I. Restricted Spray Zones Around School Property
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 school’s 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.
Rhode Island does not have any statewide requirements regarding restricted spray zones around school property.
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.
Rhode Island does not have any statewide posting requirements for indoor pesticide applications.
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.
Rhode Island Rule T, promulgated by the Rhode Island Pesticide Control Law, requires signs to be posted before a commercial applicator begins a pesticide application to school grounds, playgrounds or athletic fields. The signs must remain posted for 72 hours. The school is responsible for posting the signs. The signs state the name of the pesticide(s) applied.
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 right-to-know because of its limited scope. Requiring that individuals place themselves on registries, sometimes only with a doctor’s 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.
Each school shall maintain a registry of persons requesting prior notification. Notification shall be given to parents and guardians who have registered for prior notice 24 hours prior to the application. Notice shall be given by any means practicable to school staff who have registered for the notice. Also, notice of any pesticide application at a school shall be given, by any means practicable, to the parents or guardians of any child enrolled at the school and to the staff of the school not later than one week after the application.
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. 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.
No applications of pesticides may be made in any building or on the grounds of any school during regular school hours or during planned activities at any school, except that an emergency application may be made to eliminate an immediate threat to human health.
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.
Rhode Island law specifically directs the Departments of Environmental Management and Health to "develop regulation to restrict the use of hazardous pesticides in schools, pre-schools and child care centers in Rhode Island; (2) for the promotion and implementation of IPM and (3) to cover situations where an emergency application must be conducted to eliminate an immediate threat to human health, and establish reporting requirements for these emergency applications." IPM Guidelines and Policy for School Pest Management.
COPY OF STATE SCHOOL PESTICIDE LAW
Rhode Island Pesticide Control Law: Pesticide applications and notification of applications at schools.
Rhode Island Pesticide Control Law: Pesticide applications and notification of pesticide applications at pre-schools and child care centers.
Rhode Island Pesticide Control Law: Posting notification signs for outdoor pesticide applications
Beyond Pesticides is unaware of any schools implementing an IPM policy in the state of Rhode Island. If you have any information please contact us at [email protected]
For more information contact
Beyond Pesticides, 701 E Street, S.E., Suite 200, Washington, DC, 20003, [email protected]