Pesticides move off the target site when they are sprayed, whether inside or outside. When sprayed outside pesticides drift on to nearby property resulting in off target residues. Buffer zones can eliminate exposure from spray drift on to school property. As a result, states require buffer zones around schools. In order to adequately protect against drift, buffer zones should, at a minimum, be established in a 2 mile radius around the schools property. Aerial applications should have a larger buffer zone, at least 3 miles encircling the school. Buffer zones should be in effect at all times of the day. It is especially important for spray restrictions to be in place during commuting times and while students and employees are on school grounds.
Arizona Administrative Code, section 3-365(D), requires buffer zones around schools for applications of doriferous pesticides profenofos, sulprofos, def, merphos and other pesticides with similar odoriferous characteristics. These types of pesticides are not to be sprayed within ¼ mile of a school or day care facility, whether ground or aerial application. This section also states that highly toxic pesticides cannot be applied within ¼ mile of a school or day care facility.
II. Posting Notification Signs for Indoor Pesticide Applications
States use different approaches in providing school pesticide use information to parents, students and staff. Some forms include the posting of notification signs and/or the distribution of notices directly to the affected population. Posted notification signs warn those in the school when and where pesticides have been or are being applied. This is a vehicle for basic right-to-know if the posting occurs in an area where it is easily seen by parents, students and staff. It is important to post signs for indoor pesticide applications because of the extensive period of time students and school employees spend at school. Signs posted prior to commencement of the pesticide application, not after, are more protective. The prior notification system effectively enables people to take precautionary action. Because of the residues left behind after an application, signs should remain posted for at least 72 hours. It takes time for pesticides to start breaking down and some pesticide residues can least for weeks. Signs should also be posted at all main entrances of the building and the specific area sprayed, on the main bulletin board, and, for more comprehensive notification, in the school newspaper or on the daily announcements. Posted signs should state when and where a pesticide is applied, the name of the pesticide applied and how to get further information, such as a copy of the material safety data sheet (MSDS) and the product(s) label.
Education Code, title 15 section 152, states that the governing board
of each school district is to
III. Posting Notification Signs for Outdoor Pesticide Applications
For a wider range of protection, states should require posting pesticide notification signs for outdoor pesticide applications as well. Students who play sports or people continually on the lawns represent a high risk when applications occur on school property. Dermal exposure can occur when a football player gets tackled, a soccer player slides to make a block or a student sits on the grass to eat lunch or watch a game. Inhalation exposure can occur when a player breathes in kicked up dust and dirt and pesticide residues. Even spectators at a game or passersby face inhalation exposure to pesticides that volatilize or vaporize off the treated area.
Arizona Education Code, title 15 section 152, states that the governing board of each school district is to adopt a policy on the procedures for posting signs for pesticides applied to the schools property. No further details are included in the Code.
IV. Prior Written Notification
Written notification of pesticide use is a good way to make sure that all parents, children and staff are aware and warned of pesticide use in the schools. Limited notification-based registries is a less effective means of notifying people and does not qualify as true right-to-know because of its limited scope. Requiring that individuals place themselves on registries, sometimes only with a doctors letter, afford only those who already know about toxic exposure the opportunity to be informed about pesticide use in the school. Prior notification should be 72 hours in advance to make sure the information has been received, to get further information regarding the pesticide and to make arrangements to avoid the exposure, if necessary. Notification should include the name of the pesticide(s), a summary of the adverse health effects listed on the Material Safety Data Sheet (MSDS) and label, the day and time, and area of the application and how to obtain a copy of the MSDS and label.
Arizona Structural Pest Control Commission Rules and Administrative Regulations, section 32-2307 of Arizona Administrative Code, requires the pest control operator to notify the school 72 hours before any pesticide application and again immediately before the application is to begin. Arizona Education Code, title 15 section 152, requires the school to then notify parents and staff of the proposed pesticide application within 48 hours of the commencement of the application. This section of the Education Code also requires that the governing board of each school district develop a policy and procedure for notifying parents, guardians, students and employees during the schools regular session, procedures for posting signs to identify pesticide application areas, and procedures for providing for continuing instruction for pupils who are absent because of pesticide applications on school property.
V. Prohibitions on Use
Limiting when and what pesticides are applied in and around schools is important to the reduction of pesticide exposure. Pesticides should never be applied when students or employees are in the area or may be in the area within 24 hours of the application. Numerous states specifically restrict the type and timing of pesticides that may be used in a school. In reality, certain types of pesticides, such as carcinogens, endocrine disrupters, reproductive toxins, developmental toxins, neurotoxins, persistent compounds and substances, bioaccumulative compounds and substances, toxicity category 1 acutely toxic pesticides and ground water contaminants should not be used around children.
Arizona does not have any state laws restricting school pesticide use.
VI. Integrated Pest Management
A good integrated pest management (IPM) program can eliminate the unnecessary application of synthetic, volatile pesticides in schools. The main elements of a good IPM program include: 1) monitoring to establish whether there is a pest problem, 2) identifying the causes of the pest problem, 3) addressing the cause by changing conditions to prevent problems, 4) utilizing pest suppression techniques, if necessary, that are based on mechanical and biological controls and 5) only after non-toxic alternatives have been tried and exhausted, use the least toxic pesticide. An IPM policy should include a written policy guide and a prohibited and acceptable materials list. Material that could be considered after using other methods include boric acid and disodium octoborate tetrahydrate, silica gels, diatomaceous earth, insect growth regulators, insect and rodent baits in tamper resistant containers or for crack and crevice placement only, microbe-based insecticides, botanical insecticides (not including synthetic pyrethriods) without toxic synergists, and biological (living) control agents.
Arizona's Structural Pest Control Commission is instructed (32-2304) to: "Prepare guidelines for an integrated pest management program for structural pest control practices at schools. On or before December 1 of each year, the commission shall report on the progress of preparing the guidelines to the governor, the president of the senate and the speaker of the house of representatives and shall provide a copy of the report to the secretary of state and the director of the Arizona state library, archives and public records. The guidelines shall include the following: (a) The identification of pests. (b) The establishment of a monitoring and record keeping system for regular sampling and assessment of pest populations. (c) The determination of the pest population levels that can be tolerated based on aesthetic, economic and health concerns and setting action thresholds if pest populations or environmental conditions warrant remedial action. (d) A plan to prevent pest problems through improved sanitation, waste management, physical barriers and the modification of habitats that attract or harbor pests. (e) The reliance on nontoxic, biological, cultural or natural control agents. (f) The use of pesticides, if necessary, with preference for products that are the least harmful to human health and the environment."
OF STATE SCHOOL PESTICIDE LAW
Dragonfleye Charter School
Date Passed: 1995
IPM: The school maintains a "chemically free" school, no chemical pesticides or herbicides are used. Lizards and spiders are used as pest controllers and diatomaceous earth is used for controlling ants and sewer roaches.
Notification: Is not applicable-school policy does not permit chemical pesticides.
Prohibition of Use: Pesticides, herbicides, toxic cleaning products, wallpaper paste, paint and fragrances are prohibited.
Other: The school contracts their pest management through Pristine Products (1-800-266-4968).
School Contact: Gail Battistella, Director of Dragonfleye Charter Schools, 10202 North 19th Ave., Phoenix, AZ 85021. Phone: (602) 944-4322