. Some districts have reached conditional contract agreements with vendors that stipulate that the vendor is responsible for excluding pests from delivery vehicles at origin. Some districts refuse to accept delivery if pests are visible in trucks or on containers at destination.

Facility Design

A major impediment to pest prevention at many sites is facility design. Schools often must pay the price many years later if pest management and other maintenance considerations were not given enough emphasis in the early planning stages. As a result, facilities may invite pest problems by providing almost ideal invasion and harborage opportunities for certain pests, and may also prevent district access for pest control efforts. Examples include buildings with soil-to-wood contact, areas in structures that trap moisture, and fence-lines without mowing strips. In some cases where maintenance considerations were included in the original planning, building additions and other modifications to accommodate campus expansion have created new design problems.

In the districts interviewed, design problems were generally greater in the older structures. In some districts, maintenance and pest management staff are involved to varying degrees with facility design. In some districts, facilities are being upgraded and retrofitted for pest prevention and ease of maintenance. This is especially true for the design considerations and structural improvements necessary for "building out" structural pests, increasing district access to vulnerable sites, and reducing the need for weed control.

In a number of districts, pest management staff, who have worked in the same district for a number of years and have watched the development of problems resulting from poor planning, are now the driving force in getting the necessary design changes made to facilitate a stronger pest prevention program.

Some of the districts interviewed feel strongly that guidelines are needed at a statewide level to insure that pest prevention is given high priority in the planning of all new facilities in every district.

Landscape Design and Maintenance

Similar to problems with facility design, some districts are now having to deal with landscape problems created by planning years ago which did not place enough emphasis on pest prevention. Many school grounds were not originally landscaped with design flexibility. Structural addition sand other changes in campus layout have crowded older plantings. Watering requirements of new plantings may be much different than older plantings in the same beds. New buildings have altered sunlight exposure of older plantings. As mentioned above, pest management staff which have worked in the district for a number of years and have watched the development of landscape problems associated with planning are often instrumental in getting the necessary changes made to facilitate a stronger pest prevention program. Today’s emphasis on pest prevention has also increased the emphasis on proper selection, placement, and care of landscape plantings.

Student, Staff, and Community Involvement

Some districts have been very successful with efforts to increase student and community awareness and involvement. The resulting increased awareness of the need for pest control also stimulates interest in pest prevention. One example is the creation of recycling programs involving students in school ground sanitation by collecting recyclable items. The school in turn donates the items to community organizations and local farms, resulting in cash rewards by county public works to the school budget for the reduced number of garbage pick-ups needed.

Other districts have been successful with funding the development of classroom training videos regarding pest problems on school grounds to stimulate student interest and awareness. Some districts with strong prevention programs have utilized professional training opportunities for staff education in preventive strategies. There are many training programs available with this emphasis, although not all districts are aware of the opportunities.

Role in Budget Planning

In some districts, pest prevention is a major consideration in district budget planning. Because timing is so important, some districts are including monitoring, preventive strategies, and pest population control alternatives in well-prepared action plans for targeted areas. Prevention measures often require considerable preparation, start-up time and materials. To use these methods, managers must become familiar with required resources for each measure well in advance of the need for implementation. In areas where problems are anticipated, resources needed for prevention of specific pests are becoming more standardized as necessary line-items in annual maintenance budgets.

Needs and Constraints

• Districts cite the need for additional resources as a major constraint for the following:
  1. Facility inspection, pest population monitoring, and problem assessment.
  2. Retrofitting of older facilities which provide pest invasion opportunities and pest harborage due to the exclusion of pest management considerations during the early stages of facility design.
     1. Installing and maintaining turf or landscaping in open fields.
     2. Periodically upgrading older facilities and equipment.
• Districts see the need for increased involvement of students, staff, parents, and the community in program planning and decision-making.
• Several districts mentioned the need for increased efforts (such as revised contract specifications) to ensure that delivery trucks do not introduce pests to school facilities.

Each district was asked to describe the importance and current extent of interdistrict communication to exchange pest management information.

Importance

Generally, the district pest managers interviewed indicate a great need for networking and information sharing with other districts. They believe that most districts would benefit if there were an more effective means of communicating and disseminating information. Of the school districts interviewed, over half indicated a desire to share information with other school districts regarding effective pest management strategies and techniques, and written policies and programs. Other types of information which are commonly shared, or for which there was an interest in sharing, included information pertaining to innovations by other districts, line and staff organization, training opportunities, current research and new developments, reliable contractors and vendors, contracting issues and processes, pest management technology including new pesticide products, and recycling programs.

