Healthy and Safe Schools

In 2017, the Oregon State Legislature passed SB 1062, which requires that, every school district, education service district, and public charter school develop a Healthy and Safe Schools Plan (HASS Plan). Each organization’s HASS Plan has specific requirements that must be included for the HASS Plan to comply with state law.

In 2017, the Oregon State Legislature passed SB 1062, which requires that, every school district, education service district, and public charter school develop a Healthy and Safe Schools Plan (HASS Plan). Each organization’s HASS Plan has specific requirements that must be included for the HASS Plan to comply with state law. All HASS Plans are due to the Oregon Department of Education by July 1, 2021. Additionally, each school district, education service district, and public charter school is required to certify annually that the organization continues to comply with the requirements of the HASS Plan by filing an Annual Statement. The following plan was developed by Clackamas ESD to meet these requirements.

  1. Responsible Person The person responsible for administering and implementing the Healthy and Safe Schools Plan:
    Name: Michael Waer
    Position Title: Operations Coordinator Phone
    Number: (503) 675-4094
    Email Address: mwaer@clackesd.k12.or.us
    Mailing Address: 13455 SE 97th Avenue, Clackamas OR 97015The person who is the designated IPM Coordinator:
    Name: Marvin Hill
    Position Title: Facilities Manager
    Phone Number: (503) 675-4007
    Email Address: mahill@clackesd.k12.or.us
    Mailing Address: 13455 SE 97th Avenue, Clackamas OR 97015The person responsible for AHERA information:
    Name: Michael Waer
    Position Title: Operations Coordinator
    Phone Number: (503) 675-4094
    Email Address: mwaer@clackesd.k12.or.us
    Mailing Address: 13455 SE 97th Avenue, Clackamas OR 97015
  2. List Facilities
    All facilities owned or leased by Clackamas ESD where students or staff are present on a regular basis are covered by this HASS Plan. The list of those buildings and facilities is below:

    • Sunnybrook Campus (Administration Building) 13455 SE 97th Avenue, Clackamas OR 97015
    • Heron Creek Program Marylhurst University 17600 Pacific Hwy., Suite 105, Marian Hall Marylhurst, OR 97036
    • Clackamas Early Learning Center 13535 SE 97th Avenue, Clackamas OR 97015
  3. Elevated Levels of Lead in Water Used for Drinking or Food Preparation
    All school districts, education service districts, and public charter schools are required to test for and eliminate exposure to elevated levels of lead in water used for Drinking and Food Preparation through either remediation or eliminating access, according to OAR 333-061-0400 and OAR 581-022-2223. In conformance with those administrative rules, Clackamas ESD certifies the following:

      1. All testing was done according to the testing requirements in OAR 333-061-0400;
      2. All samples were analyzed by a lab accredited by Oregon Health Authority to test for those materials;
      3. All water fixtures required to be tested under OAR 333-061-0400 were tested for elevated levels of lead in accordance with the testing schedule developed by the Oregon Health Authority; and
      4. The testing schedule for each building covered by this plan is set forth below:
    Facility Testing Schedule
    Facility NameYear of Last TestNext Scheduled Test (Beginning of 6-Year Schedule)Schedule or Exemption Reason
    Sunnybrook Campus20242030 fiscal year6-year schedule
    Heron Creek Program20242030 fiscal year6-year schedule
    Clackamas Early Learning Center20242030 fiscal year6-year schedule
  4. Lead Paint
    In order to comply with the United States Environmental Protection Agency’s Renovation, Repair and Painting Program Rule, the district will either contract only with certified lead based paint renovation contractors licensed by the Oregon Construction Contractors Board, or use District staff that are certified by the Oregon Health Authority to perform the work.
  5. Asbestos
    Clackamas ESD complies with the federal Asbestos Hazard Emergency Response Act (AHERA). All required asbestos management plans are available for viewing by submitting a request to Michael Waer, Operations Coordinator, mwaer@clackesd.k12.or.us, 503.675.4094
  6. Radon
    Clackamas ESD has developed a radon plan as required by ORS 332.345. Community members can access a copy of the radon plan and test results will be made public and are available here: Healthy and Safe Schools Plan and Test Results
  7. Integrated Pest Management
    Clackamas ESD has adopted an Integrated Pest Management (IPM) plan as required by ORS 634.700 through 634.750. Community members can access the IPM plan here.
  8. Carbon Monoxide Detectors
    Clackamas ESD certifies that all buildings subject to the Healthy and Safe Schools Plan comply with the carbon monoxide detection standards in the state building code that was in effect when the building was originally constructed or as required by building code due to addition, upgrade, or remodel.
  9. Test Results Publication
    Clackamas ESD is complying with the requirement to provide access to test results, as defined by OAR 581-022-2223 within 10 business days as defined by ORS 332.334. Test results can be found on the Healthy and Safe Schools page of CESD’s website.

Additionally, copies of all test results are available upon request at 13455 SE 97th Avenue, Clackamas OR 97015 in the ESD’s administration offices. Clackamas ESD will also use current email lists or communications programs to provide final test results to staff, students, parents of minor students, and other members of the community. This includes providing actual final test results or providing direct access to final test results through links in the communications. Please contact Michael Waer, mwaer@clackesd.org, 503.675.4036 to be added to current email lists and programs.

