HomeMy WebLinkAboutMINUTES - 05261987 - S.3 TO: BOARD OF SUPERVISORS
FROM:
Contra
Supervisor Nancy Fanden a4 ^_S+a
DATE: I Ill
May 19, 1987 County
PESTICIDE USE IN SCHOOL DISTRICTS
SUBJECT:
SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION
RECOMt MATION:
That Phil Batchelor, County Administrator, review the report
by Citizens for a Better Environment ( CBE) on pesticide use
in school districts in Contra Costa County, and report back
to the Board with a recommendation.
BACKGROUND:
Enclosed is a new report by CBE on pesticide use in school
districts. CBE is concerned about the overuse and possible
misuse of pesticides in school districts because pesticide
exposure has the potential to cause both long and short-teem
health problems and children are particularly at risk.
The two primary recommendations for the Department of
Agriculture are to: '
1) require that all school districts record and thoroughly
report both restricted and unrestricted pesticide use to
the County; and
2) inspect all school districts which do any chemical pest
control including at least one inspection of an actual
application each year.
CONTINUED ON ATTACHMENT: YES SIGNATURE:
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S)
ACTION OF BOARD ON May 26, 1987 APPROVED AS RECOMMENDED X_ OTHER
VOTE OF SUPERVISORS
X —
UNANIMOUS (ABSENT ) I HEREBY CERTIFY THAT THIS.IS A TRUE
AYES: NOES: AND CORRECT COPY OF AN ACTION TAKEN
ABSENT: ABSTAIN: AND ENTERED ON THE MINUTES OF THE BOARD
OF SUPERVISORS ON THE DATE SHOWN. -\
CC: County Administrator ATTESTED /" J<. 0Z 4i
— i; Phil Datehei r,Clerk of the Board of
- Supem*Irsand County Administrator
\M382/7-83 BY DEPUTY
4 May 1987 CITIZENS
Supervisor Nancy Fanden FOR
District 2 A
4300 Garden Rd. B ETT E R
E1 Sobrante, CA 94803
ENVIRONMENT
Dear Supervisor Fanden,
Please find enclosed a new report by Citizens for a Better Environment (CBE) on
pesticide use in school districts in Contra Costa County. CBE is concerned
about the overuse and possible misuse of pesticides in school districts because
pesticide exposure has the potential to cause both long and short-term health
problems and children are particularly at risk. Most school district pest
problems can be effectively dealt with without the use of pesticides.
One of the report's conclusions is that the County Department of Agriculture
does not provide sufficient oversight of pesticide use in schools. Only seven
of seventeen districts whose staff apply pesticides submitted any pesticide use
reports to the County (for unrestricted pesticides, these reports are requested
but not required by the County). Only four of 1400 reported district staff
applications were inspected by the County in the last three years.
-CBE urges the Contra Costa County Board of Supervisors to demand that the
Agricultural Commissioner take action to carry out the recommendations of the
report. The two primary recommendations for the Department of Agriculture are
to:
1) require that all school districts record and thoroughly report both
restricted and unrestricted pesticide use to the County; and
2) inspect all school districts which do any chemical pest control including
at least one inspection of an actual application each year.
The County Department of Agriculture is the only agency which monitors school
school district pesticide use. Without more thorough oversight it is not
possible to ensure that pesticides are being used safely. CBE has also provided
copies of this report to all of the school districts, recommending that each
district adopt a pest management policy that will reduce or even eliminate
pesticide use and that requires public notification of all pesticide
applications.
Please review this report carefully. I am available to answer questions in
person or by phone (at either the Berkeley or San Francisco office). Please
inform me of any action you take.
Sincerely,
Diane Bush
Research Associate
cc : John de Fremery, Agricultural Commissioner
Dan Bergman, Director, County Dept. of Environmental Health
Ronald Stewart, Superintendent, County Office of Education
State -Headquarters: 942 Market Street, Suite 505 San Francisco, CA 94102 (415) 788-0690
2131 University Ave.,Suite 400 971 N. La Cienega Blvd., Suite 204 121 Cedar St.
Berkeley,Ca. 94704 Los Angeles, Ca.90069 Santa Cruz,Ca.95060
(415)841-6163 (213)659-7245 (408)458.5053
CBE
off
PEST CONTROL OR POISONED GROUNDS?
An Assessment of Pesticide Use
in Contra Costa County's Public Schools
CITIZENS FOR ABETTER ENVIRONMENT
MAY 1987
Prepared by:
Diane Bush
Elizabeth Sweet
d
ornnronm rIT
State Headquarters: 942 Market Street, Suite 505 San Francisco,CA 94102 (415)788.0690
2131 University Ave.,Suite 400 5539 West Pico Blvd. 121 Cedar St.
Berkeley,Ca.94704 Los Angeles,Ca.90019 'Santa Cruz,Ca.95060
(415)841-6163 (213)9350117 (408)458-5053
PEST CONTROL OR POISONED GROUNDS?
An Assessment of Pesticide Use
in Contra Costa County's Public Schools
Project Director: Diane Bush
Project Assistant: Elizabeth Sweet
CITIZENS FOR A BETTER ENVIRONMENT (CBE) is a California state,
non-profit organization working toward effective solutions to urban
pollution problems that affect human health and the environment.
CBE - San Francisco CBE - Berkeley
942 Market Street, #505 2131 University Ave. #400
San Francisco, CA 94102 Berkeley, CA 94704
(415) 788-0690 (415) 841-6163
CBE appreciates the generous editing assistance of Steve Dreistadt,
former CBE Research Associate, and time volunteered by Elizabeth
Sweet, for gathering data. CBE also appreciates the cooperation and
assistance of the Contra Costa County Department of Agriculture, and
of the school district staff who responded to our survey.
Copyright 1987. Citizens for a Better Environment.
caG'BE� � � o
EXECUTIVE SUMMARY
Pesticides are widely used in school districts in Contra Costa County and are
cause for concern due to pesticide toxicity, the lack of County oversight and
the lack of school district policy on how and when pesticides will be used.
Citizens for a Better Environment (CBE) has found that pesticides are applied in,
and around schools and other facilities in all but one of nineteen school
districts in Contra Costa County, by district staff, commercial contractors, or
both. Yet no school district in Contra Costa County has a formal written policy
on pesticide use, and no district posts written notices in areas where
pesticides have recently been applied. In addition, CBE found that of the
seventeen districts whose staff apply pesticides, only seven districts submitted
any pesticide use reports to the County Department of Agriculture, the only
agency which supervises major pesticide users. Only one of these seven
submitted all twelve reports for all three years.
Use of pesticides in our schools poses an unnecessary health risk to children.
All three of the pesticides most widely used by school staff are suspected
carcinogens. Eight of the pesticides used will be undergoing a health risk
assessment by the California Department of Food and Agriculture because of
adverse health effects notedin a recent review of pesticide health data. Three
fourths of the districts inspected by the County Department of Agriculture were
found to have violated state or federal pesticide regulations.
The County Department of Agriculture does not provide adequate oversight of
pesticides used in school distrcts. In addition to the monthly pesticide use
reports , inspections by the County are the only other method of pesticide use
oversight. Of the 1397 reported applications during 1984-1986 only four were
inspected by the County. As most districts do not report pesticide use to the
County, the actual number of district staff applications is much greater. In
addition, seventeen districts also contract out with commercial pest control
companies. For these companies , the County inspected an average of one of every
10,000 applications.
The County Department of Agriculture should inspect at least one pesticide
application each year for all of the school districts whose staff apply
pesticides. The County should also consistently require that all school
districts submit monthly reports on all pesticide applications.
School districts must take greater responsibility in ensuring that pesticides
are applied only when safer alternatives are not feasible. Each school district
should adopt a pest management policy that reduces pesticide use in favor of
non-toxic alternatives , requires public notice of all pesticides applied, and
requires that public records be kept on all pesticides applied by staff and
contracted PCOs. Many school district pest problems can be more effectively
managed while reducing the use of toxic chemicals. Several school district
programs which can serve as models for more safe and effective pest management
are described.
-page i-
l
SCHOOL DISTRICTS
CONTRA COSTA COUNTY
JOHN SWETT OAKLEY
UNIFIED _ UNION
PITTSBURG
UNIFIED
ANTIOCH
UNIFIED ,-----
MARTINEZ Z� KNIGHTSEN
UNIFIED MT.DIABLO
RICHMOND UNIFIED UNIFIED �--
_i
ti
BRENTWOOD UNION RINDA
`+
UNION iLAFAYETTEI WALNUT LIBERTY
-, I CREEK UNION H.S.D.
ACALANES� 1
UNION H.S.D.',
1 - J BYRON UNION
_ 1 '
CANYON \
�.MORAGA SAN FIAMON VALLEY UNIFIED
-Frage ii-
aCBE� � ° o
TABLE OF CONTENTS
Section Page
EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
MAP OF CONTRA COSTA COUNTY SCHOOL DISTRICTS . . . . . . . . . . . . . . .
TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . .
LIST OF TABLES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
INTRODUCTIONS AND OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . 1
REGULATORY BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . 3
CONCLUSION # 1:
PESTICIDES ARE WIDELY USED BY PUBLIC SCHOOLS IN CONTRA COSTA COUNTY
WITHOUT FORMAL PESTICIDE USE POLICIES OR ADEQUATE OVERSIGHT . . . . 7
Richmond . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Mt. Diablo '11
Contra Costa�Community*College 14
Lafayette . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Acal anes . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Martinez . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Ori nda . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
CONCLUSION # 2:
THE OVERUSE OF PESTICIDES IN SCHOOLS POSES AN UNNECESSARY HEALTH
RISK TO OUR CHILDREN . . . . . . . . . . . . . . . . . . . . . . 23
CONCLUSION # 3:
THE COUNTY DEPARTMENT OF AGRICULTURE DOES NOT PROVIDE ADEQUATE
OVERSIGHT OF SCHOOL DISTRICT PESTICIDE USE . . . . . . . . . . . . . 27
Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
RECOMMENDATIONS FOR INCREASED COUNTY DEPARTMENT OF
AGRICULTURE OVERSIGHT OF SCHOOL DISTRICT PESTICIDE USE . . . . . . . 32
CONCLUSION #4:
SCHOOL PEST PROBLEMS CAN BE CONTROLLED WITHOUT THE EXTENSIVE
USE OF PESTICIDES . . . . . . . . . . . . . . . . . . . . . . . . . 33
RECOMMENDATIONS FOR SAFE PEST CONTROL
BY SCHOOL DISTRICTS IN CONTRA COSTA COUNTY . . . . . . . . . . . . . 34
REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
-page iii-
LIST OF TABLES
Table 1: Reported Pesticide Use by School Districts in
Contra Costa County, 1984-1986 . . . . . . . . . . 9
Table 2: Pesticide Use Reported by the
Richmond Unified School District . . . . . . . . . . .. . . . 12
Table 3: Pesticide Use Reported by the
Mount Diablo Unified School District . . . . . . . . . . . 13
Table 4: Pesticide Use Reported by the
Contra Costa Community College District . . . . . . . . . . 15
Table 5: Pesticide Use Reported by the
Lafayette School District . . . . . . . . . . . . . . . . . 16
Table 6: Pesticide Use Reported by the
Acalanes . Union High School District . . . . . . . . . . . . 18
Table 7: Pesticide Use Reported by the
Martinez Unified School District . . . . . . . . . . . 19
Table 8: Pesticide Use Reported by the
Orinda Union School District . . . . . . . . . . . 19
Table 9: Inspections and Violations for School District
. Pesticide Use in Contra Costa County 1984-1986 . . . . . 21
Table 10: Restricted Materials Permits and
I Notices of Intent to Spray 1984-1986 . . 26
-page iv-
SCBER �
INTRODUCTION AND OBJECTIVES
This report has been prepared to inform the public and public decision makers
about hazardous pesticide use and pest problems in their schools. This report
will also assist school districts in Contra Costa County in evaluating their
current pesticide use, as a first step towards developing safer and more
effective pest control methods.
