Integrated Pest Management Plan

Introduction

In January 1990 in his message, Peace with God the Creator, Peace with All of Creation, Pope John Paul II reminded all peoples of the world as to their moral responsibility in caring for our global ecosystem:

"Certain elements of today's ecological crisis reveal its moral character. First among these is the indiscriminate application of advances in science and technology.... Unfortunately, it is now clear that the application of these discoveries in the fields of industry and agriculture have produced harmful long-term effects. This has led to the painful realization that we cannot interfere in one area of the ecosystem without paying due attention both to the consequences of such interference in other areas and to the well-being of future generations."

Subsequently, in June 2002, the Holy Father further expressed the Church's concern for the detrimental impact upon the world's population and upon all of God's creation from:

"... the degradation of some basic natural resources such as water, air and land, brought about by an economic and technological progress which does not recognize and take into account its limits..... An awareness of the relationship between God and humankind brings a fuller sense of the importance of the relationship between human beings and the natural environment, which is God's creation and which God entrusted to us to guard with wisdom and love (cf. Gen 1:28).... It is love for our children that will show us the path that we must follow into the future (Declaration on the Environment)."

The philosophy of Sacred Heart School calls for us to impart an intellectual and a spiritual framework from which our students can draw strength to promote positive social change. To this end, we guide our students to develop into well-rounded, responsible, and caring individuals with an informed moral conscience based on the Word of God. The Integrated Pest Management Policy of Sacred Heart School (SHSIPM) draws not only upon this unique mission, but moreover upon the teachings of the Church concerning the sacredness of the environment and our obligations as stewards of God's creation.

Policy Statement

The Integrated Pest Management Policy of Sacred Heart School (SHSIPM) seeks to resolve conflicts and redirect pest control efforts toward least hazardous practices. As such, any methods used in the management of pests will not exclude the application of pesticide agents, but will minimize their use whenever possible. Sacred Heart School acknowledges that a safe, sanitary and healthy learning environment is required for students and educators. Therefore, we will concentrate our efforts on developing and implementing long-term pest prevention methods favoring non-chemical control measures and other means posing the least possible threat to persons or the environment. Sacred Heart School will make every effort to prevent pest infestations through economically feasible methods.

In accordance with applicable NJ State statutes, the goal of our policy is to eliminate or mitigate the economic, health, and aesthetic damage caused by pests at Sacred Heart School. Additionally, our policy is designed to reduce the volume of pesticides used on school property so as to minimize the potential hazards posed by these agents to human health and the school environment. The procedures to be used will include site or pest inspections, pest population monitoring, an evaluation of the need for pest control, and one or more pest control methods, such as sanitation, structural repair, mechanical and biological controls, and other nonchemical methods. When nonchemical options are ineffective or unreasonable, our policy allows for the use of a pesticide, with a preference towards the use of a low impact pesticide.

The Integrated Pest Management Program of Sacred Heart School (SHSIPM) includes the following elements:

(a) Identification and monitoring of pests to determine pest population levels as a basis for decisions and practices that could affect said pest populations.

(b) Establishment of action levels to determine when vegetation or a pest population causes unacceptable economic or medical damage requiring corrective action.

(c) Modification and/or elimination of pest habitats to deter pest populations and minimize pest infestations.

(d) Consideration of the use of a range of potential treatments for identified pest problems, including physical, horticultural, and biological methods of control over that of chemicals that could pose a potential hazard to persons and the environment.

Definition of An Integrated Pest Management Program

Under the School Integrated Pest Management Act of New Jersey, the Legislature recognizes that the United States Environmental Protection Agency has recommended the use of an integrated pest management system by local educational agencies, which emphasizes nonchemical ways of reducing pests, such as sanitation and maintenance. An integrated pest management is an effective and environmentally sensitive approach to pest management that relies on common sense practices and uses current comprehensive information on the life cycles of pests and their interaction with the environment. This information, in combination with available pest control methods is used to manage pest damage with the least hazard to people, property and the environment and by economical means.

Integrated pest management programs take advantage of all pest management options possibly including, but not limited to, the judicious use of pesticides. A notification process should be established by schools under which each student, parent, guardian, staff member, and teacher will be notified of a pesticide application. Parents and guardians have a right to know that there is an integrated pest management system in their children's school and that such a program provides long-term health and economic benefits. Furthermore, parents and guardians have a right to be notified in advance of any use of a pesticide in their children's school.