The 2015 Legislature passed House Bill (HB) 2931 so that elevated radon levels in Oregon schools would be known. House Bill 2931 later became Oregon Revised Statute (ORS) 332.166-167. As directed by this statute, all school districts in Oregon must develop a plan to accurately measure school buildings for elevated radon levels. Under the statute, school districts must submit a plan to Oregon Health Authority (OHA) by September 1, 2016. Per ORS 332.166-167, actual testing of schools must be done on or before January 1, 2021 and the testing results sent to OHA and posted on the school or school district’s website.

This plan will develop the protocols necessary for compliance. OHA’s Testing for Elevated Radon in Oregon Schools, specifically Appendices A and D will be used to guide this effort. Below is the plan developed for the Clackamas Education Service District.

Per ORS 332.166-167, School Radon Measurement Teams (i.e. personnel appointed to measure a school site for elevated radon) must, at a minimum, conduct initial measurements in all frequently occupied rooms in contact with the soil or located above a basement or a crawlspace. Testing will occur in all frequently occupied spaces simultaneously per school site. Examples include: offices, classrooms, conference rooms, gyms, auditoriums, cafeterias and break rooms. A minimum of one detector for every 2,000 sq. ft. of open floor space or portion thereof is required. United States Environmental Protection Agency (USEPA) studies indicate that radon levels on upper floors are not likely to exceed the levels found in ground-contact rooms. Testing rooms on the ground-contact floor or above unoccupied basements or crawlspaces is sufficient to determine if radon is a problem in a school. Areas such as rest rooms, hallways, stairwells, elevator shafts, utility closets, kitchens storage closets do not need to be tested.

Initial and follow-up testing, as needed, will use passive test devices. Active devices (electrically powered, continuous radon monitors) may be used in follow-up testing of locations, if needed, where it is important to determine that radon levels vary according to the time of day. Because testing under closed conditions is important to obtain meaningful results from short-term tests, the District will schedule testing during the coldest months of the year. “Closed building conditions” are defined as keeping all windows closed, keeping doors closed except for normal entry and exit, and not operating fans or other machines which bring in air from outside. Fans that are part of a radon-reduction system or small exhaust fans operating for only short periods of time may run during the test. Testing will occur between October and March in any given school year. Short term testing will be used with passive test kits will be used in “closed building conditions.” Test kits will be placed during weekdays with HVAC (heating, ventilation, air conditioning) systems operating as they do normally. The following is a detailed protocol instruction checklist:

  1. A Test Kit Placement Log and a Test Kit Location Floor Plan will be prepared for each school in which radon measurements are made. Schools will use their emergency/fire escape plan as a template. Test kit location will be accurately recorded on both a Log and Floor Plan. Test kits or testing services must meet the current requirements of the national certifying organizations, National Radon Proficiency Program (NRPP, www.nrpp.info) or the National Radon Safety Board (NRSB, www.nrsb.org). Testing must be done following the directions on the test kit.
  2. Per ORS 332.166-167, school radon measurement teams must, at a minimum, conduct initial measurements in all frequently occupied rooms in contact with the soil or located above a basement or a crawlspace. Room examples include offices, classrooms, conference rooms, gyms, auditoriums, cafeterias and break rooms.
  3. The number of test kits used to measure radon (detectors) must be determined by counting the number of appropriate rooms. One detector kit is used for each room that is 2,000 square feet or less. Additional test kits are needed for larger rooms.
  4. Added to this number will be the test kits needed for Quality Assurance purposes.
  5. Test kits will be placed in all rooms in contact with the soil or located above a basement or crawlspace that are frequently occupied by students and school staff.
  6. Testing will occur during the time that students and teachers are normally present (during weekdays).
  7. In addition to placing detectors, additional test kits will be provided to serve as quality assurance measures (duplicate, blank, and spike measurements). Quality Assurance procedures will be conducted as described in OHA’s Testing for Elevated Radon in Oregon Schools.
  8. All test kits placed in the school site (detectors, duplicates, and blanks) must be noted on the Device Placement Log and Floor Plan by their serial number.
  9. Test kits should be placed.
    • Where they are least likely to be disturbed or covered up.
    • At least three feet from doors, windows to outside or ventilation ducts.
    • At least one foot from exterior walls.
    • At least 20 inches to six feet from floor.
    • About every 2,000 square feet for large spaces (e.g., a 3500 square foot gymnasium would require two test kits)Along with the five-item placement protocol above, School Radon Measurement Teams can simply place the test kit on the teacher’s desk or up on a bookshelf, out of the way of students. To prevent tampering, kits may be suspended from a wall or ceiling (using string and thumb-tack/tape). If they are suspended, they should be 20 inches to 6 feet above the floor, at least 1 foot below the ceiling.
  10. Test kits must NOT be placed:
    • Near drafts resulting from heating, ventilating vents, air conditioning vents, fans, doors, and windows.
    • In direct sunlight.
    • In areas of high humidity such as bathrooms, kitchens, laundry rooms, etc.
    • Where they may be disturbed at any time during the test
  11. Testing with short-term test kits must be used under closed conditions (closed windows/doors except for normal exit/entry).
    • Closed conditions: Short-term tests should be made under closed conditions in order to obtain more representative and reproducible results. Open windows and doors permit the movement of outdoor air into a room. When closed conditions in a room are not maintained during testing, the subsequent dilution of radon gas by outdoor air may produce a measurement result that falls below the action level in a room that actually has a potential for an elevated radon level. Schools shall only be tested for radon during periods when the HVAC system is operating as it does normally.
    • All external doors should be closed except for normal use – structural and weatherization defects need to be repaired prior to testing.
    • Closed conditions must be verified when placing and retrieving test kits.
  12. Short-term test kits will be placed during colder months (October through March).
    • Colder months: Because testing under closed conditions is important to obtain meaningful results from short-term tests, the District will schedule testing during the coldest months of the year. During these months, windows and exterior doors are more likely to be closed. In addition, the heating system is more likely to be operating. This usually results in the reduced intake of outside air. Moreover, studies of seasonal variations of radon measurements in schools found that short-term measurements may more likely reflect the average radon level in a room for the school year when taken during the winter heating season.
    • The District will check and document local weather forecasts prior to placing test kits. Do not conduct short-term measurements (2-5 days) during severe storms or period of high winds. The definition of severe storm by the National Weather Service is one that generates winds of 58 mph and/or ¾ inch diameter hail and may produce tornadoes.
  13. Test Kits will be placed during weekdays with HVAC (heating, ventilation, air conditioning) systems operating as they do normally. Suggested timeline: Monday morning – Place kits (detectors/duplicates/blanks) per Test Kit Placement Log created for school. Record data, as needed, on Log. Thursday morning – Pick up kits, record as needed, ship with (previously requested & received) spiked test kits to Radon Measurement Laboratory.
    • Air conditioning systems that recycle interior air may be operated.
    • Window air conditioning units may be operated in a re-circulating mode, but must be greater than 20 feet from the test kit.
    • Ceiling fans, portable humidifiers, dehumidifiers and air filters must be more than 20 feet from the test kit.
    • Portable window fans should be removed or sealed in place.
    • Fireplaces or combustion appliances (except for water heaters/cooking appliances) may not be used unless they are the primary source of heat for the building.
    • If radon mitigation systems are in place in the school, they should be functioning.
  14. The District will not conduct initial measurements under the following conditions:
    • During abnormal weather or barometric conditions (e.g., storms and high winds). If major weather or barometric changes are expected, it is recommended that the 2 to 5-day testing be postponed. USEPA studies show that barometric changes affect indoor radon concentrations. For example, radon concentrations can increase with a sudden drop in barometric pressure associated with storms.
    • During structural changes to a school building and/or the renovation of the building’s envelope or replacement of the HVAC system
  15. After receiving the results of the initial testing, School Radon Measurement Teams will follow the “Interpreting initial results” section of the OHA’s Testing for Elevated Radon in Oregon Schools.

Follow-up Measurements

Follow-up testing (in rooms with initial short-term measurement of 4.0 pCi/L or higher) should start within one month after receiving the initial test results. Follow-up testing must be made in the same location in a room. When conducting follow-up testing using short-term methods will be done in the same conditions as the initial measurement. Follow-up testing using passive short-term test kits should follow the same Quality Assurance procedures and requirements (i.e. percentages of duplicates/blanks/spikes), including quality assurance calculations. Follow directions under Radon Test Placement Strategy and Protocol Checklist and Test Kit Placement again.

Report of Results and Distribution

ORS 332.166-167 requires that school districts make all test results available: to the district’s school board; the Oregon Health Authority (to post on its website), and readily available to parents, guardians, students, school employees, school volunteers, administrators and community representatives at the school office, district office or on a website for the school or school district.

US EPA, OHA Oregon Radon Awareness Program, and numerous non-governmental groups recommend that the school district take action to reduce the radon level in those rooms where the average of the initial and follow-up short-term kit results OR the result of the long-term kit used in follow-up is 4.0 pCi/L or more.

Initial testing will be conducted in accordance with ORS 332.166-167 before January 1, 2021. Because buildings age and ground beneath them settles, radon entry may increase due to cracks in the foundation.

For that reason, ORS 332.166-167 requires that schools be tested once every 10 years regardless of initial testing results or whether mitigation was done.

Suggested times, for retesting, in addition to that required under ORS 332.166-167, are as follows:

  1. Current national guidelines (ANSI/AARST, 2014) recommend that school buildings be re-tested every five years.
  2. If radon mitigation measures have been implemented in a school, retest these systems as a periodic check to ensure that the radon mitigation measures are working. EPA does not provide a specific interval, but OHA recommends that schools with radon mitigation measures retest every 5 years.
  3. Retest after major renovations to the structure of a school building or after major alterations to a school’s HVAC system. These renovations and alterations may increase radon levels within a school building.
  4. If major renovations to the structure of a school building or major alterations to a school’s HVAC system are planned, retest the school before initiating the renovation. If elevated radon is present, radon-resistant techniques can be included as part of the renovation.

GLOSSARY

Radon – A gaseous radioactive decay product of radium.

Blanks – Measurements made by analyzing unexposed (closed) detectors that accompanied exposed detectors to the field. The School District use of blanks is to assess any change in analysis result caused by exposure other than in the environment to be measured. Background levels may be due to leakage of radon into the detector, detector response to gamma radiation, or other causes.