Pollution of the urban environment with toxic chemicals is a problem of special
concern to the public in Contra Costa County. Pesticides are an important and
often unconsidered portion of urban toxic exposure and an area where conscious
choices can easily be made to limit the public's exposure. Tens of millions of
pounds of pesticides are applied in urban areas of California each year.
Contrary to popular belief, on a per acre basis the intensity of urban pesticide
use may be greater than the annual rate applied to an average acre of
agricultural land (1). Public agencies such as public works, housing, parks and
road departments, and schools apply large amounts of pesticides in urban areas.
Although this report focuses on pesticide use in schools, many of the criticisms
and recommendations offered apply to most public agency pesticide use.
Pesticides are poisons, and pesticide exposure can pose a threat to the health
of school children. Children, with their faster growing and breathing rates and
lower body weights , are more susceptible to hazardous chemicals such as
pesticides than are adults. Yet school districts continue to use chemicals such
as 2,4-D and lindane, both of which are being phased out of many uses because of
serious health risks associated with exposure.
-page 1 -
Pesticide applications are not the only way to control pests. Often they are
not even the most effective method. Most indoor pests can be controlled with
good maintenance and housekeeping, by eliminating food, shelter, entryways and
breeding ,areas. Many insect pests can be controlled with natural enemies.
Weeds can be excluded through methods including denser planting of shrubs and
concrete "footers" under fencelines. A few school districts in the country have
begun to adopt some of these safer pest control techniques to reduce or
eliminate the use of pesticides on their school grounds (see "Conclusion ff 4" ,
page,_ 33).
In order .to begin developing safer pest control policies and practices, Contra
Costa County's school districts must first evaluate their current pesticide use
and pest control practices, including contracting out for pest control . This
report is a result of CBE's review of Contra Costa County Department of
Agriculture records on school district pesticide use from 1984 to 1986. The
information is primarily. a summary of monthly pesticide use reports , inspection
reports, restricted materials permits, notices of intent to spray, and a CBE
phone survey of school district personnel . Records for the seven commercial
pest control operators listed by school districts as school contractors were
also reviewed, and pertinent information has been included.
-page 2 -
HC8EVSFWT
The objectives of this report are to:
1) Summarize the available information on school district pesticide use and
reporting based on Contra Costa County Department of Agriculture records
and a survey of school district personnel by Citizens for a Better
Environment;
2) Provide basic background information on safer non-chemical pest control
methods ; and
3) Recommend steps toward the development and implementation of
comprehensive pest management policies for local school districts. Such
a policy promotes effective pest management while minimizing or
eliminating the use of potentially hazardous pesticides.
REGULATORY BACKGROUND
The U.S. Environmental Protection Agency (EPA) has ultimate authority over
pesticide regulation under the Federal Insecticide, Fungicide and Rodenticide
Act (FIFRA). In California , the California Department of Food and Agriculture
(CDFA) has primary responsibility for enforcing FIFRA as well as California's
own pesticide regulations.
Each county has a Department of Agriculture responsible for local surveillance
and enforcement of regulations pertaining to the "agricultural uses" of
pesticides. In addition to cropland applications , "agricultural use" includes
-page 3
"CBE aF
pesticide applications by commercial pest control operators (PCOs) who do
outdoor residential and institutional pest control , as well as most outdoor
landscape pest control work performed by park, street and tree maintenance
departments , including state and federal agencies. The County also regulates
all government. agency pesticide use , including school districts. The County
Department of Agriculture, in cooperation with the Structural Pest Control
Board, also regulates indoor pesticide use by public agency employees and
commercial pest control operators, such as for cockroach, flea and rodent
control .
..All pesticides must be registered with the EPA and- in California, with the CDFA.
The public depends on ,the CDFA and the EPA to adequately regulate the safety of
pesticides on the market. Many pesticides , however, were approved for use
before the extensive upgrading of FIFRA in 1972. New chemicals are required to
undergo 'a fairly extensive battery of testing for both acute and chronic health
ieffects before they can be placed on the market (although half of .all new
pesticides between 1978 and 1984 were conditionally registered by the EPA
without full testing). Most of the earlier pesticides have not yet been
re-evaluated for many health effects such as potential to cause genetic damage,
cancer or birth defects. -In fact, according to a recent report by the federal .
General Accounting Office, no pesticide has fully completed the formal federal
registration process (2). In California , 400 of the 700 pesticides registered
for use in this state lack all of the required studies on chronic health effects
such as genetic damage , cancer, and birth defects. No pesticide has all of the
required test data (3).
-page 4
"CBEFSPUT
Upon registration, pesticides are classified either as general (unrestricted) or
restricted use pesticides. The majority of pesticides are registered for
general use. These unrestricted pesticides may be purchased and applied by
anyone. No special training or supervision is required for their use.
Pesticides classified as restricted may only be sold to, and applied under the
supervision of, "qualified" applicators who have passed written multiple-choice
tests administered by CDFA. Qualified applicators must obtain a permit from the
County Department of Agriculture before purchase and application of restricted
pesticides. Restricted use pesticides are ones which have been recognized,
according to the EPA, as having the ability to "cause some human injury or
environmental damage even when used as directed on the label " (4).
Public agencies and institutions are not presently required to keep record of,
or report, the majority of pesticides they use, because most of the pesticides
they use are unrestricted. Public agencies and institutions are only required
by California state law to file monthly pesticide use reports with the County
listing the amount of "restricted" pesticides used during the previous month.
The County Department of Agriculture has the authority to require reporting of
both restricted and unrestricted pesticides, as the Food and Agriculture Code
allows the commissioner of any county to "adopt regulations applicable in his or
her county which are supplemental to those of the director (of the California
Department of Agriculture) which govern the conduct of pest con-tol operations
and records and reports of such operations" (Divis.ion 6, Chapter 2, Section
11503). The Contra Costa County Department of Agriculture has requested public
agencies and institutions to report all pesticides used, but has not made this a
legal requirement.
-page 5 -
In addition to staff pesticide use, most school districts contract out to
commercial pest control operators (PCOs) for at least some pest control . PCOs
are required to record and report to the County all pesticides used, both
restricted and unrestricted, on a monthly basis. This information, however, is
reported in gross quantities of pesticides used county-wide. No specific
information on where pesticides are applied by PCOs is publicly available under
current record-keeping requirements„ It is not possible to determine which
pesticides PCOs use on school property, indoor or out. This report focuses on
pesticide use by school district staff.
•-page 6 -
&CBER & ° O
CONCLUSION 8 1:
PESTICIDES ARE WIDELY USED IN PUBLIC SCHOOLS IN CONTRA COSTA COUNTY WITHOUT
FORMAL PESTICIDE USE POLICIES OR ADEQUATE OVERSIGHT.
Pesticides are applied in all but one of Contra County's 19 school districts,
either by school staff, commercial pest control applicators, or both. None of
the districts has a formal pest management policy outlining when, how, and under
what conditions pesticides will be used. None of the districts posts notices
when pesticides are applied. Although the County Department of Agriculture has
requested that school districts report all pesticides used, only seven of the
districts have submitted any pesticides use reports to the County. Only one
district has submitted all monthly reports during the three years surveyed.
Information on pesticides applied by commercial contractors is not available
because it is not submitted on a site by site basis.
Citizens for a Better Environment (CBE) has found that pesticides are used in
and around most schools in Contra Costa County. Table 1 summarizes the
pesticide use information available from the Contra Costa County Department of
Agriculture for all school districts in the County. None of the contracted use
is included in school district .pesticide use totals. During the 1984-1986
school years, pesticides were applied in all but one of the 19 school districts
in Contra Costa County. In 17 of these districts (all except Oakley and
Canyon) , school staff applied pesticides at least occasionally, according to a
CBE survey of school district personnel . In addition, 16 of these 17 and the
Oakley District also contract out for pest control from commercial pest control
operators (PCOs). Canyon School District (which has just one school) reported
using no pesticides whatsoever.
Because consistent reporting of pesticide use has not been required by the
County, very few of the districts whose staff apply pesticides report any of
-page 7 -
BCBEPAPM7
these applications to tht County. This lack of reporting poses a serious
concern because- school district staff pesticide applications are often carried
out by custodians and other maintenance staff as work incidental to their other
tasks. Staff are often untrained in pest control and unaware of the potential
hazards of the chemicals they apply. Of the 17 school districts whose staff
applied pesticides, only seven filed any monthly pesticide use reports with the
County (see Table 1). Only one submitted all 12 monthly reports for all three
years (1984-1986). When reporting, all of these seven districts included both
restricted and unrestricted pesticides in their reports.
Pesticide use reports are'one of the few ways the County Agriculture Department
can: be sure that,:at. the,, very least, restricted pesticides are.not being used
without permits and/or by untrained personnel.. For example, the only way the
County became aware that the restricted herbicide 2,4-D was -being used .without a
permit at Diablo Valley College (Contra Costa Community College) was through the
t college's monthly pesticide use reports. When metasystox-R became a .restricted
chemical in 1984 due to concerns about its potential to cause adverse
reproductive effects in lab animals, the County knew to require a permit from
the Richmond ,district because of Richmond's monthly pesticide use -reports.