A number of reasons were cited supporting the need for improved interdistrict communication. In addition to simply knowing what is going on in one’s own field elsewhere in the state, the sharing of technical information provides practical information tailored to school sites and situations. This is especially true for various pest management techniques, products, and equipment. In addition, advice pertaining to community relations, laws and regulations, and ideas to make pest management budget dollars stretch farther, are all worth the efforts to strive for better communication among school districts. District pest managers also felt that they needed to find out in a timely manner about in-service and other training opportunities. They believed that, interdistrict communication would be an efficient way to meet that need. Finally, knowing which knowledgeable pest management professionals to contact to get questions answered in a timely manner would result from improved interdistrict communication.

Current Extent of Information Sharing

Currently, the most common means of information exchange takes place on the telephone. Several districts that frequently contacted other districts reported they in turn were frequently contacted for advice or help. Although several districts reported that they currently had little or no involvement with interdistrict information sharing, they would definitely like to see such communication increase (or in some cases, begin). They indicated that they would be very willing to share pest management information with other districts if called upon.

In addition, some networking takes place as a result of mutual involvement in professional organizations such as the Pesticide Applicators Professional Association. In some regions of the state, joint power authority insurance groups, such as the School Insurance Association in Northern California, have promoted cohesion among local school districts by providing regular meetings designed for the sharing of information concerning reduction of risk associated with pesticide use. Because of fiscal constraints, the ability of district staff to attend professional meetings is decreasing and some districts would like to see this, or a similar type of district forum, expanded to a regional basis to reduce travel costs. These same districts acknowledge that finding the time to attend forums of this type would be difficult.

Several district staff felt that an electronic mail network would be a very effective way to accommodate the need for increased interdistrict communication. A newsletter with articles and columns by various individuals in the "system" could also be a very useful tool to communicate among school pest management professionals all over the state, and would probably soon be in demand outside of California as well.

Needs and Constraints

• Generally, school districts operate autonomously in their approach to problem solving. Some districts suggest that a cooperative approach among districts would be more cost-effective. One example of a problem faced by many districts is insufficient funding to purchase expensive, specialized equipment such as the trucks needed for large-scale mulching and landscape waste disposal. Large spray rigs are unaffordable for many districts. An equipment pool arrangement among several school districts and other local agencies has been very successful in the Redding area. Other immediate needs suggested by some districts for this approach include regional approaches to: public education and outreach; structural pest control contracting; establishing written IPM policies and programs and improving existing documents; and obtaining technical training, and technical and regulatory information updates.

Each district was asked to describe district relations with the community, particularly with regard to pesticide use.

Current Public Perspective

Districts generally believe that the current public perspective concerning pest management on school grounds ranges from one extreme -- that schools are overly-concerned with pest problems and control measures, especially pesticide applications, are excessive, to the opposite extreme -- that schools are not doing enough to control pest problems and control measures should be increased.

In all districts interviewed, human health and safety was reported to be the top priority in all decisions regarding pesticide use. Pesticide use is generally considered the last resort; pesticides are considered by district staff to be necessary when other alternatives are not feasible. The public generally does not have an accurate picture of pest management programs in school districts, particularly with respect to the emphasis on child safety.

While it is true that in some areas of the state the public has strongly challenged the thoroughness of school district efforts in preventing potential exposure of school children to school-use pesticides, most districts interviewed report that this is the exception, not the rule. The public more commonly wants to be kept better informed of what the school is doing, i.e., what pesticides are being used and their relative risks. Generally, most pest management activities on school grounds are not challenged by the public, due in part to the fact that districts go to great efforts to conduct control measures when there are no students on campus. This is done not only for the safety of students and school staff, but also because it simply avoids much unnecessary confusion and concern by the public who may misinterpret what they observe. For example, district employees wearing white disposable suits, knee-high rubber boots, heavy rubber gloves, and respirators has a tendency to alarm the public, regardless of the pesticide being applied. Such appearances can be a significant factor contributing to public misconceptions of a school district’s commitment to the safety and health of school children.

Need for Education and Outreach

District staff reported that the public will, more often than not, support a program it clearly understands and oppose a program that is not well understood. Districts recognize that communication and involvement of the school district with the public is an important key to the mutual understanding of the needs and concerns of both parties. For this purpose, establishing open lines for two-way communication with the public is a prerequisite.

Districts find that a concerted outreach effort is necessary to learn how the public feels about certain pest management practices and pesticides. With this information, districts can then more effectively target a public information program to address the public’s concerns. This information is most effective if it explains the pest problem(s) the district is faced with, the alternatives for dealing with these problem(s), and the technical, institutional, and economic constraints involved with the alternatives. District staff reported that this communication is sometimes done well, sometimes it is not. Consequently, the response of the public to a school district’s pest management program can range from organized outrage and protests to public award ceremonies. Both extremes have occurred in California.