Closed-Building Conditions – Means keeping all windows closed, keeping doors closed except for normal entry and exit, and not operating fans or other machines which bring in air from outside. Fans that are part of a radon-reduction system or small exhaust fans operating for only short periods of time may run during the test.

Duplicates – Duplicate measurements provide a check on the precision of the measurement result and allow the user to make an estimate of the relative precision. Large precision errors may be caused by detector manufacture or improper data transcription or handling by suppliers, laboratories, or technicians performing placements. Precision error can be an important component of the overall error. The precision of duplicate measurements are monitored and recorded as quality records.

Spikes – Measurements used to assess the accuracy of a lab analysis and/or how accurately detectors supplied by a laboratory (i.e. test kit manufacturer) measure radon. “Spikes” are test kits that have been exposed to a known concentration of radon in a chamber approved by the National Radon Proficiency Program (NRPP) or National Radon Safety Board (NRSB). The process for completing this aspect of a radon measurement effort’s Quality Assurance/Quality Control plan is laid out in the Radon Test Placement Strategy and Protocol Checklist below.

Appendix A: Test Kit Placement Guide

Once the number of test kits is determined, they will be placed in the frequently-occupied rooms as identified in the “What Rooms Should Be Tested?” section above.

  • Be sure to check these items before placing the radon test kits:
    • Closed building conditions have been maintained in the building for 12 hours.
    • HVAC system is operating as it normally would when students and faculty are present.
    • Testing is being done during a time that students and faculty are present.
  • As detectors are placed in the rooms determined during section 1, thorough and accurate data needs to be recorded on the device log and floor plan (see sample below).Protocol for all test kits include the following; be sure that each detector placed is:
    • in a location where it will be undisturbed
    • out of direct sunlight
    • three feet from all doors and windows
    • four inches from all other objects
    • at least 1 foot from all exterior walls
    • at least 20 inches to 6 feet from the floor
    • out of direct air flow from vents
    • four feet from heat sourceTo protocol above, School Measurement Teams in other states simply place the test kit on the teacher’s desk or up (out of the way of students) on a bookshelf.
  • Specific protocol for duplicate measurements. If the test kit you are placing is duplicate measurement also be sure to:
    • Placed duplicate (side-by-side) test kit 4-5 inches away from test kit for that room.
  • Specific protocol for blank measurements. If the test kit you are placing is a blank measurement, also be sure to:
    • Unwrap blanks, open, but then immediately close and reseal them.
    • Place the test kit next to the detector kit(s) for the room 4-5 inches away.
  • Specific protocol for spiked test kits.
    • Arrange for the spiked test kits to arrive back from the Certified Performance Test Chamber to the School Measurement Team as close to the day that kits are retrieved from the school as possible. [See Quality Assurance Procedures for a School Radon Measurement Program in OHA’s Testing for Elevated Radon in Oregon Schools.]
  • Testing Period.
    The minimum length of time test kits should be left out is 48 hours, but not exceed seven days. [It’s best to follow test kit manufacturer’s instructions for more specific recommendations.] It’s best if devices should be left in place for four days to ensure optimum results.Many schools place short-term kits on Monday morning and pick them up on Thursday morning. Retrieving Kits: Once the testing period has ended, all test kits placed at a school site (detectors, duplicates, and blanks) need to be retrieved. This should be done on the same date. Complete the data sheet when retrieving detectors.

    • Record ending date and time (kits were pick up) information, per the “Test Kit Placement Log” [Appendix D of OHA’s Testing for Elevated Radon in Oregon Schools.]
    • Record ending information on the test kit package (if required).
  • Prepare and mail all kits.
    • Seal and prepare test kits to be mailed to the lab by the manufacturer’s instructions.
    • Include those spiked kits (not identified as such) in the same box(es) as other kit types.
    • Mail all test kits (detectors, duplicates, blanks, spikes) to the Radon Measurement Laboratory using a mail service that guarantees delivery to the laboratory within two days at maximum, but preferably overnight shipping.

I. INTRODUCTION

Structural and landscape pests can pose significant problems in schools. Pests such as mice and cockroaches can trigger asthma. Mice and rats are vectors of disease. Many children are allergic to yellow jacket stings. The pesticides used to remediate these and other pests can also pose health risks to people, animals, and the environment. These same pesticides may pose special health risks to children due in large part to their still-developing organ systems. Because the health and safety of students and staff is our first priority – and a prerequisite to learning – it is the policy of Clackamas Education Service District, herein referred to as the District, to approach pest management with the least possible risk to students and staff. In addition, Senate Bill 637 (incorporated into ORS Chapter 634 upon finalization in 2009) requires all school districts to implement integrated pest management in their schools. For this reason, the District Cabinet adopts this integrated pest management plan for use on the campuses of our district.

II. WHAT IS INTEGRATED PEST MANAGEMENT?

Integrated Pest Management, also known as IPM, is a process for achieving long-term, environmentally sound pest suppression through a wide variety of tactics. Control strategies in an IPM program include structural and procedural improvements to reduce the food, water, shelter, and access used by pests. Since IPM focuses on remediation of the fundamental reasons why pests are here, pesticides are rarely used and only when necessary.