In addition, it is important that the County require "negative" use reports' when
pesticides. are not applied, especially for restricted materials. According to
state law, when a licensed PCO holds a restricted materials permit, "negative"
use reports must be submitted even when no material is used that month. This
does not apply to public agency permits, but Alameda County, for example,
extends this requirement to public agencies by adding a negative use reporting
requirement to the permit. Contra Costa County has not done this.
-{gage 8 -
51(� DOD �
TABLE 1: REPORTED PESTICIDE USE BY SCHOOL DISTRICTS IN CONTRA COSTA COUNTY
(from records at the Contra Costa County Department of Agriculture dated: 1984-1986)
---------------------------------------------------------------------------------------------------------------------------------------
I SCHOOL IN(MER IINWrKLY PESTICIDE USEII POWS OF 11 NUMBER OF STAFF Il STAFF I CONTRACTS I I
I DISTRICT I OF II REPORTS FILED 11 PESTICIDES USED 11 PESTICIDE II USES I OUT FOR I COIt1ENTS I
1 ISCHOOLSII 11 BY STAFF II APPLICATIONS 11 PESTI- I PEST I ON OUTSIDE PEST CONTROL I
I I 11 1984 1 1985 1 1986 II 1984 11985 11986 111984 11985 11986 II C1DES* I CONTROL* I CONTRACTS I
I---------------- -------------_-----__—_------_---_----I--------------------I
I I II I 1 II I I II I I Il I I 1
IAcalanes 1 6 11 10 1 6 1 9 If 311 1 387 1 267 11 39 1 51 1 24 11 yes I yes (contracts out for bee and I
I I II 1 1 II I I II I I II I !wasp control only. I
t i 11 I 1 11 I I I I I t 11 I I I
(Antioch 1 13 II none I none I none 11 NA I NA I NA 11 NA I ITA I NA II yes I yes (Rose Exterminator-when'need-I
I I II I I II 1 I II 1 1 11 1 led' monthly or periodically I
I I II I 1 It I I II I I 11 1 1 1
(Brentwood 1 3 11 none 1 none I none 11 NA I NA I NA II NA I NA I NA II yes I yes (Blue Ribbon Pest Control I
I 1 II I I 11 I 1 II 1 1 II 1 Imonthly service I
I 1 II 1 1 II 1 I If I 1 II 1 1 1
111yron I 2 11 none I none I none 11 MA I NA I NA 11 NA I NA I NA II yes I yes IBlue Ribbon Pest Control I
I I it I I I1 I 1 11 1 1 11 1 (bimonthly or as needed I
I '1 11 1 I It I 1 II 1 1 11 1 1 1
(Canyon I 1 11 — 1 — I -- II 0 1 0 1 0 11 0 1 0 1 0 11 NO I NO (reports no pesticides used I
I 1 II 1 1 11 1 1 11 1 1 If I I I
ICC Cam Col. 1 4 11 11 I 12 1 10 II 1138 11329 1 328 11 76 1 169 1 40 II yes I yes (Crane Pest Control-monthly I
I 1 11 1 1 II 1 1 II 1 1 11 1 1 1
[John Swett 1 4 11 none I none I none 11 NA I NA I NA II NA I NA I NA 11 yes I yes IJ-Spay - for weed control I
I 1 II 1 1 11 1 1 II 1 1 11 1 I I
IKnightsen I 1 It none I none 1 none 11 NA 1 N4 I M I1 NA I NA I N4 If yes I yes [Clark's Pest Control - for I
I I If I I II I 1 11 1 1 11 1 Ifleas and ants I
1 t II I I 11 1 I II I I II 1 I 1
lLafayette 1 5 11 12 I 12 1 11 11 1574 1 223 1 423 11 19 1 7 1 25 II yes I yes (Contracts out for rats only I
I 1 11 1 1 11 1 1 11 1 1 11 1 1 1
ILiberty t 3 II none I none I none 11 NA I NA 1 NA 11 NA I NA I NA II yes I yes (Clark's Pest Control-monthly)
I 1 It I 1 11 1 1 11 1 1 - 11 1 1 1
(Martinez 1 7 11 12 1 6 1 6 11 34 1 66 1 56 11 27 1 14 1 6 II yes I yes (Clark's Pest Control-monthlyl
I 1 If i 1 11 1 1 It I 1 11 1 1 1
IMoraga 1 3 11 none I none I none 11 NA I NA I NA II NA I NA I NA II yes I NO (City of Moraga maintains 1
I I II I 1 II I I 11 I 1 11 1 lall playing fields (through 1
1 I II I I It I 1 11 1 1 II 1 Icontractor) I
I 1 II I 1 11 1 1 11 1 1 II 1 1 I
INt. Diablo 1 48 11 12 1 10 1 10 11 1813 1 626 11168 II 116 1 97 1 97 11 yes I yes [Montgomery Pesticide - I
I 1 11 I 1 11 1 1 II 1 I II 1 (rodents and gophers I
I I II I 1 11 1 1 11 1 1 11 1 1 1
(Oakley 1 2 11 — 1 — I — 11 0 1 0 1 0 I1 0 1 0 1 0 11 NO I yes (Contracts out for everythingl
I I If 1 1 11 1 1 11 1 1 II 1 1 1
10rinda 1 4 11 4 1 none 1 9 11 176 1 NA 1237 11 15 1 NA 1 19 11 yes I yes ICorky's Pest Control - bees I
I 1 11 1 1 11 1 1 11 1 1 11 1 1 1
(Pittsburg 1 13 II none I none 1 none II NA I NA I NA 11 NA I NA 1 NA II yes I yes (Clark's Pest Control-monthlyl
I 1 11 1 1 II I 1 II 1 1 11 1 1 1
;Richmond 1 58 11 12 1 12 1 12 11 926 1 559 1 484 11 184 1 233 1 139 11 yes .I yes (Earl's Pest Control-monthly 1
I 1 11 1 1 II I 1 11 1 1 II 1 !for ants, roaches;also,weedsl
I I It I 1 11 I 1 11 1 1 11 1 1 1
(San Ramon 1 22 11 none I none I none It NA I NA I NA II NA I NA I NA 11 yes I yes (Contracts out for gophers 1
I 1 II 1 1 II 1 1 II 1 1 11 1 1 1
Walnut Creekl 5 11 none I none I none 11 MA I NA 1 NA 11 NA 1 NA I NA II yes f yes IMontgomery Pest ic ide-noathlyl
I 1 II 1 1 If I 1 11 1 1 II 1 Ifor ants; also weeds I
------------------------------------------------•----------------------------------------------------------------------------------
NA: not available
* Source: CBE Survey of school district maintenance staff, 1986
-page 9-
The only other way for the County to regulate school district pesticide use is
through inspections. The lack of County inspections is discussed under
"Conclusion # 3" on page 27.
Table 1 also shows that at least nine of the 17 school districts which contract
out for pest control rely on routine monthly or bi-monthly pesticide
applications by PCOs. PCOs were most: often hired for control of indoor pests
such as ants and cockroaches, and for weed control . In addition, although the
Moraga District does not contract out directly, all of its playing fields are
maintained by .the 'City of Moraga's contractor.
PCO applications on school grounds are almost never observed by the County
Department of Agriculture. It is also not possible to determine if and where
2,4-D, the one restricted herbicide used by •PCO's listed by school districts,
was applied on school grounds. All of the PCOs listed by district personnel as
doing weed control (except Earl 's Pest Control , for which the County had no
records) use 2,44, a restricted herbicide normally requiring a Notice of Intent
to .Apply ,Restricted Materials (NOI). The County, .however, has the perogative to
waive the NOI requirement, and did so for each PCO after inspecting ,one
application. Therefore no NOI's for 2,4-D use were submitted by any of these
companies. None of the PCOs listed by school district personnel reported
applying restricted insecticides on school grounds.
The lack of information about most school districts emphasizes the need for
improved reporting and greater public access to information about specific
pesticide use in the schools. Because of inadequate reporting and lack of
-page 10 -
SCBE o
information on PCO applications, these results should be used not to compare the
pesticide use of one school district to that of another, but to examine the
school districts which reported extensive pesticide use and to identify those
for which more information is needed.
Based on pesticide use reported, the Richmond School District appears to
have reduced staff pesticide use substantially since 1979, when 'CBE first did a
review of public agency pesticide use in Contra Costa County (5). Richmond, the
district with the most schools, was the only district in the County to submit
all 12 pesticide use reports for the last three years. Each year shows a
reduction in pounds used, from just over 2000 pounds in 1979 to 484 pounds in
1986 (Table 2). However, the Richmond School District also currently contracts
out with Earl 's Pest Control. as well , primarily for control of ants and
cockroaches. Two violations of state or federal pesticide use regulations were
found during three inspections by the Contra Costa County Department of
Agriculture in 1984.. One violation was for failing to have-a permit for the use
and possession of restricted pesticides. The second was because applicators
were not provided with proper safety clothing. One of the inspections in 1984
included one of the three County inspections of a school district pesticide
applicaton that year. There was one inspection each year in 1985 and 1986 and
no violations were found.
Mt. Diablo School District applied the greatest amount of pesticides of all
the districts over the three year period (averaging 1202 pounds per year). Mt.
Diablo shows a jump in pesticide use reporting from 1979 when 487 pounds were
reported, to 1984 when 1813 pounds were reported (Table 3). Only seven
pesticide use reports were filed in 1979 while all 12 reports were filed in
-page 11-
�l�bG Dc po .