Occasionally the public response to a school district’s pest management practices have been organized, vocal, and highly publicized. Organizations such as Citizens for a Better Environment, Pesticide Watch, Environmental Health Coalition, and Coalition Green have done much to publicize the activities of local school districts. In some cases districts have gone to considerable expense to explain and defend their activities. However, some public groups have been instrumental in working with districts to effect a positive change in a district’s pest management program, most notably when it resulted in a formal, written, IPM-based pest management policy. Still other benefits from the mutual efforts of organized community groups and school districts working together include school-community cooperative recycling programs, joint pest management decision-making committees (composed of district pest management specialists and knowledgeable members of the local community), and student intern and volunteer programs which involve and instruct students and volunteers in landscape management.

Needs and Constraints

• Most district staff interviewed believe that, in general, most public school districts do not place enough emphasis on efforts to increase student, staff, parent, and community awareness, understanding and appreciation of the need for pest management on school grounds, the district’s program objectives, and the proposed pest management strategies. They believe that public opposition to a good pest management program is usually the result of poor understanding resulting from an inadequate public information program.
• District staff cited the need for a more extensive public outreach effort on individual school districts’ behalf to inform the public of the effectiveness and safety of school pest management. The result would be increased public support. In many situations, inadequate public information has been largely responsible for unwarranted or unrealistic public concerns.
• Some district staff believe that all public school districts would benefit from a statewide public outreach program to inform the public of the effectiveness and safety of the many excellent district pest management programs which now exist. They believe that statewide public outreach from this perspective has been inadequate and contributes to public concerns regarding public school districts generally.
• Some district staff also believe that there is a need for a statewide public information program which provides a larger-scale, statewide approach to supplement individual district efforts in addressing public concerns. Districts which have substantially improved their pest management programs often found it difficult to convince the public that the change occurred. Districts need the support of the community for their programs. However it may take years for a district community relations program to affect a change in public attitude toward a district’s pest management program, particularly with regard to pesticide use.

Each district was asked to describe difficulties, such as interpretation or compliance, with current pesticide laws and regulations.

Licensing and Certification

The regulatory issue of most concern was that most uses of pesticides on school grounds do not require a written recommendation by a licensed agricultural pest control adviser (PCA), and do not require application by or under the direct supervision of someone who holds a Qualified Applicator Certificate (QAC).

Title 3 of the California Code of Regulations (3CCR), Section 6000, Definitions, defines "institutional use" to mean the use within the confines of, or on property necessary for the operation of buildings such as hospitals, schools, libraries, auditoriums, and office complexes. Use on property necessary for the operation of buildings includes the landscaped area, parking area, playing field, track and field, etc., that are necessary for the operation of the institution or building. Therefore an agricultural PCA license is not required for individuals who make recommendations or act as an authority on pest control on school property except in certain situations such as on the school farm, nursery, or greenhouse where it is considered to be production agriculture. Because the licensed advisers are required for public parks, golf courses, and cemeteries, many school district staff do not understand why schools are exempt from the license requirement where the need for safety seems even stronger.

A QAC is required for an applicator on school grounds only when applying restricted materials. An individual using a restricted pesticide in a school yard must be a QAC holder in the appropriate pest control category, or work under the direct supervision of a certified or licensed applicator. Most pesticides applied on school grounds are not restricted materials.

Most staff interviewed believe that changes in pesticide regulations or in district guidelines are needed which would require the PCA recommendation for all sites and situations on school property. In addition, the changes would require that any pesticide used on school property must be applied by or under the direct supervision of a QAC holder in the appropriate pest control category. Most staff interviewed believed that these changes would result in the following improvements:

1. Increased accountability of individuals using pesticides on school property, thereby increasing public confidence in school pest management programs.
2. Increased CDE and district school board administrative support of professional pest management training for district staff. The training would be required as continuing education for maintaining a PCA license or a QAC. Although district staff realize that increased district expense would result from obtaining the continuing education, they believe that the benefits would far outweigh the costs.

Staff from several districts suggested that the needed changes could be effectively accomplished by revising current district pest management guidelines (Appendix 2), with stronger licensing and certification specifications. Strong administrative support of the guidelines by both CDE and school boards would be critical for successful implementation. Staff generally agreed that this approach would be more attainable than pursuing changes in existing pesticide regulations.

Staying Current with Regulatory Changes

Some districts also have difficulty in knowing whether or not they have up-to-date information with regards to recent regulatory changes, and in knowing whether their interpretations of laws and regulations are correct. Many districts have developed good working relationships with both the county agricultural commissioner and chemical company representatives and rely on them for regular updates and interpretations.

Existing Regulatory Framework

There is considerable variation among pest managers in each district regarding interpretations of laws and regulations applicable to district programs, and understanding of the responsibilities of DPR and county agricultural commissioners. Districts with full-time personnel that specialize in pest management appear to have the best understanding of pesticide laws and regulations and California’s pesticide regulatory structure. Districts see the need for both increased interdistrict communication and increased district interaction with commissioners to insure that districts have correct interpretations of laws and regulations and are current with regulatory changes. Some district staff believe a regulatory update published and distributed to each district by either the DPR or commissioners would be a valuable tool.

