Don Quixote [also known as the Maryland Pesticide Network and their cohorts] is alive and well — chasing through Maryland waving his swords at the state’s public schools and the Maryland Department of Agriculture in two recently released "reports":
• Are We Passing the Grade: Assessing MD Schools’ Compliance with IPM-in-Schools Law.
• Are We Passing the Grade: Maryland Department of Agriculture’s Failure to Comply with the Integrated Pest Management-in-Schools Law.
These organizations exist at all levels. Despite their claims to the contrary, their mission is to deplete our toolbox of all pesticides and replace them with products that, in their opinion, are suitable replacements for the reduced risk pest management products being used. It is easy to respect another point of view and to negotiate reasonable solutions when dealing with rational people. These groups are well organized and play off misinformed perceptions of pesticides to garner support for their cause — banning all pesticide use. They typically do not negotiate openly; they distort the facts, use innuendo and selectively cite research that supports their cause.
HOT BUTTON. One of the most contentious issues I have with the anti-pesticide element is their bastardization of the term Integrated Pest Management, which they have re-shaped to suit their needs. Specifically, the MPN report states, "Pesticides do not play an important role in IPM. In fact, pesticides are considered a last option if included at all in an IPM program." This statement reflects either the authors’ lack of knowledge regarding IPM or their unwillingness to accept its true principles in an effort to further their cause.
Historically, IPM was a concept developed for agricultural applications almost 50 years ago. The concept was simple and designed for one purpose — to reduce the unnecessary application of pesticides in preventing crop damage and in turn save money. To accomplish this, non-chemical means were used to suppress pest populations; however, when these populations exceeded a predetermined level (the economic threshold) only then would pesticides be applied to reduce pest numbers. Pesticide applications would not be made again until the threshold was exceeded.
It would be nice if we could stick to one sheet of music when we are crafting language for IPM and not rewrite it to suit individual and group agendas. For instance, compare the following definitions of IPM:
• MPN promulgated the following Maryland statute — "Integrated pest management" means a managed pest control program in which methods are integrated and used to keep pests from causing economic, health related, or aesthetic injury through the utilization of site or pest inspections, pest population monitoring, evaluating the need for control, and the use of one or more pest control methods including sanitation, structural repair, nonchemical methods, and, when nontoxic options are unreasonable or have been exhausted, pesticides…(MDA regulation: and pesticides, when nontoxic options are unreasonable or have been exhausted …)
Talk about splitting hairs over a definition — MPN went so far as to request the state’s attorney general to interpret and comment on this split hair (statute vs. regulation). MPN’s contention is that the regulation as quoted in training manuals "infers that the use of pesticides in the schools is equal to non-toxic practices, rather than a strategy of last resort." Even in their own words they misquote the statute (there is no mention of "last resort").
The unfortunate aspect of this is that a coalition of stakeholders, including organizations that had strong feelings about pesticide use in schools headed by the U.S. Environmental Protection Agency, formulated a definition of IPM for use in developing school IPM policies:
EPA (1993): Pest Control in the School Environment: Adopting Integrated Pest Management — "IPM is an effective and environmentally sensitive approach to pest management that relies on a combination of common sense practices. IPM programs use current, comprehensive information on the life cycles of pests and their interactions with the environment. This information in combination with available pest control methods is used to manage pest damage by the most economical means and with the least possible hazard to people, property, and the environment. IPM programs take advantage of all pest management options possibly including but not limited to the judicious use of pesticides."
Apparently, this definition was rejected by MPN because it did not suit their goal of banning pesticides in schools. These reports are full of similar criticisms of MDA and the Department of Education and they have no more substance than the previous issue.
WHO’S THE BOSS? There is an inherent problem with this concept in structural environments — economic thresholds have rarely been established because typically the threshold is aesthetic and set by the customer at one. One mouse in the school, one cockroach in the food service area, or one wasp nest near an entry way are enough to provoke an unequivocal request for immediate remediation. This does not mean a pesticide application must be made, but it is not a tool we want to discard.
In public schools, the question remains — who determines the course of action for a pest problem. Is it a teacher, custodian, principal, and/or parents? Having worked in what I consider one of the most effective IPM school programs in Maryland (despite the findings of MPN) intervention is determined in consultation with the school and the county school system’s IPM coordinator. In my experience during the last six months, and observing the IPM services provided in my wife’s school, I have made some firsthand observations of our state’s IPM in schools program promulgated by MPN:
• One of the schools cited for excellence in implementing IPM in schools uses little if any pesticides; however, cockroaches and mice are frequent problems in the classrooms. And contrary to the MPN’s unscientific claim that pesticides are allergens responsible for causing asthma in children, mice and cockroach allergens have been repeatedly demonstrated to be the most significant cause of childhood asthma (Rosenstreich et. al, 1997, New England Journal of Medicine).
• This same county also has misused an EPA registered disinfectant to disinfect ant trails, i.e., to kill ants.
• When IPM (the MPN non-chemical approach) has failed, i.e., the structural threshold of one is exceeded, teachers and staff resort to their own means, e.g., sprays and baits. This is a worse outcome than the judicious use of pesticides by certified pest management professionals.
THE FUTURE. Our (Maryland) Departments of Agriculture and Education have done an admirable job in implementing the IPM in schools legislation (in my opinion an onerous one) in such a short period of time and under severe budget constraints. Any new program needs to be adjusted as it moves forward and pesticide use reduction is an admirable goal and the frivolous criticisms leveled by MPN in these two documents simply slow the process.
For IPM to work in the school systems as promulgated my MPN and their cohorts at least two things need to occur in each county:
• A dedicated IPM coordinator who is trained in IPM — a person not assigned the position as an additional duty.
• A comprehensive preventive maintenance program that is meticulous and trained in pest prevention.
MPN and their cohorts like to tell us how to walk the walk, isn’t it about time they walk it with us.
The author is technical director of American Pest Management, Takoma Park, Md. He can be reached at 301/891-2600 or rkramer@giemedia.com.
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