TABLE 2: PESTICIDE USE REPORTED BY THE RICHMOND UNIFIED SCHOOL DISTRICT
I I I I REPORTED USE (lbs.)*I q OF MONTHS 1
I C"ON NAME (TRADE NAME (PESTICIDE( I I 1 USED I MODE OF ACTION I
I I I TYPE 1 1984 1 1985 1 1986 1 (36 poss.) I I
I----------------------------- -------------------------------------------------I
lacephate I Orthene 1 I I 1 1 5 1 1 1 1
I I 1 I I I I I I
lamitrole I Weedazol I H 1 115 1 1 1 1 5 (nen-selective herbicide I
lamitrole/atrazine I Fenamine I H I 1 1 41 1 2 Inon-selective herbicide I
I 1 . I I I I I 1 I
Idalapon I Dalapon I H 1 14 1 1 1 1 Inon-selective growth inhib- I
I 1 I I I I I litinq_ herbicide I
I } I I
(DCPA I Dacthal I H 1 123 1 150 1 125 1 6 1 1
I I I I 1 I -I I I
Idicamba I Banvel I H 1 34 1 1 1 1 1 1
I I I I I I 1 I I
12,4-D I Weedar 64 1 H 1 24 1 12.5 1 1 3 Iselective systemic herbicidel
• I : I i 1 I I 1 I
Idiethyl phos-- I Diazinon I I - 1 6 1 4 1 1 1 8 linsecticide-organophosphate I
Iphothioate 1 . I . I I I I
1 I 1 I I I I I I
Idiuron, bromocil 1 . Krovar I H 1 91 1 155 1 138 1 18 Iselective pre-emergence I
I I I 1 I I I (herbicide I
I I I I I I I I I
(glyphosate I Roundup I H 1 81 1 98.5 1 66 1 24 Inon-selective I
I I I I I I 1 .(contact herbicide I
I I
lisopropoxyphenyl (Ortho Hornet 1 I I 11 1 3 1 3 linsecticide I
Imethylcarbamate I& Wasp Spray I I I I I- I 1
I I I I I I I I 1
Ihexulofuranosonic I Atrinal 1 I 11 I I 1 I I
laeid,sodium salts I I I 1 I I 1 I
I
Imesurol I Ortho Snail I M 1 1 7.5 1 1 1 I 1
I I & Slug Bait I I I I I I I
I I I I I I I I 1
Imetasystox R I Metasystox I I 1 11.5 1 1 1 5 linsecticide I
I I I f
I I No Foam B I I 11 I I 1 I I
1
Iproneton I Pramitol I H 1 370 1 100 1 75 1 7 Ipreemergence herbicide 1
I I I I I I 1 I 1
loryzalin I Surflan I H I I I 8 1 1 Iselective preemergence I
I I I I I it I (herbicide I
I I 1 1 I I I I I
Isodium cacodylate I Rade Cate I H 1 36 1 I 1 2 (non-selective herbicide I
I I 1 I I 1 I
Istrychnine I Gopher Mix I R 1 12 1 27 1 22 1 12 I 1
I TOTALS: 1 1 1925,:5 1558.5 1 484 1 1 1
H = herbicide, I = insecticide, M = molluscicide, R = rodenticide
*Pesticide use is reported as pounds of concentrated formulated product. The concentration of active ingre-
dients typically varies from 40% to 807 of the amount reported. The formulated product is diluted before
application, usually with water or diesel oil. Pesticide use reported as liquid measures has been converted
using I gallon equals eight pounds.
-page 12-
TABLE 3: PESTICIDE USE REPORTED BY THE MOUNT DIABLO UNIFIED SCHOOL DISTRICT
-------------------------------------------------------------------------------------------
I 1 I I REPORTED USE (lbs.)*I # OF MONTHS I I
COMMON NAME (TRADE NAMEIPESTICIDEI I I I USED I MODE OF ACTION I
I I I TYPE 1 1984 1 1985 1 1986 1 (36 poss.) I I
I-----------------------------------------------------------------------------------------I
I I I I I I I I I
lamitrole I Amizol , I H 1 485 1 90 1 94 1 9 Inon-selective I
I I Amrol 10 1 1 1 1 1 (herbicide I
I I I I 1 I i I I
Ibendiocarb I Ficam 1 I I 1 1 2 1 1 1 1
1 1 1 1 1 I 1 1 1
Idiquat I Diquat I H 1 24 1 64 1 40 1 7 (contact herbicidel
I I I I I 1 I land dessicant I
I I I I I I I I I
(glyphosate I Roundup I H 1 264 1 332 1 312 1 27 Inon-selective I
I I I I I I I (contact herbicidal
I I I I I I I I I
loryzalin I Surflan I I 1 1 20 1 1 Iselective preem- I
I I I 1 I I I lergence herbicidel
I I 1 I I I I I I
loxadiazon I Chipco I H 1 530 1 1 500 1 6 Iselective preem- I
I I Ronstar I I I I I lergence herbicidel
I I I I 1 1 I 1 I
Isimazine I Princep I H 1 510 1 140 1 200 1 9 Iselective preem- I
I I Cal 90 1 1 1 1 1 lergence herbicidal
1 TOTALS: I 1 1 1813 1 626 1 1168 I 1 1
-------------------------------------------------------------------------------------------
H = herbicide, I = insecticide
*Pesticide use is reported as pounds of concentrated formulated product. The concentration
of active ingredients typically varies from 40% to 807 of the amount reported. The for-
mulated product is diluted before application, usually with water or diesel oil . . Pesti-
cide use reported as liquid measures has been converted using 1 gallon equals eight
pounds. r
-page 13-
�C�000O
1984. Only 10 reports were filed in 1985, reporting 626 pounds used. The 10
reports in. 1986 showed 1168 pounds used. Mt. Diablo also has a contract with a
pest control company for gopher and rodent control and occasional weed control .
j No violations of pesticide use regulations were noted for the Mt. Diablo
District during five inspections in 1984-1986. This included inspections of one
application in 1984 and one in 1986.
Contra Costa Community College District reported the second largest amount of
pesticides applied over the three year period (averaging 932 pounds per year)
(Table. 4). This, district showed a commendable improvement in filing pesticide
use reports. In 1979 ,only;one report was filed showing 0.1 pounds of pesticides
used. Eleven reports were filed in .1984 indicating that 1137 pounds of
pesticides were used. Twelve reports were filed in 1985 reporting 1317 pounds
used. Ten reports were filed in 1986 reporting only 328 pounds used. The
primary reduction was in the use of Turf Supreme/Trimec (containing 2,4-D). The
District also contracts out for monthly service with a pest control company.
Contra Costa Community College District was inspected three times in 1984
(including one of the three school district application inspections done by-the
County that, year) and was cited once! for improper equipment usage (not during
the application inspection). In 1985, the District was inspected once and two
violations were found: one for spraying 2,4-D without the required permit and
one for failing to submit all pesticide use reports. In 1986 the district has
had one inspection with no violations cited.
Lafayette School District shows a marked reduction of reported staff pesticide
use from over 1500 pounds applied in 1984 to 222 pounds reported in 1985 and 423
pounds reported 1986 (Table 5). The bulk of this reduction can be attributed to
-page 14 -
((oJJtiOG p o p �
TABLE 4: PESTICIDE USE REPORTED BY THE CONTRA COSTA COMMUNITY COLLEGE DISTRICT
---------------------------------------------------------------------------------------------
I I I I REPORTED USE (lbs.)*I k OF MONTHS I I
I COMMON NAME (TRADE NAME (PESTICIDE( I I I USED 1 MODE OF ACTION I
I 1 I TYPE 1 1984 1 1985 1 1986 1 (36 poss.) I I
I-------------------------------------------------------------------------------------------I
I I I I I I I I I
Ibendiocarb andl Bendiocide I 1 1 <0.5 1 1 <0.5 1 2 Iresidual and I
(pyrethrins I I I I I I 1knockdown insec- I
I I 1 I I I I Iticide 1
I I I I I I I I I
Idicamba I Banvel I H I 1 1 18 1 1 1 1
1 1 1 1 1 1 1 1 1
1 1 Dichform I 1 1 2.5 1 .5 1 2 1 1
I I I I 1 I I I I
12,4-D I Weedar 64 1 H I 1 1 36 I 1 Iselective system-1
I I I I I I I lic herbicide I
12,4-D./diacambalBanvel 294-DI H 1 4 1 32 1 1 4 1 1
1 1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1 1
12,4-D, MCPA I Turf I H 1 1011 1 1100 1 1 3 1 1
Idicamba I Supreme w/ I I I I I I I
I I Trimec I I I I I I I
I I I I I I I I I
I I Fenocil I I 1 I 32 1 1 1 1
1 1 1 1 1 1 1 1 1
(glyphosate I Roundup I H 1119.5 1141 .5 1 178.5 1 27 Inon-selective I
I I I I I I I (contact herbi.cidel
I I 1 I I I 1 I 1
Imalathion I Malathion I I 1 1 6 1 8 1 2 lorganophosphate I
I I I I I I I Inerve poison I
I I I I I I I I I
Imethanearsonicl Weed Hoe I H 1 1 14 1 1 4 1 1
lacid, sodium I 108 I I I I I I I
Isalts I I I I I I I I
I I I I I I I I I
loryzalin I Surflan I H 1 1 27 1 50 I 4 Iselective preem- I
I 1 I I I I I lergence herbicidel
I I I I 1 I I I I
I I Oxford Ant I 1 1 2.5 1 <0.5 1 1 2 1 1
I Spray I I I I I I I
I I I I I I I I I
I I Sectocide I I I 1 1 4 1 4 1 I
1 Icooke spiderl I I I I I I
I I 1 I I I I 1 I
I I Urea Sul- I 1 1 5 1 1 1 1 I
I 1 furic Acid I 1 I I i I I
I TOTALS: 1 1 11137.511328.51 327.5 1 1 I
---------------------------------------------------------------------------------------------
H = herbicide, I = insecticide
*Pesticide use is reported as pounds of concentrated formulated product. The concentration
of active ingedients typically varies from 40% to 807 of the amount reported. The for-
mulated product is diluted before application, usually with water or diesel oil . Pesticide
use reported as liquid measures has been converted using I gallon equals eight pounds.
-page 15-
SCBE 6V
TABLE 5: PESTICIDE USE REPORTED BY THE LAFAYETTE SCHOOL DISTRICT
-----------------------------------------------------------------------------------------------
ICOMMON NAME( TRADE NAME (PESTICIDE( REPORTED USE (lbs.) ( N OF MONTHS I MODE OF ACTION I
I I I TYPE 1196'4 1 1985 1 1986 IUSED (36 poss.) I I
I---------------------------------------------------------------------------------------------I
I I I 1 I I I I I
I I Agridex 1 I 1 1 3 1 2 1 1
1 1 1 1 1 1 1 1 1
Ibenfluralinl Balan I I 1 1 320 1 1 1 1
1 1 1 1 1 1 1 1 1
Idiquat I Diquat I H 1 1 6.5 1 7.5 1 7 (contact herbicide I
.1 1 1 1 1 1 1 land dessicant I
I I I I 1 I I I I
I I Direx I 1 1 1 16 1 1 1 1
I I I I I I I I I
(glyphosate I Roundup I H 1 35 1 41 1 47 1 13 Inon-selective con-1
I I I I I I I !tact herbicide I
I I I I I 1 I I I
loryzalin 1 Surfl.an 1 H 1 1 7 1 26 1 4 Iselective preemer-I
I I I I I I i Igence herbicide I
I I I I I I
(petroleum l X/77 I H 1 1539 1 168 1 1 .5 1 10 Isurfactant 1
Idistillatesl (sticker) , I I I I I I I
1 I Spray film, I' I I I I I I
I (Weed Oil", Weedl I I 1 I I I
I I Boomer I I I I I I 1
I I I I I I 1 I I
Istrychnine I Wilco Gopher I R I 1 I 1 1 1 1 1
I I Getter I I 1 I I I I
I I I I I I I I I
I I Cooks Gopher I R I I I 1 I 1 I I
I I Bait I I I I I I 1
I 1 I I I I I I I
I TOTALS: 1 1 1 1574 1222.5 1 423 1 1 1
-----------------------------------------------------------------------------------------------
H = herbicide, I = insectic-ide, R = rodenticide
*Pesticide use i:s reported as pounds of concentrated formula product. The concentration of
active ingredients typically varies from 407 to 80% of the amount reported. The formulated
product is diluted before application, usually with water or diesel oil . Pesticide use
reported as liquid measures has been converted using 1 gallon equals eight pounds.
page 16-
3CBER p O
discontinued use of "weed oil ". Twelve monthly pesticide use reports were filed
in 1984 and 1985, and 11 in 1986, although almost one third of these reports
were at least a month late. Lafayette only contracted out for the control of
rats on an "as needed basis". Lafayette School District was inspected for its
adherence to pesticide use regulations two times in 1984 with no violations
found. There were no inspections done in 1985. One inspection in 1986 revealed
three violations concerning lack of employing training.