District pest management staff generally believe that pesticide laws and regulations are effective in protecting schools from pesticide use and other pest management activities on adjacent properties (see discussion of "Activities on Adjacent Properties").

Several districts pointed out that school-use pesticides are usually the least hazardous and therefore compliance is simplified. Another factor which simplifies compliance is the extent that districts contract with pest control companies, placing the regulatory compliance workload on the contractors.

Additional Needs and Constraints

• Some district staff believe that a communication mechanism is needed to facilitate regular interaction and communication between school districts and regulatory agencies, primarily DPR and commissioners. In addition to assisting districts with regulatory issues, it would provide regulatory agencies with a clearer picture of the current technical, institutional, and economic considerations and constraints involved with school pest management decision-making, the extent that the safety of school children is the top priority, and the extent of voluntary efforts by district personnel to protect human health and safety and the environment.

Each district was asked to describe the importance and availability of professional-quality technical pest management training.

Importance

Virtually all district pest managers interviewed report that training is, or at least needs to be, a high district priority. Districts recognize the direct contribution made by well-trained custodians, gardeners, and pest management specialists to the safety and cost effectiveness of pest management efforts in school facilities. Districts also recognize that having such staff results in increased professional credibility and good public image, which in turn results in increased public confidence in a school district’s pest management program.

The pest management training currently available to district pest management staff comes from a wide diversity of sources. There are a number of professional organizations in California which sponsor conferences and seminars which offer training in pest management in various locations throughout the state, such as the California Association of School Business Officials, Pesticide Applicators Professional Association (PAPA), the University of California Cooperative Extension Service, and the California Agricultural Production Consultants Association. In addition to providing high quality training in pest management, these seminars frequently provide the added benefit of continuing education credits required by the State of California for maintaining qualified applicator certificates, pest control operator certificates, and pest control adviser licenses.

In addition to training from statewide organizations, many local opportunities for training also exist. Product vendors, particularly those that market pest management tools such as pesticides, frequently hold training sessions either at school sites or at company locations. Some districts are fortunate to have access to seminars sponsored by such local organizations as the Sacramento Tree Foundation for districts in the Sacramento Valley and the Los Angeles County Arboretum for districts in Southern California. Agencies such as the local county agricultural commissioner’s office, various joint power authorities such as the School Insurance Association in Northern California, among others, may also provide local training.

Some districts are fortunate to have highly trained and qualified district pest management professionals on staff who conduct in-house training for employees involved in pest management. On occasion some districts have been known to loan qualified employees to neighboring districts to conduct professional pest management training. In addition to hands-on training and informative seminars, there are also various bulletins, newsletters, video tapes, audio tapes, and industry periodicals which are available as sources of technical information. These are made available by various organizations such as the U.C. Cooperative Extension Service, Bio-Integral Resource Center (BIRC), chemical companies, trade magazine publishers, and government agencies such as the U.S. National Park Service and the U.S. EPA.

Awareness of Training Opportunities

District access (or lack thereof) to professionally organized seminars is dependent upon several factors. Familiarity of district pest management staff with the various organizations who provide training plays an important role. There are many training opportunities available, many of which are not excessive in cost but are not necessarily well known to school district pest management professionals. A few districts, for example, have individuals who are very active in PAPA and consequently are regularly made aware of numerous opportunities for very high quality training. Meanwhile, staff from other districts who are not involved or associated with the various organizations are unaware of such opportunities.

Need for Locally Based Training

Distance to training locations can be a significant factor in limiting the availability of training. Many professional training organizations limit their course offerings to relatively large population centers where they can attract the largest number of potential clients. Unfortunately, this may eliminate the affordability of the training for school districts located long distances from such areas. In addition to registration costs, travel expenses and lost work hours must also be considered as part of districts’ costs for staff training. Some districts provide registration fees, or paid time off for employees who attend training sessions, particularly if there is a license or legal certificate for which continuing education credits are needed. However, this is most common when training does not involve extensive travel, or when training organizations (usually chemical companies) are willing to provide or share district costs involved with travel to training sites.

Another reason school districts prefer more locally based training is regional focus. Training is often tailored to specific environmental, social and other considerations of the area in which the training is presented and may be only partially applicable to other regions.

Many of the districts interviewed agreed that despite the importance of pest management training for district staff, budgeted funding for such training is severely restricted. Most believed that financial assistance from any source for pest management training would be a significant contribution to the maintenance of school sites. Fortunately there are innovative approaches being used by some districts to meet district training needs despite tight budgets. One of the most successful is the local sharing of experts and expertise, thereby reducing the costs involved in training. A few districts are already poo