IPM Basics

  • Education and Communication: The foundation for an effective IPM program is education and communication. We need to know what conditions can cause pest problems, why and how to monitor for pests, proper identification, pest behavior and biology before we can begin to manage pests effectively. Communication about pest issues is essential. A protocol for reporting pests or pest-conducive conditions and a record of what action was taken is the most important part of an effective IPM program.
  • Cultural & Sanitation: Knowing how human behavior encourages pests helps you prevent them from becoming a problem. Small changes in cultural or sanitation practices can have significant effects on reducing pest populations. Cleaning under kitchen serving counters, reducing clutter in classrooms, putting dumpsters further from kitchen door/loading dock, proper irrigation scheduling, and over-seeding of turf areas are all examples of cultural and sanitation practices that can be employed to reduce pests.
  • Physical & Mechanical: Rodent traps, sticky monitoring traps for insects, door sweeps on external doors, sealing holes under sinks, proper drainage and mulching of landscapes, and keeping vegetation at least 24 inches from buildings are all examples of physical and mechanical control.
  • Pesticides: IPM focuses on remediation of the fundamental reasons why pests are here; pesticides should be rarely used and only when necessary.

III. WHAT IS AN INTEGRATED PEST MANAGEMENT PLAN?

ORS 634.700 defines an IPM plan as a proactive strategy that:

  • Focuses on the long-term prevention or suppression of pest problems through economically sound measures that:
    • Protect the health and safety of students, staff and faculty;
    • Protect the integrity of campus buildings and grounds;
    • Maintain a productive learning environment; and
    • Protect local ecosystem health;
  • Focuses on the prevention of pest problems by working to reduce or eliminate conditions of property construction, operation and maintenance that promote or allow for the establishment, feeding, breeding and proliferation of pest populations or other conditions that are conducive to pests or that create harborage for pests;
  • Incorporates the use of sanitation, structural remediation or habitat manipulation or of mechanical, biological and chemical pest control measures that present a reduced risk or have a low impact and, for the purpose of mitigating a declared pest emergency, the application of pesticides that are not low-impact pesticides;
  • Includes regular monitoring and inspections to detect pests, pest damage and unsanctioned pesticide usage;
  • Evaluates the need for pest control by identifying acceptable pest population density levels;
  • Monitors and evaluates the effectiveness of pest control measures;
  • Excludes the application of pesticides on a routine schedule for purely preventive purposes, other than applications of pesticides designed to attract or be consumed by pests;
  • Excludes the application of pesticides for purely aesthetic purposes;
  • Includes school staff education about sanitation, monitoring and inspection and about pest control measures;
  • Gives preference to the use of nonchemical pest control measures;
  • Allows the use of low-impact pesticides if nonchemical pest control measures are ineffective; and
  • Allows the application of a pesticide that is not a low-impact pesticide only to mitigate a declared pest emergency or if the application is by, or at the direction or order of, a public health official.

The above definition is the basis for the District’s IPM plan. This plan fleshes out the required strategy from ORS 634.700 – 634.750 for the District.

Note: As mentioned above, ORS 634.700 allows for the routine application of pesticides designed to be consumed by pests. To avoid a proliferation of pests and/or unnecessary applications of pesticides, we will not set out any ant or cockroach baits until first:

  1. Informing staff in the area where the pests are that sanitation and exclusion are the primary means to control the pest.
  2. Establishing an acceptable pest population density
  3. Cleaning up any food debris in the area.
  4. Sealing up any cracks or crevices where we know the pests are coming from.
  5. Setting out sticky insect monitoring traps in the area using the sticky insect monitoring trap protocol.

IV. SCHOOL DISTRICT IPM PLAN COORDINATOR

The District Cabinet designates the district’s Facilities Manager as the IPM Plan Coordinator. The Coordinator is key to successful IPM implementation in the District, and is given the authority for overall implementation and evaluation of this plan. The Coordinator is responsible for:

  • Attending not less than six hours of IPM training each year
    The training will include a general review of IPM principles and the requirements of ORS 634.700 – 634.750. It will also include hands-on training on updated exclusion practices, monitoring & inspection techniques, and management strategies for common pests.
    Note: ORS 634.720 requires IPM plan coordinators to complete six hours of training each year. Contact your property and liability insurance provider, your Education Service District, or the OSU School IPM Program for information on IPM coordinator training courses that cover the above.
  • Conducting outreach to the school community (custodians, maintenance, construction, grounds, faculty, and kitchen staff) about the school’s IPM plan;
    The IPM Coordinator (or designee) will provide training as outlined in Section V below.
  • Overseeing pest prevention efforts;
    The Coordinator will work with administration, custodian/maintenance, teachers and staff to reduce clutter and food in the classrooms, and seal up pest entry points.
  • Assuring that the decision-making process for implementing IPM in the district (section VI) is followed;
    The Coordinator will continually assess and improve the pest monitoring/reporting/action protocol.
  • Assuring that all notification, posting, and record-keeping requirements in section VII are met when the decision to make a pesticide application is made;
  • Maintaining the approved pesticides list as per section VIII;
  • Responding to inquiries and complaints about noncompliance with the plan;
    Responses to inquiries and complaints will be in writing and kept on record with the Coordinator.
  • Placing and checking sticky insect monitoring traps around facility;
  • Keeping records of pest complaints using pest logs or other documentation located in Facilities office located on the District’s main campus.
  • Developing protocols and provisions for pest avoidance and prevention during construction and renovation projects. The Coordinator will be involved in drafting any bids, and will have the authority to halt construction projects if protocols and provisions for pest avoidance and prevention are not being met.