Acalanes High School District filed 12 monthly reports in 1984, six reports in
1985 and nine reports in 1986. Surprisingly, reported pesticide use was
greatest in 1985, when fewest reports were submitted (Table 6). District staff
reportedly apply most pesticides ; the District only contracts out for control
of bees and wasps. The District received one violation during the one
inspection in 1984 due to "improper submission" of pesticide use reports. In
1985, they were inspected once and cited twice, once for failing to .properly
post a warning sign at the pesticide storage area and once for applying
restricted pesticides without supervision by a qualified applicator. No
violations were discovered during the one inspection in 1986.
Martinez School District filed 12 pesticide use reports in 1984 but only six
in 1985 and six in 1986 (Table 7). In fact in 1986, no reports were submitted
for three of the nine months that Martinez held a use permit for 2,4-D. While
the County cited the District for failing to submit the monthly reports in 1984
(4 of the 12 reports came in at least a month late) , the District was not cited
in 1986 when the Distrit held a restricted materials permit, the most obvious
time to look for reports. Requiring negative use reports is an important way to
ensure that restricted pesticides are not being used without the County's
-page 17-
ACBE A_
TABLE 6: PESTICIDE USE REPORTED BY THE ACALANES U41ON HIGH SCHOOL DISTRICT
-----------------------------------------------------------------------------------------------------------
I COMMON NAME I TRADE NAME I PESTICIDE I REPORTED USE (lbs.)* 1 R OF MONTHS I MODE OF ACTION I
I I I TYPE 11984 1 1965 1 1986 1 USED (36 poss.) I I
I----------------------------------------------------------I---------------------------------------------I
I 1 I I I I 1 I I
Icarbaryl, I Sevin I I I 1 1 16 1 1 Icarbamate nerve I
I I I I I I I (poison I
I I I I I I I I I
Idiethyl I Diazinon . I I 1 1 11 36 1 2 lorganophosphate I
Iphosphorothioatel I I I I I Inerve poison I
I I 1 I I I I I I
Idiquat I Diquat, 1 H 1 13.5 1 68 1 8 1 8 (contact herbicide I
I 1 Aquaquat I I I I I land dessicant I
1 I I I I I I I I
Ifluazifop-butyl I Fusilade I 1 1 .5 1 1 1 1 1
Iglyphosate I Roundup' 1 H 1 43 1 270 1 156 1 13 Inon-selective I
I. I I I I (contact herbicide I
I I "I I I I I 1
Ilindane ' Ilsotox, Lindane I 1 1 1.5 1 1 12 1 2 lorganochlorine I
I I I I I I I (nerve poison I
I I 1 I I I I I I
(malathion I 'Malathion, I 1 1 0.5 1 4.5 1 2 1 4 lorganophosphate I
I I Chacon I I I I I Inerve poison 1
I I I I
loryzalin I Surflan I H 1 16 1 24 1 17 1 10 Iselective preem- I
I I I I I I 1 lerg_ence herbicide I
I I I I I I I I I
I I Parch I H 1 152 1 1 1 1 1 1
1 1 1 1 1 1 1 1 1
Isimazine I Amizine I H 1 84 1 20 1 20 1 5 Iselective preem- I
I I I I I I I lergence herbicide 1
I I I I------I------I--------I I I
I TOTALS: 11 1310.5 1 387 1 267 1 I I
H = herbicide, I = insecticide, R = rodenticide
*Pesticide use is reported as pounds of concentrated formulated product. The concentration of active in-
gredients typically varies from 40% to 80% of the amount reported. The formulated product is diluted be-
fore application, usually with water or diesel oil. Pesticide use reported as liquid measures has been
converted using i gallon equals eight pounds.
-cage 18-
a�D o D Q
CITABLE 7: PESTICIDE USE REPORTED BY THE MARTINEZ UNIFIED SCHOOL DISTRICT
--------------------------------------------------------------------------------------
1 I I I REPORTED USE (lbs.)*IM OF MONTHS( 1
ICOMMON NAMEITRAOE NAMEIPESTICIDEI 1 1 I USED I MODE OF ACTION 1
I I I TYPE 11984 11985 1 1986 106 poss.) I 1
1------------------------------------------------------------------------------------1
I I I I 1 1 I 1 I
lamitrole i Amitrole I H 1 6 1 ' :14 1 12 1 5 [non-selective 1
1 1 I I 1 I I (herbicide I
I I I 1 I I I I 1
12,4-D,MCPA I Trimec I H I 1 1 16 1 1 Iselective systemicl
Idicamba I 1 1 1 1 I (herbicide I
I I I I I I I I I
lglyphosate I Roundup l H 1 28 1 32 1 13 1 9 Inon-selective con-I
I I I I 1 1 I Itact herbicide I
I I I I 1 I I I I
Isimazine I Princep 1 H 1 1 20 1 15 1 4 Iselective preem- 1
I I I 1 [ I I lergence herbicide I
I TOTALS: I 1 1 34 1 66 1 56 1 1 1
---------------------------------------------------------------------------------------
TABLE B:PESTICIDE USE REPORTED BY THE ORINDA UNION SCHOOL DISTRICT
------------------------------------------------------------------------------------------
I I 1 I REPORTED USE (lbs.)*l q OF MONTHS I I
I COMMON NAME (TRADE NAMEIPESTICIDEI I I I I USED I MODE OF ACTION I
I 1 I I TYPE 1 1984 1 1985 1 1986 1 (24 poss.) I I
1------------------------------------------------------------------------------------------I
I I I I I I I 1 I
Icarbaryl I Sevin I I I I 1 8 1 1 Icarbamate I
I I I I I I I Inerve poison I
I I I I I 1 I 1 I
Ichlorpyrifos I Dursban I I 1 1 1 1 .5 1 1 lorganophosphate 1
I 1 1 1 I I I Inerve poison 1
1 I I I II I I I
Idiethyl phos-1 Diazinon I I I 1 1 24 1 3 lorganophosphate
Iphothioate I I I I I I Inerve poison I
I I 1 I I I 1 I I
12,4-D, MCPA, I Trimec I H I 1 1 16 1 1 Iselective systemic I
Idicamba 1 I I I 1 I (herbicide I
1 I 1 I I I I I I
(glyphosate I Roundup I H 1 104 1 1 88 1 5 Inon-selective I
I I I I I I I (contact herbicide I
l I 1 I I I ! I I
loryzalin 1 Surflan I H 1 72 1 1 94 1 3 Iselective preem- I
1 1 I I I I I lergence herbicide I
I I I I I I 1 I I
[strychnine I Wilco I R I 1 1 5 1 1 1 1
1 1 Gopher I 1 [ I [ I I
I I Bait I I I I I I I
I TOTALS: I 1 1 176 1 1 236.5 1 1 1
--------------------------------------------------------------------------------------------
H = herbicide, I = insecticide, R = rodenticide
*Pesticide use is reported as pounds of concentrated formulated product. The concentration
of active ingredients typically varies from 40% to 807 of the amount reported. The formu-
lated product is diluted before application, usually with water or diesel oil. Pesticide
use reported as liquid measures has been converted using 1 gallon equals eight pounds.
-page 19-
aCBE � a ° o
knowledge. The one inspection in 1984 also revealed a failure to maintain
employee training records. The District was inspected three times in 1985-1986
with no violations found.
Orinda School District filed only four reports in 1984 reporting 176 pounds
used, no reports in 1985, and nine reports in 1986 reporting 327 pounds used
(Table 8). Six of these nine reports were one to three months late, and the
County had to cite Orinda for failing to submit reports to get some of these.
Orinda received one inspection in 1984 with one violation for failing to keep
personnel records on the amount of pesticides used. In 1985, the one .inspection
revealed fourproblems:. a. use permit for 2,4-D was denied because the District
did not have a qualified applicator; the applicator must also be "qualified". in
the proper categories ; pesticide use. reports were not being submitted ; and
.safety equipment and equipment nozzles needed improvement. It. is not clear from
the inspection report whether 2,4-D had been used or not and no use reports were
submitted at all in 1985. The inspector did issue a storage permit for 2,4-D on
that day, although lack of a storage permit was not listed as a violation. In
1986, Orinda was inspected once and cited again for not submitting use reports
(although a-ll„ reports were eventually submitted for the duration of their 2,4-D
use permit that year, most were late, as mentioned above).
Table 9 summarizes the school district inspections made by the County Department
of Agriculture. Five other Contra Costa school districts which did not report
pesticide use but whose staff apply peticides have been inspected by the Contra
Costa County Department of Agriculture in 1984-1986. The Albany School District
was also .inspected once in 1985 with no reported violations. (Albany is not a .
Contra Costa School District but some of its fields are located in Contra Costa
-page 20 -
ACBE° � ° o
TABLE 9: INSPECTIONS AND VIOLATIONS FOR SCHOOL DISTRICT PESTICIDE USE IN CONTRA COSTA COUNTY 1904-1986
(All districts whose staff use pesticides have been included.)