The statute defines a "low impact pesticide" as any pesticide or pesticidal active ingredient alone, or in combination with inert ingredients, that the United States Environmental Protection Agency has determined is not of a character necessary to be regulated pursuant to the Federal Insecticide, Fungicide, and Rodenticide Act and that has been exempted from the registration and reporting requirements adopted pursuant to that act; any gel; paste; bait; antimicrobial agent such as a disinfectant used as a cleaning product; boric acid; disodium octoborate tetrahydrate; silica gels; diatomaceous earth; microbe-based insecticides such as bacillus thuringiensis; botanical insecticides, not including synthetic pyrethroids, without toxic synergists; and biological, living control agents.

A "pesticide" means any substance or mixture of substances labeled, designed, intended for or capable of use in preventing, destroying, repelling, sterilizing or mitigating any insects, rodents, nematodes, predatory animals, fungi, weeds and other forms of plant or animal life or viruses, except viruses on or in living man or other animals. A pesticide also includes any substance or mixture of substances labeled, designed or intended for use as a defoliant, desiccant or plant regulator.

Practices and Procedures

The following are the practices and procedures established under the Integrated Pest Management Program of Sacred Heart School (SHSIPM):

(1) The school principal and/or his/her designee (Terminix) in consultation with the pastor, director of school maintenance, and other parish staff will serve as the integrated pest management control coordinator. The responsibilities of this individual will be to maintain information about the school's integrated pest management policy including a record of pesticide applications on the property by personnel or contractors; to act as a contact for inquiries concerning this policy; and to maintain material safety data sheets, when available, and labels for all pesticides used on the property.

(2) The school principal and/or his/her designee (Terminix) will request from the pesticide contractor and will maintain records of pesticide applications used on the Sacred Heart School property for three years after the application, and for five years after the application of a pesticide designed to control termites, and on request, will make the data available to parents and the public for review.

(3) The school principal and/or his/her designee (Terminix) will include a notice of the integrated pest management policy in the school calendar/handbook, newsletter(s), and/or on the school's website.

The notice will include:

(a) a list of any pesticide that has been used in the prior twelve months on school property;

(b) a statement that the integrated pest management coordinator maintains available product label/material safety data sheets of each pesticide in use on school property, which may be reviewed by parents/guardians, staff members, or students; and

(c) a process wherein the integrated pest management coordinator can be contacted by parents/guardians and staff members for information and comment.

Additionally, the following statement will be disseminated to all parents/guardians and staff members on an annual basis:

"As part of a school pest management plan, Sacred Heart School may use pesticides to control pests. The United States Environmental Protection Agency (EPA) and the New Jersey Department of Environmental Protection (DEP) register pesticides to determine that the use of a pesticide in accordance with instructions printed on the label does not pose an unreasonable risk to human health and the environment. Nevertheless, the EPA and DEP cannot guarantee that registered pesticides do not pose any risk to human health, thus unnecessary exposure to pesticides should be avoided. The EPA has issued the statement that where possible, persons who are potentially sensitive, such as pregnant women, infants and children, should avoid unnecessary pesticide exposure."

(4) Whenever the school principal and/or his/her designee (Terminix) determines that an agent, other than a low impact pesticide, must be used on school property, the parents/guardians of each student and every staff member will be notified at least 72 hours in advance of the application of the pesticide. If the date of the application of the pesticide must be extended beyond the period required, the notice will be reissued for the new date of application.

The notice will include:

(a) the common name, trade name, and Federal Environmental Protection Agency registration number of the pesticide;

(b) a description of the location of the application of the pesticide;

(c) a description of the date and time of application plus alternate dates in the case of outdoor treatments;

(d) a statement from The Office of Pesticide Programs of the United States Environmental Protection Agency that, "Where possible, persons who potentially are sensitive, such as pregnant women, infants, and children, should avoid any unnecessary pesticide exposure";

(e) a description of potential adverse effects of the pesticide based on the material safety data sheet, if available, for the pesticide;

(f) a description of the reasons for the application of the pesticide;

(g) the name and telephone number of the integrated pest management coordinator for the school; and

(h) any additional label instruction and precautions related to public safety.

Additionally, a sign of at least 8inches x 11 inches will be posted 72 hours in advance and following the application that provides notice of the application of the pesticide in or adjacent to the location to be treated and at each entrance to the buildings. In the case of outdoor pesticide applications, each sign will include three dates, in chronological order, on which the outdoor pesticide application may take place if the preceding date is canceled due to weather.