V. RESPONSIBILITIES + TRAINING/EDUCATION of SCHOOL EMPLOYEES

Note: ORS 634.700 (3) (i) requires staff education “about sanitation, monitoring and inspection and about pest control measures”. All staff should have at least a general review of IPM principles and strategy as outlined in Sections II and III.

  • IPM Plan Coordinator
    • Training (see section IV above)
    • Responsibilities (see section IV above)
  • Custodial / Maintenance Staff
    • Training/Education
      • Custodial – The IPM Plan Coordinator (or a designee of the Coordinator) will train custodial staff at least annually on sanitation, monitoring, inspection, and reporting, and their responsibilities as outlined below.
      • Maintenance – The IPM Plan Coordinator (or a designee of the Coordinator) will train maintenance staff at least annually on identifying pest-conducive conditions and mechanical control methods (such as door sweeps on external doors and sealing holes under sinks), and their responsibilities as outlined below.
    • Responsibilities
      • Attending annual IPM training provided by the IPM Coordinator (or designee).
      • Continually monitoring for pest-conducive conditions during daily work, and sealing small holes and cracks when noticed (if this can be done in a short amount of time)
      • Reporting pest problems and pest-conducive conditions that he/she cannot resolve in a short amount of time to the IPM Coordinator.
      • Reporting teachers to IPM Coordinator who repeatedly refuse to or need assistance to reduce clutter and other pest-conducive conditions in their classrooms.
      • Confiscating – reporting any unapproved pesticides (such as aerosol spray cans) discovered in their regular duties or during an inspection and delivering them – reporting them to the IPM Coordinator.
      • Assisting IPM Coordinator with resolving issues found in annual inspection report.
      • Working with the IPM Coordinator to develop a protocol and priority list with deadlines for sealing holes, installing external door sweeps, and other pest exclusion needs which cannot be done in a short period of time.
  • Grounds Department
    • Training/Education
      The head of grounds staff (or designee) will train grounds staff at least once per year. Each year before the training, the head of grounds staff will meet with the IPM Coordinator to review the annual report of pesticide applications and plan training for all grounds staff. The annual training will review this IPM Plan (especially grounds department responsibilities outlined below) and data from the annual report related to pesticide applications by grounds crew. Grounds staff will also be trained in basic monitoring for common pests on grounds.
    • Responsibilities
      Grounds crews are responsible for:

      • Attending annual IPM training provided by the IPM Coordinator (or designee).
      • Working with the IPM Coordinator to reduce conditions conducive to weeds, gophers, moles, yellow jackets, and other outdoor pests
      • Keeping vegetation (including tree branches and bushes) at least 18 inches from building surfaces.
      • Proper mulching in landscaped areas to reduce weeds.
      • Proper fertilization, over-seeding, mowing height, edging, drainage, aeration, and irrigation scheduling in turf areas to reduce weeds.
      • When the decision is made to apply a pesticide, following notification, posting, record-keeping and reporting protocols in Section VII.
  • Kitchen Staff (as applicable)
    • Training/Education
      The IPM Coordinator (or a designee of the Coordinator) will train kitchen staff at least once per year on the basic principals of IPM and their responsibilities as outlined below.
    • Responsibilities
      Kitchen Staff are responsible for:

      • Attending annual IPM training provided by the IPM Coordinator (or designee).
      • Assuring floor under serving counters and movable equipment is kept free of food and drink debris.
      • Avoiding long-term storage or use of cardboard boxes.
      • Removing recycle products daily.
      • Keeping outside doors closed at all times (except during deliveries and emptying trash).
      • Keeping all food items in sealed containers.
      • Immediately reporting any sightings of rodents or rodent droppings to the IPM Coordinator, and following up with an email to the Coordinator (for records).
      • Reporting to the Coordinator any pest-conducive conditions that require maintenance (e.g., leaky faucets, dumpster too near building, drains need scrubbing, build-up of floor grease requiring spray-washing, etc.)
  • Faculty
    • Training/Education
      The IPM Plan Coordinator (or a designee of the Coordinator) will train faculty and principals at least once per year on the basic principals of IPM and their responsibilities as outlined below. These short (15 – 20 minutes) training are arranged by the Coordinator with individual principals when openings in their school Faculty Meeting schedules permit. During the training, the Coordinator will review the following with Faculty:

      • What pest-conducive conditions are (clutter, food debris, moisture, cracks, holes, etc.), and the importance of reporting these in a timely manner.
      • The importance of keeping their classrooms and work areas free of clutter.
      • The importance of having students clean up after themselves when food or drink is consumed in the classroom.
    • Responsibilities
      Faculty are responsible for:

      • Attending annual basic IPM training provided by the IPM Coordinator (or designee).
      • Keeping their classrooms and work areas free of clutter.
      • Making sure students clean up after themselves when food or drink is consumed in the classroom.
      • Reporting pests and pest-conducive conditions to the IPM Coordinator, in-person – by email – by letter. In emergency situations, by phone.Current IPM Coordinator Contact Information:
        Name Rod Bashor
        Email Marsden@clackesd.k12.or.us
        Mailing Address Attn: Facilities Maintenance, 13455 SE 97th Ave., Clackamas, OR 97015
        Phone 503-675-4035
  • School Principal
    • Training/Education
      (Same training/education as Faculty)
    • Responsibilities
      The School Principal is responsible for:

      • Scheduling time for teachers to receive annual training provided by the IPM Coordinator (or designee).
      • Attending annual IPM training for teachers.
      • Assuring that teachers keep their rooms clean and free of clutter in accordance with the IPM Coordinator’s instructions.
      • Assuring that all faculty, administrators, staff, students and parents receive the annual notice (provided by the IPM Coordinator) of potential pesticide products that could be used on school property as per Section VII.
      • Working with the IPM Coordinator to make sure all notifications of pesticide applications reach all faculty, administrators, staff, students and parents through e-mail and the district’s website.
  • Other
      • Training/Education
        Basic training on the principals of IPM and the main points of this IPM Plan should also be provided to school nurses, administrative staff, and the superintendent. If applicable, Coaches who use athletic fields should be given an overview and updates of basic monitoring and IPM practices for turf so they understand key pest problems to look out for and when to report them.
      • Responsibilities
        All other staff are responsible for keep their work areas free of clutter, and reporting pests and pest-conducive conditions to the IPM Coordinator.

VI. IPM PROCESS

A. Monitoring – Reporting – Action Protocol

Monitoring is the most important requirement of ORS 634.700 – 634.750. It is the backbone of the District’s IPM Program. It provides recent and accurate information to make intelligent and effective pest management decisions. It can be defined as the regular and ongoing inspection of areas where pest problems do or might occur. Information gathered from these inspections is always written down.

As much as possible, monitoring should be incorporated into the daily activities of school staff. Staff training on monitoring should include what to look for and how to record and report the information.

  • Monitoring & Reporting – All Staff
    After a brief (15 – 20 minute) training by the IPM Coordinator (or designee) on pests and pest-conducive conditions, staff will be expected to report pests or pest-conducive conditions they observe during the normal course of their daily work. Reporting will be done verbally, by e-mail, using Pest Logs, and/or by written letter to the IPM Coordinator.
  • Monitoring & Reporting – Coordinator and Custodial/Maintenance Staff
    During the normal course of their daily work, the IPM Coordinator and custodial/maintenance staff will monitor structures and building perimeters for:

    • Pest-conducive conditions inside and outside the building (structural deterioration, holes that allow pests to enter, conditions that provide pest harborage).
    • The level of sanitation inside and out (waste disposal procedures, level of cleanliness inside and out, conditions that supply food and water to pests)
    • The amount of pest damage and the number and location of pest signs (rodenT droppings, termite shelter tubes, cockroaches caught in sticky traps, etc.)
    • Human behaviors that affect the pests (food preparation procedures, concessions procedures, classroom food, etc.)
    • Their own management activities (caulking/sealing, cleaning, setting out traps, treating pests, etc.) and their effects on the pest population.
    • Any pests or pest-conducive conditions will be reported to the IPM Coordinator either orally, or by e-mail, using Pest Logs, or written letter to the Coordinator.
  • Monitoring & Reporting – Grounds Staff
    During normal daily activities, grounds staff will monitor for invasive weeds, gophers, moles, yellow jackets, and other outdoor pests. These will be reported to the IPM Coordinator orally, or by e-mail, using Pest Logs, or written letter to the Coordinator.
  • Sticky monitoring traps for insects
    Sticky traps are neither a substitute for pesticides nor an alternative for reducing pest populations, but rather a diagnostic tool to aid in identifying a pest’s presence, their reproductive stage, the likely direction pests are coming from, and the number of pests.All staff will be made aware of the traps and their purpose so they don’t disturb them. The IPM Coordinator and/or contracted Custodial/maintenance staff will be responsible for setting them out and checking them once per month, and replacing them once every four months.Sticky monitoring traps will be placed in the kitchen and any other “pest-vulnerable areas” the Coordinator deems necessary.Kitchen sticky insect traps will be checked monthly (primarily for drain flies, ants, and cockroaches).
  • Monitoring for Mice
    In addition to monitoring for signs of mice (droppings, gnawing, hair, etc.), snap traps will be placed in the kitchen (and any other area the IPM Coordinator deems necessary), and checked monthly by the Coordinator.
  • Reporting (pests, signs of pests, and conducive conditions)
    When staff observe pests or pest-conducive conditions they should contact the IPM Coordinator.
  • Reporting “Pests of Concern”
    “A pest of concern” is a pest determined to be a public health risk or a significant nuisance pest. These include cockroaches (disease vectors, asthma triggers), mice & rats (disease vectors, asthma triggers), yellow jackets (sting can cause anaphylactic shock), cornered nutria, raccoons, cats, dogs, opossums, skunks (they can bite), and bed bugs (significant nuisance pest).When pests of concern (or their droppings, nests, etc.) are observed, staff should contact the IPM Plan Coordinator immediately.
  • Action!
    • Structural
      Any items (such as sealing up holes) that custodial/maintenance staff observe that they can resolve should be taken care of and reported to IPM Coordinator. The Coordinator will keep records of these actions using appropriate documentation stored in the facilities office.If the actions needed are not something that can be accomplished alone with minimal time, the Coordinator will meet with them to develop a plan of action with a proposed deadline for completion based on the severity of the risk or nuisance.The Coordinator will inform Cabinet of actions being taken/work performed, and monitor the completion of all work. The Coordinator will keep records of actions taken/work performed using proper documentation.The Coordinator will keep records of time and money spent to manage pests.
    • Grounds
      When pests on grounds reach a threshold established by the IPM Coordinator, action will be taken as per guidelines developed by the Coordinator and Grounds Crew. The Grounds Crew or Coordinator will keep records of actions, time, and money spent to manage pests on grounds.
  • Acceptable Thresholds
    A threshold is the number of pests that can be tolerated before taking action. The acceptable threshold for cockroaches, mice, rats, raccoons, cats, dogs, opossums, skunks, and nutria is zero.Acceptable thresholds for other pests will be determined by the IPM Coordinator and the Clackamas ESD Chief Financial Officer.