------------—---------------------------------------—"'---------—----------------------------------
ISCHOOL DISTRICT I NUIBER AND TYPE OF INSPECTION IINONBER OF VIOLATIONSI CATEOORIES OF VIOLATIONS I
1 1197911 1984 1 1985 1 1986 11197911198411985119861 1
I -----1 11-1— -- I
Mcalanes I 1 I1:R,S,E,HO 11:R,S,E I I:HQ,S,E II 0 1 1 1 2 1 0 11984: No proper submission of pesticide use reports.[
I I I I I II I 1 1 11985: Amino triazole k simazine require qualified 1
I 1 I I I II I 1 I lapplicatorl No proper storage sign. I
(Albany (playing 1 0 1 0 1 1 1 0 II --- 1--- 1 0 1--- I I
Ifields in CCCo.)I I I 1 11 1 1 1 1 1
1 I I I I I1 I 1 1 I I
(Antioch 1 0 1 0 1 0 1 0 11 — I— I— I— I I
1 I I I 1 II 1 1 1 1 1
18"otmcd 1 0 1 1:S I 0 I 11S It — 1 0 1— 1 0 1 i
1 I I I I II I 1 1 I I
(Byron 1 0 1 1 1 1:S,E 11 — I— I-- 1 0 1 1
I I I I I II I I 1 I 1
I I I I I II 1 I I I I
[Contra Costa 1 4 1 ME,A); 1 I.R,SIE 11:R,HQ,S,E[I 1 1 1 1 2 1 0 11979: Safety equipment not used/furnished. 1
IComunity Coll. I 1(R,S,E);(S)l 1 11 1 1 1 11984: Improper equipment usage. 1
I 1 I I 1 11 1 1 1 11985: No restricted pesticide permit when used 2,4-DI
i 1 I I 1 II 1 1 1 lin Narch k April; December no pesticide use repart.l
1 I I I 1 11 1 1 1 1 1
IJohn Swett 1 0 1 0 1 0 1 0 11 — 1-- 1— I— I I
I I I I 1 11 1 1 1 1 1
IKnightsea 1 0 1 I:S 1 O I 1:S II -- 1 0 1--1 1 11986: Storage area not posted. I
I I I I I If I I I I 1
(Lafayette I 1 12:09,5IE) 1 O 11:RIHQ,SIEII 0 1 0 1— 1 3 11986: No records on training topics covered; No re- I
I I 1(R,RQ,S,E) I 1 11 1 1 1 (cords on training prior to handling; Training re- I
I I I I 1 11 1 1 1 [cords not complete and available. I
1 I I I 1 11 1 1 1 1 1
ILiberty 1 0 1 0 1 0 1 0 11 — I— I— I-- I I
I I I I 1 11 1 i I I I
Martinez 1 2 1 l.R,S,E 11:R,SIE I WPM; 11 0 1 2 I 0 [ 0 11984: Need to keep personnel application records; I
1 1 I I I (R,S,E) II I I 1 I Need to sent pesticide use reports. I
I I I 1 1 11 1 1 1 1 1
INoraga 1 0 1 0 1 I:S,E 1 0 11 --- I- I 1 I--- 11985: Need 'Poison' sign on storage shed for 'warn- I
i I I I 1 11 i I I ling' or 'danger' labelled chemicals. I
I 1 I I I II I I I I I
INt. Diablo I I 12:(E,A); I1:R,HQ,S,E12:(R,S,E);II 0 1 0 1 0 1 0 1 1
I 1 1(R,HQ,S,E) I 1(A,N,E,S) 11 1 1 1 1 1
1 I I I 1 11 1 1 1 [ I
IOrinda I I I 1:R,S,E 11:R,SIE ll:R,HO,S,EII 1 1 1 1 4 1 1 11979: No emergency medical care posted. 1984: Amount[
I I I I 1 11 1 1 1 lof materials used not written on personnel records. 1
I I 1 1 ( I! I I 1 11985: Can't receive 2,4-D use permit w/o qualified I
1 I 1 I 1 II I 1 I [applicator Applicator must be qualified in proper I
i I 1 I I 11 I I I Icategories; Need to send use reports monthly; Need I
I I I I I II I I I Iproper nozzle and safety equipment. I
1 I I I 1 II I 1 1 11986: Need to send pesticide use reports monthly. 1
I I I I 1 II I 1 I I I
(Pittsburg 1 0 1 0 1 2.(S,E); 11:S,E 11 -- 1-- 1 4 1 0 11985: Need backflow device, Need new sight gauge on I
I 1 I I (S) 1 11 1 1 1 Isprayer; Need storage permit for 2,4-Di Need poison I
I I I I I It I I I Isiga posted. 1
I I I I 1 11 1 1 1 1 I
(Richmond I I I MPA,E); 11:R,HQ,S 111R,H8,S,EI1 1 1 2 1 0 1 0 11979: Lack employee training. I
1 I 1(R,HQ,S,E);I 1 II 1 1 1 119841 Need possession and use permits for restricted)
I I I (S,PA,A) I 1 11 1 1 1 Imaterials; Applicators using improper safely I
I 1 I I 1 II 1 1 1 Iclothing. 1
(San Ramon 1 0 1 0 1 0 1 0 11 --- I--- I--- I 1 I
I I I I 1 11 1 1 1 1 1
Walnut Creek 1 0 1 0 1 0 1 0 11 -- I— I-- I I I
I 1—I --I— I— II—I—I—I-1 I
I TOTAL 1 11 1 15 1 10 1 12 II 3 1 7 1 13 1 5 1 1
R: certified applicator record audit PA: prt-application site inspection N: mix/load inspection E: equipment inspection
S: pesticide storage site inspection NO: employer headquarters inspection A: application inspection
'Data from LSE's report 'Publicly Administered Pest Control Progams and Their Regulation in Contra Costa County,' 1980.
-page 21-
1
51CBE000 �
County. ) Byron was inspected once in 1986 (storage and equipment only) with
no violations found. Brentwood and Knightsen both had one inspection
each (storage area only) in 1984 and 1986. No violations were found at
Brentwood. In 1986, Knightsen was cited for failing to properly post a warning
sign on the pesticide storage area. Moraga was inspected once in 1985 and
cited for one violation, also for failing to post a poison sign on a storage
shed. Pittsburg was inspected twice in 1985 (once for storage and equipment
and once only for storage) with four violations found. Two were due to improper
equipment maintenance, one was due to lack of a storage permit for 2,4-D, and
one was, due: to ,failing to post a poison sign on the storage shed. Pittsburg was
inspected once .i.n,' 1986 with no violations discovered.
Despite the fact that most school districts in Contra Costa County apply
pesticides, none have a formal written policy outlining how and when pesticides
will be used. None post notices in areas where pesticides have recently been
applied, according to CBE's survey of school district personnel in Contra Costa
County. A few indicated that notices would be posted if required on the
pesticide label , .but this is very rare and County officials were not aware of
any. situations where state law would require posting on school grounds.
Decisions about pesticide use .tend to be made by individual maintenance staff.
Some personnel indicated that the only real guidelines considered are state and
federal regulations. Many districts indicated that pesticides are applied only
when children are not present, either in the early morning (not more than a few
hours before children arrive) , or in the afternoon or on weekends (school
grounds are often used at these times by children and the general public).
Without notices , these people cannot, be aware of any recent pesticide
applications.
-page 22-
O o po
CONCLUSION 1 2:
THE OVERUSE OF PESTICIDES IN OUR SCHOOLS POSES AN UNNECESSARY HEALTH RISK TO OUR
CHILDREN.
Pesticides are poisons designed to disrupt biological systems, and are
intentionally released into the environment in a manner that may result in human
exposure. As such they pose an inherent threat to human health. Children are
even more susceptible to toxic chemical exposures than adults, due to their
faster growing and breathing rates, lower body weights, and playing habits which
increase their chance of coming into contact with pesticide-treated surfaces.
In addition to the potential for accidental immediate poisonings, repeated low
level exposure to pesticides may also lead to more long-term health effects.
The three most widely used herbicides in Contra Costa County schools are all
suspected carcinogens, and eight of the pesticides used by schools in Contra
Costa County will be undergoing a health risk assessment by the CDFA because of
adverse health effects noted in lab tests. Because of these concerns, pesticide
use should be kept to an absolute minimum in our schools.
The health risks of pesticide use depend on the degree of human exposure and on
the chemical 's intrinsic hazardous properties, such as its toxicity. Because
public records are not available for most school district pesticide use, it is
difficult to make an accurate assessment of the potential for student or staff
pesticide exposure. Incidents of inadvertent pesticide poisoning of students
and staff in other Bay Area counties have been documented (6).
In Contra Costa County in 1986, one pre-school teacher suffered "respiratory
symptoms" and several students suffered "irritations" after chlorpyrifos
(Dursban: an organophophate insecticide) was sprayed on children's play
equipment in a small room to control fleas. No violations were found and no
further action was taken (7). Chlorpyrifos is one of the insecticides being
reviewed by the CDFA in response to a report put out by the California
Department of Health Services entitled "An Assessment of the Hazard From
Pesticide Absorption From Surfaces" (8).
-page 23-
SCBE R
In addition to potential acute exposures, long-term or chronic low level
exposure to pesticides also poses an unnecessary health risk to children and
other members of the community. Th•e chronic toxicity of many of the pesticides
used in and around schools in Contra Costa County is strongly suspected or
already established. The great lack of information on the chronic health
effects of most pesticides was discussed in "Regulatory Background".
Of all school district pesticide use reported to the County, glyphosate,
simazine and amitrole were used in the largest amounts , and by three or more
districts. None 'of these'are restricted pesticides, but all pose potential
health threats. Glyphosate or Roundup (2450 pounds applied) is a relatively new
(and expensive) weed killer introduced by Monsanto. Every district which
reported.,its pesticide use reported using Roundup. Numerous cases of eye and
skin injury from exposure to Roundup have been reported, two studies indicate it
4 is a weak mutagen, and a recent review by the U.S. Environmental Protection
Agency temporarily classed Roundup as a "weak carcinogen" (9). Laboratory tests
of simazine (1009 pounds used .by three districts) have shown it to be both a
mutagen .and potential carcinogen (10). Amitrole .(858 pounds used by three
districts) is a suspected carcinogen (11) and is at the top of the CDFA's Risk
Assessment Priority List, due to potential adverse health effects identified in
an oncogenicity (tumor-causing) study and a birth defect study. This list is
made up of pesticide active ingredients "identified as having potential adverse
health effects in studies of sufficient quality to permit a risk assessment"
(12). The CDFA will reportedly be reassessing the health hazards of these
pesticides, and have assigned each pesticide high, moderate, and low priority
for reassessment. Oryzalin, while not used in large amounts (316 pounds total
-page 24-
8CBEFA° o
reported) , was used by six of the seven reporting districts. It has been
classed as a "probable human carcinogen" by the EPA (13) and has been given
"moderate" priority on CDFA's Risk Assessment Priority List due to adverse
effects noted in an oncogenicity study. Other pesticides reported by Contra
Costa County schools and found on the Risk Assessent Priority List include:
diquat (high priority for review of a chronic toxicity study) ; acephate
(moderate priority for review of a mutagencity and an oncogenicity study) ;
oxadiazon (moderate priority for review of a chronic toxicity and an
oncogenicity study) ; dicamba (low priority for review of a neurotoxicity
study) ; diuron (low priority or review of a mutagenicity study) ; and
glyphosate (low priority for review of an oncogenicity study).