(5) A pesticide, other than a low impact pesticide, may be applied on school property in response to an emergency, without complying with the above aforementioned procedure. Within 24 hours after the application of a pesticide or on the morning of the next school day, whichever is earlier, the principal and/or his/her designee (Terminix) will provide each parent/guardian and staff members notice of the application of the pesticide for emergency pest control. The notice will include all components previously delineated plus a description of the problem and the factors that qualified the problem as an emergency that threatened the health or safety of a student or staff member and if necessary, a description of the steps that will be taken in the future to avoid emergency application of a pesticide. A sign warning of the pesticide application at the time of the application will be posted as described herein.

(6) A pesticide, other than a low impact pesticide, will not be applied on school property where students are expected to be present for academic instruction or for organized extra-curricular activities prior to the time prescribed for re-entry to the application site by the United State Environmental Protection Agency on the pesticide label, except that where no specific numerical re-entry time is prescribed on the label. Such a pesticide, other than a low impact pesticide, will not be applied on school property where students are expected to be present for academic instruction or for organized extra-curricular activities within seven hours of the application.

(7) A pesticide, other than a low impact pesticide, will not be applied in the school buildings when students are present. Students will not be present in an untreated portion of the school buildings unless the area being treated with a pesticide, other than a low impact pesticide, is served by a separate ventilation system and is separated from the untreated area by smoke or fire doors.

(8) A low impact pesticide may be applied in areas of the school buildings where students will not contact treated areas until sufficient time is allowed for the substance to dry or settle, or after the period of time prescribed for re-entry or for ventilation requirements on the pesticide label has elapsed accordingly. This provision will not apply to public health officials during the normal course of their duties.

(9) A commercial pesticide contractor will not be liable to any person for damages resulting from the application of a pesticide at Sacred Heart School if the damages are solely due to our failure.

Commercial Contractor Requirements

A thorough, initial inspection shall be conducted before the start of each school year by the contractor representative and the school pest control manager. The purpose of this initial inspection will be to allow the contractor to evaluate the pest management needs of the property. The following specific points will be addressed: (a) identification of problem areas in and around the school buildings; (b) identification of structural features or personnel practices that are contributing to pest infestations; (c) discussion of the effectiveness of previous control efforts; (d) facilitation of contractor access to all necessary areas; and (e) informing the contractor of any restrictions or special safety precautions, or other constraints.

The contractor must submit a detailed Pest Management Plan and service schedule for the school property for review and approval by the principal and/or his/her designee (Terminix). This written plan and schedule must address the following points: (a) the structural and operational actions to inhibit pests; (b) the means for monitoring pest populations in and around the building; (c) the proposed primary pesticides (accepted common name and generic name) and alternatives approved by the Environmental Protection Agency (EPA); and (d) the conditions requiring application.

As a general rule, application of pesticides in any area inside or outside the premises in any room, closet, hallway, stairwell, driveway, planting bed, and similar locations will not occur unless inspections or monitoring indicate the presence of pests that exceed action thresholds in that specific area. Signs of pest activity must be seen and identified by the contractor. The use and effectiveness of alternative nonpesticidal pest management methods must be documented in monitoring records prior to requesting the use of pesticides. Preventive pesticide treatments of inside and outside areas where inspections indicate a potential insect or rodent infestation will be considered generally unacceptable. In exceptional circumstances, however, preventive pesticide treatment may be allowed on a case-by-case basis.

The contractor is responsible for maintaining a complete and accurate Pest Management Log Book which must contain a copy of the current label and EPA registration number for each pesticide used in the buildings, including the Material Safety Data Sheet. Pest monitoring data sheets must record in a systematic fashion the number of pests or other indicators of pest population levels for the buildings. The location of all traps, trapping devices, and bait stations in or around the property.

The contractor must provide only qualified pest management personnel with adequate experience. It is the contractor's responsibility to perform all work according to the detailed Pest Management Plan and schedule developed for the school property. The contractor must observe all safety precautions and is responsible for the proper use of pesticides. All pesticides used by the contractor must be registered with the EPA and state and/or local jurisdiction. Transport, handling, and use of all pesticides must be in strict accordance with the manufacturer's label instructions and all applicable federal, state, and local laws and regulations.

The contractor must minimize the use of synthetic organic pesticides wherever possible through the use of alternatives methods such as crack and crevice application of pesticides to pest harborage areas rather than fan spraying exposed surfaces in the general vicinity of harborage areas. Pesticide fogs and sprays (including mists and ultralow volume applications) will be restricted to unique situations where no alternative measures are available or practical. All rodenticides, regardless of packaging, must be placed either in locations not accessible to children, pets, wildlife, and domestic animals, or in EPA-approved tamper-resistant bait boxes.