Six school districts have permits for their staff to apply restricted
pesticides. Restricted pesticides may also be used on other school district
grounds by commercial pest control operators (see "Regulatory Background page
3). All of the PCOs spraying for weeds have permits to apply 2,4-D and reported
applying it in Contra Costa County, although it is impossible to know where.
Albany (for fields in Contra Costa 'County only) , Contra Costa Community College,
Martinez, Mt. Diablo, Orinda and Richmond districts have permits to use the
restricted herbicide 2,4-D, although only four of those. districts applied 2,4-D
(Table 10). This herbicide is used to kill broad-leafed weeds such as
dandelions in turf and playing fields. Many studies indicate that 2,4-D has the
potential to cause birth defects and a recent study has implicated it as a
carcinogen (14). Carbaryl , lindane and strychnine were also used by several
districts. These are restricted materials in California, but do not require a
permit for "non-agricultural use" such as on school grounds.
-page .25-
1
ACBE WI
TABLE 10: RESTRICTED MATERIALS PERMITS AND NOTICES OF INTENT TO SPRAY 1984 - 1986
-------------------------—-------------------------------------—-------------------------------------------
ISCHOOL I RESTRICTED MATERIAL PERMITS (PEST TO BE CONTROLLEDI NOTICE OF I
IDISTRICT I STORAGE ONLY I POSSESSION & USE I(According to permit)( INTENT FILED 1
I'-------------------------------------------��------------------------------------I
IAcalanes 12,4-D Amine I I
I 17/12/84-12/31/84 I 1 I I
i I I I I I
(Albany I 12,4-D Amine, Banvel (Broadleaf weeds IYes; 6/1/85 I
I 1 15/30/85-12/31/85 1 1 I
1
!Contra Costa 1 IBest Weed &feed, w/ 18roadleaf weeds IYes; 5/8/84 1
(Community I ITrimec, 2,4-D, Banvell INo NOI for use 7/84 1
(College 1 14/7/84-5/13/84 1 I 1
I I I I 1 I
1 I 12,4-D, Banvel (Broadleaf weeds IYes; 6/14/85, 9/20/85 1
I 1 15/22/85-12/31/85 1 INo NOI for Trimec applic.l
1 I 1 1 13/85 or 2,4-D-Banvel I
I I 1 I 14/85; phoned in NOI for I
I I 1 1 17/85 application. I
I I 12,4-D, Banvel 18roadleaf weeds IYes; 3/26-3/28/86, 3/26 1
I I 12/13/86-12/31/66 1 13:00 am;9/27/86 Iqt/acre I
1
ILafayette 12,4-D, Dieldrin I I I I
1 15/11/84-12/31/84 1 1 1 1
I I I I I I
IMartinez 1214-D Amine, Banvel 12,4-D Amine, Banvel (Broadleaf weeds lYes;4/19/869Trimec 2qt/
I 16/19/84-12/31/84 13/28/86-12/31/B6 I lacre I
1
I 12,4-D Ervine, Banvel I 1 I I
I 19/9/B5-12/31/85 I I 1 I
I I I I I I
IMaraga 12,4-D,(Weed B-Gone) I I I I
1 16/11/85-12/31/85 1 I I I
1
IMt. Diablo IStrychnine, 2,4-D AminelBanvel, 2,4-D Amine I INo use reported I
1 13/14/84-12/31/84 17/23/85-12/31/B5 I I I
I I I I I I
IOrinda ISevin, Banvel 12,4-D Ervine, Banvel I IYes; 8/4/86 (24hr notice I
1 14/16/84-12/31/84 15/9/86-12/31/86 1 (waived) I
I I I I I I
I 12,4-D Amine, Banvel I 1 I I
1 112/6/65-12/31/85 1 I 1 I
(Pittsburg 12,4-D I I I I
1 111/20/85-12/31/85 1 I 1 1
1 I I 1 I I
[Richmond I 12,4-D Amine, Banvel (Broadleaf weeds IYes; 5/17/84; 4/IB-19/84;1
I I 11/17/84-12/31/84 1 14/25; 6/28; 6/29 1
I I 1 1 1 1
I IMetasystox 12,4-D Amine, Banvel 18roadleaf weeds (Yes; 4/2-4/85 1
1 11/16/85-12/31/85 11/16/85-12/31/85 1 14/4/85 1
1 1 1 1 1 1
I IMetasystox R 1214-D Amine, Dicamba (Turf INo use reported in 1986 1
I 11/6/86-12/31/86 (Amino Triazole 1 I(metaysystox traded back 1
I I 11/16/86-12/31/86 1 Ito co. by 1/29/87) 1
-page 26-
8CBEFOPWT
CONCLUSION # 3:
THE COUNTY DEPARTMENT OF AGRICULTURE DOES NOT PROVIDE ADEQUATE OVERSIGHT OF
SCHOOL DISTRICT PESTICIDE USE.
The two primary methods of oversight are pesticide use reporting and inspections
by the County. From 1984-1986, the County only inspected four of 1397 reported
school staff applications. Only twelve of the seventeen districts whose staff
apply pesticides were inspected, and only six of those were inspected every
year. In addition, the County inspected, on the average, only one out of every
10,000 applications by commercial pest control operators (not just school
district applications). Finally, the County has not been consistent about
following up on its request to have all pesticide use reported by school
districts.
The County Department of Agriculture is the only agency which monitors how
pesticides are used by local school districts, and enforces pesticide use
regulations (see "Regulatory Background" , page 3). Most school staff have
little or no formal training in pest management or pesticide hazards. Thus
pesticide use in schools is a particularly important- area in which the County .
exercises regulatory oversight.
Inspections
School District Staff Use: Over the three year period surveyed, five of the
17 districts whose staff apply pesticides were never inspected by the County
Department of Agriculture. Two of the 12 that were inspected were only
inspected once in those three years (15 inspections in nine districts were done
in 1984, 10 inspections in nine districts were done in 1985, and 13 inspections
in 11 districts were done in 1986) (Table 9). The majority of these inspections
-page 27-
SCBE AP
included only a review of records (training records, use reports, and restricted
materials permits) , pesticide storage areas, and equipment (but not while in
use). Inspections of the employer headquarters (for things such as posting of
emergency medical care and health information) , of sites before application of
pesticides , of. mixing and loading tanks with pesticides, and of pesticide
applications , were rare.
Over the three year period, only four of the 1397 reported school district staff
applications were inspected (less than 0.3%) : three were done in 1984, none in
1985, ,and one in 1986. . All of the applications inspected were by qualified
applicators in large districts. While inspecting applications by trained staff
is important, these inspections do not address concerns about pesticide use by
staff with no formal training at all .
Little increase in inspections has occurred since 1979, when 11 inspections were
done in eight districts. Violations cited have been more serious than in 1979,
iwhich may or may not indicate more thorough and better inspections. Despite the
lack of application inspections , site and record inspections do provide some
opportunity to regulate pesticide use. In fact, almost half of all violations
. noted (11 of 25) during 1984=:1986 were due to restricted material permit
problems or equipment problems, both important safety issues , even though none
of these were noted during an actual application.
One or more violations of state or federal pesticide regulations were found in
nine of the twelve school districts inspected. For the twelve school districts
inspected in 1984-1986, the most frequently observed violations included lack of
a qualified applicator or valid permit (6 violations) , using improper equipment
page -28-
aCBE° & ° o
(5 violations) , failing to submit pesticide use reports (5 violations) and lack
of employee training records (5 violations). Because the County almost never
inspects actual applications, most of these are "paper" violations.
Nonetheless, they indicate serious problems with untrained staff and the
potential for misapplication of pesticides.
The County, in general , seems to inspect primarily those districts which submit
pesticide use reports. Of the seven which did some pesticide use reporting, all .
but Lafayette were inspected annually by the County. In addition the County
inspected the following districts at least once: Albany (those areas in Contra
Costa County) , Brentwood, Byron, Knightsen, Moraga and Pittsburg. None of these
have reported any pesticide use to the County in the last three years. Yet the
district which was cited for the largest number of violations in 1985 was
Pittsburg, a district which has not submitted reports in the last three years ,
and which therefore might not have been inspected.
Pesticide Use by Commercial Pest Control Operators: In addition to district
staff applications, PCOs applied pesticides on school grounds an unknown number
of times. The only school ground PCO applications inspected (for those
companies listed by district staff) were two phostoxin applications for control
of ground squirrels done by Crane Pest Control at Los Medones College (of the
Contra Costa Community College District). No violations were cited.
Of the seven PCOs listed as school district contractors by school personnel , all
but Clark were inspected during a pesticide application at least once in 1985
and once in 1986. Although on the surface this seems like a better record than
for school district applications, the County has actually, on the average, only
-page 29-
inspected one out of every 10,000 applications made by these PCOs. The County
averaged 2.6 inspections per year for these companies. Twenty five per cent of
these inspections noted at least one! violation (nine of 36 inspections done in
1985 and 1986). Unlabeled containers was the most frequent violation (four
times). The other violations cited were: containers not properly rinsed or
handled (two) , pesticide enclosure or storage box not locked (two) , lack of a
valid permit (one) , lack of written recommendation for application (one) , and
failing to write amounts of pesticides used on personnel records (one).
County follow-upon. violations noted consisted generally of ensuring at any
subsequent inspections that corrections had been made. No letters of warning
were sent to any of the,'school districts or any of the seven PCOs during the
last three years.
Pesticide Use Reporting
The second primary means of County oversight of pesticide use in schools is .
through pesticide use reporting. Twelve school districts did not submit any
monthly pesticide. use reports, despite staff use of pesticides. As noted
earlier, the Contra- Costa County Department of Agriculture has asked that public
agencies and institutions report all pesticides used. The County, however, has
not made this a legal requirement, and does not request reporting consistently.
Despite the serious lack of pesticide use reporting, there has been a
significant improvement in reporting by school districts since 1979, when only
three districts submitted any use reports (of those three, only Richmond
submitted all 12 reports). The County appeared to make an effort to improve
-page 30-
8CBERaP=
school district reporting in 1984. Three districts which did not even hold
restricted pesticide use permits were cited by the County for not submitting
reports. However, in 1985 and 1986., three districts which did have restricted
material permits were not cited for failing to submit reports. In addition,
when the County requested reports but did not receive them there was no record
of any follow-up. The County should consistently require monthly reporting
(including reports that no pesticides were used) from all districts using any
pesticides.
The primary reason cited by County officials for lack of school district
.pesticide use enforcement is lack of staff. According to County officials, only
five people are available (due to budget restrictions) to carry out inspections,
not only for school districts but for all public agencies, commercial pest
control companies , growers and pest control advisors in Contra Costa County. In
addition, performing inspections makes up only a fraction of their job
responsibilities. On the average, these five people spend 60% of their time on
pesticide use enforcement, including inspections, issuing permits and
certifications, and investigating pesticide use incidents. Due to these .
restraints , a more casual form of inspection has developed in which the County
makes periodic telephone calls to check for problems. The County tries to
establish some form of contact with the various agencies and school districts in
lieu of formal inspections. When a specific problem is reported, then there
will be an immediate response.
There is no meaningful reporting of PCO applications at the County level , since
applications are not reported on a site by site basis. PCOs are required to
keep .site records in their office. These records should be open to the public.
-page 31 -
Because the information is most important to each individual district, PCOs
should report all pesticide use in a particular district to that district's
grounds or maintenance department, on a site. by site basis.
RECONNENDATIONS FOR INCREASED COUNTY DEPARTMENT OF AGRICULTURE OVERSIGHT OF
SCHOOL DISTRICT PESTICIDE USE
1. The Contra Costa County Department of Agriculture should consistently
require, that, all school districts record and thoroughly report both restricted
and:unrestricted pesticide use, including "ne§ative use" reports.
Complete, timely pesticide use reports provide an invaluable tool for alerting
the County to the amounts and types of pesticides being used in Contra.Costa
County schools. The County can ensure that restricted pesticides are not being
applied illegally and that all districts which apply insecticides are being
inspected regularly.
2. All school districts which do any chemical pest control should be inspected
by the County at least once each year, .including an inspection of an actual
application.
The County should not limit its inspections to large districts with qualified
applicators. Applications of unrestricted pesticides by minimally trained staff
are equally important and have greater potential for accidental exposure to
students and staff.
-page 32-
CONCLUSION 04:
SCHOOL DISTRICT PEST PROBLEMS CAN BE CONTROLLED WITHOUT EXTENSIVE USE OF
PESTICIDES.
Because of concerns about the known and unknown health risks posed by pesticide
use, the safest approach to pest control in the schools is to minimize or
eliminate all pesticide use. Several districts have begun to do this by
adopting pest management policies that ensure that safe, non-toxic pest control
methods are given priority, that pesticides are only used as a last resort, and
that notices are posted when pesticides are applied.
Several school districts in the Bay Area have begun to reduce their pesticide
use. Districts in Fairfax, San Anselmo, Berkeley and Palo Alto have committed
to this reduction by adopting written policies which give priority to non-toxic
pest control . Such a policy commits the school district to using safe effective
non-toxic pest control methods while reducing or eliminating chemical pesticide
use.
To assist the Berkeley School District in implementing its pest management
policy, adopted in 1984, CBE piloted a short science curriculum on urban insects
and safe pest management (15). Students and teachers learned about the new
policy, and how to identify insect pest problems and modify the school
environment to control pests without using chemicals.
In Eugene, Oregon, the school district has adopted a similar policy focusing on
non-toxic solutions to pest problems (16). The school district has hired a
full -time pest management consultant to help develop these alternatives.
-page 33 -
aC� 0000
In Flint, Michigan, the John Muir :institute helped the school district to
develop and implement effective s6 ence unit curricula on non-chemical pest
management of school pests (17). Using these curricula on rodents and
cockroaches, students and teachers learned to identify potential food and hiding
places in their homes and at school , and how to eliminate pests without using
potentially hazardous chemicals.
RECONNENDATIONS FOR SAFE PEST CONTROL BY SCHOOL DISTRICTS IN CONTRA COSTA COUNTY
It is clear that pesticides continue to be the pest control method of first
resort for most school districts in Contra Costa County. Given the low level of
pesticide enforcement and surveillance by the County Department of Agriculture,
and the extent to which hazardous pesticides are used by minimally trained
i
istaff, school districts must take greater responsibility for ensuring safe and
effective pest management. Following are several recommendations for school
districts seeking to create a safer environment for their students.
1. Adopt a safe pest management policy.
Every school district should have a comprehensive pest management policy which
ensures that all pest management problems will be dealt with in a safe and
consistent manner. This policy should be officially adopted by the district's
elected school board.
-page 34 -
BCBE AP(
The primary intent of a good pest management policy should be to reduce or
eliminate the use of toxic pesticides while providing safe and effective pest
control . The policy should govern pesticide use by school staff and by
commercial pest control contractors. It should include the following
components:
1) Establishment of a community pest management advisory committee made up
of citizens and school staff to develop policy and pest management
procedures and plans ;
2) Procedures for developing site or pest specific plans. Each plan should
outline the combination of physical , cultural , biological and chemical
control methods to be used ; state which methods are preferred (giving
priority to non-toxic control methods) ; and state specifically what
pesticides can be used in which specific situations (if any) ;
3) Development of criteria for selection of pesticides ;
4) Provisions for public notification of any pesticide use (notices should
be clearly posted by staff or by the contracted PCO) ;
5) Provisions for staff training in integrated pest management and
non-toxic control alternatives ; and
6) Provisions for student and community involvement and education.
-page 35 -
SCBEPAPM7
2. Improve pesticide use reporting and record keeping in the school district,
both for school staff applications and for commercial pest control
applications.
The public should have access to information about pesticide use on school
grounds, including information about health effects and risks associated with
any pesticides applied. School districts should keep thorough records on all ,
pesticides used by school staff and make monthly reports as requested by the
Contra Costa County Department of Agriculture. School districts should also
request from their commercial pest control contractors regular reports on all
pesticides used on their school grounds and request that their contractor
provide written reports identifying any pest related improvements needed in
school facility sanitation or maintenance. These records should also be
accessible to the public.
3. Train school staff in safe pest: management techniques.
Too frequently, most pest management training is focused on how to use
pesticides. Grounds and maintenance staff need to be trained in alternati.ve
pest control methods. All staff who do apply pesticides should be trained as
"qualified applicators". The entire school staff needs to be fully informed
about any new pest management policy. The information should be disseminated
through memos, any regularly scheduled meetings and special information
sessions. Custodial and gardening staff need explicit training and adequate
resources for implementing non-chemical pest management techniques.
-page 36-
COXAMPOP07
4. Educate students about pest problems and safe pest control ..
Because many non-chemical solutions to pest problems include decreasing the
pests ' resource availability (food and living space) , education in the classroom
is essential to effective school pest management. This can also become a
valuable lesson in applied science. Children need to learn why it is important
to keep classrooms free of food and trash. They need to learn what precautions
to take to avoid pesticide hazards. Classroom education will reinforce among
teachers and other school staff the importance of alternative pest control
methods. Resources include the Flint, Michigan curricula available through the
Bio-Integral Resource Center in Berkeley (18) , CBE's curriculum, and the
University of California.
5. Educate the community.
School districts can .use this opportunity to serve as a model for safe pest
control . Some of the most dangerous pesticide abuse occurs in the home.
Informing parents of a new school district pest management policy may begin to.
teach students' parents about the hazards of their own pesticide use, the
availability of alternatives, and the possibility of tolerating certain "pests"
which do no damage and pose no hazard. If parents are informed, this may also
help ensure that school staff follow the policy as closely as possible. The
community can be informed through a public hearing, workshops, or general press
releases.
-page 37-
3CBE o p O
REFERENCES
1. California Department of Food and Agriculture. 1980. Report of pesticides
sold in California for 1980. Division of Pest Management.
von Rumker, R. , R. Mather, D. Clement and F. Erickson. 1972. The use of
pesticides in suburban homes and _gardens and their impact on the aquatic
environment. Office of Water Programs. U.S. Environmental Protection
Agency.
2. U.S. , General . Accounting Office. 1986., Pesticides : EPA's Formidable Task
to Assess and Regulate Their Risks. Report to Congressional Requesters.
,(GAO/RCED-86-125) April .
3. California Department of Food and Agriculture. 1985. Report to the
Legislature on the Birth Defect Prevention Act of 1984. December 31, 1985.
4. U.S. Department of Agriculture and U.S. Environmental Protection Agency.
Apply. Pesticides Correctly, A Guide for Commercial Applicators. p. 41-3.
5.. Dreistadt, S.. , 1980. . Publicly administered pest control programs and their .
regulation in Contra Costa County. Citizens for a Better Environment.
CBE-80681. (October).
6. Dreistadt, S. 1984. Public agency pesticide use and regulation in Santa
Clara County. Citizens for a Better Environment. CBE-84680. (March).
7. Pesticide Incident Report, Contra Costa County Department of Agriculture.
April 1986.
8. Berteau, P. and D. Mengle. 1985. An Assessment of the Hazard from
Pesticide Absorption from Surfaces. Community Toxicology Unit,
Epidemiological Studies Section, California Department of Health Services.
May.
9. U.S. Environmental Protection Agency. 1986. Guidance for the
Reregistration of Pesticide Products Containing Glyphosate as the Active
Ingredient. Office of Pesticides and Toxic Substances. June.
10. Guerzoni , M.E. , L. Del Cupolo and P. Ponti . 1976. Mutagenic Activity of
Pesticides. Riv. Sci . Technol . Alemeit Nutr. UM ,6:161-165.
Pliss , G.B. and M.A. Zhinski . 1970. New data on carcinogen properties of
some derivitives of symmetrical triazine. Proceedings of 10th International
Union Against Cancer. Houston., 1970, published in series "Oncology 1970."
-page 38-
a3)rpo p O
11. U.S. Environmental Protection Agency. 1984. Chemical Information Fact
Sheet for 3-Amino-1,2,4-Triazole. May 14, 1984.
U.S. Department of Health and Human Services. 1983. Third Annual Report on
Carcinogens. Public Health Service.
12. California Department of Food and Agriculture. 1987. SB 950 Risk
Assessment Priority List. January 1987.
13. U.S. Environmental Protection Agency. 1986. Guidance for the
Reregistration of Pesticide Products (Registration Standard) Containing as
the Active Ingredient: Oryzalin. Case number: GS-0186. Office of
Pesticide Programs.
14. Hazard Evaluation System and Information Service. 1980.
2,4-Dichlorophenoxyacetic acid (2,44). Evaluation of the human health
hazards. California Department of Health Services/Department of Industrial
Relations.
Hoar, S. K. , A. Blair, F.F. Holmes et al . 1986. Agricultural herbicide use
and risk of lymphoma and soft-tissued sarcoma. Journal of American Medical
Association. 256 (9/5/86).
15. Bush, D. and S. Dreistadt. 1987. Living With Insects in the Big City: .
Urban Insect Ecology and Safe Pest Management. A Science Curriculum for
Grades K-3. Citizens for a Better Environment.
16. Eugene Public Schools. 1985. Landscape Management policy. School District
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