B. Inspections

The IPM Plan Coordinator will conduct an annual inspection using the annual IPM inspection form. During the inspection he or she will also inspect or review:

      • Human behaviors that affect the pests (working conditions that encourage or support pests, food preparation procedures that provide food for pests, etc.)
      • Management activities (caulking/sealing, cleaning, setting out traps, treating pests, etc.) and their effects on the pest population.

C. Pest Emergencies (see also Section VII. B. below)

IMPORTANT: If a pest emergency is declared, the area must be evacuated and cordoned off before taking any other steps. When the IPM Plan Coordinator, after consultation with school faculty and administration, determines that the presence of a pest or pests immediately threatens the health or safety of students, staff, faculty members or members of the public using the campus, or the structural integrity of campus facilities, he or she may declare a pest emergency. Examples include (but are not limited to) yellow jackets swarming in areas frequented by children, a nutria in an area frequented by children, a half a dozen mice or rats running through occupied areas of a school building. The Coordinator will keep records of actions taken using proper documentation.

D. Annual IPM Report (completed by IPM Plan Coordinator)

In January of each year, the IPM Plan Coordinator will provide Cabinet an annual IPM report. The report will include a summary of data gathered from Pest Logs, or e-mails, or Coordinator notes, as well as costs for PMPs and pesticides (including turf and landscape pesticides). Costs for items such as sealants, fixing screens, door sweeps and other items that would not normally be considered part of pest control will not be recorded. Prevention and management steps taken that proved to be ineffective and led to the decision to make a pesticide application will be copied and pasted or incorporated into the annual report of pesticide applications (see section VII. D)

VII. PESTICIDE APPLICATIONS: REQUIRED NOTIFICATION, POSTING, RECORD KEEPING, AND REPORTING

Any pesticide application (this includes weed control products, ant baits, and all professional and over-the-counter products) on school property must be made by a licensed commercial or public pesticide applicator. At the beginning of each school year, all faculty, administrators, staff, adult students and parents will be given a list of potential pesticide products that could be used in the event that other pest management measures are ineffective. They will also be informed of the procedures for notification and posting of individual applications, including those for pest emergencies. This information will be provided to all the above via e-mail to staff and parents (as applicable).

A. Notification and Posting for Non-emergencies

When prevention or management of pests through other measures proves to be ineffective, the use of a low-risk pesticide is permissible. Documentation of these measures is a pre-requisite to the approval of any application of a low-risk pesticide. This documentation will remain on file with the IPM Plan Coordinator.

Non-emergency pesticide applications may occur in or around a school at any time school is in session, unless the IPM Plan Coordinator authorizes an exception. If the labeling of a pesticide product specifies a reentry time, a pesticide may not be applied to an area of campus where the school expects students to be present before expiration of that reentry time. If the labeling does not specify a reentry time, a pesticide may not be applied to an area of a campus where the school expects students to be present before expiration of a reentry time that the IPM Plan Coordinator determines to be appropriate based on the times at which students would normally be expected to be in the area, area ventilation and whether the area will be cleaned before students are present.

The IPM Plan Coordinator (or a designee of the Coordinator) will give written notice of a proposed pesticide application (via email) at least 24 hours before the application occurs.

The notice must identify the name, trademark or type of pesticide product, the EPA registration number of the product, the expected area of the application, the expected date of application and the reason for the application.

The IPM Plan Coordinator (or a designee of the Coordinator) shall place warning signs around pesticide application areas beginning no later than 24 hours before the application occurs and ending no earlier than 72 hours after the application occurs.

A warning sign must bear the words “Warning: pesticide-treated area”, and give the expected or actual date and time for the application, the expected or actual reentry time, and provide the telephone number of a contact person (the person who is to make the application and/or the IPM Plan Coordinator).

B. Notification and Posting for Emergencies

Important Notes:

  • The IPM Plan Coordinator may not declare the existence of a pest emergency until after consultation with school faculty and administration.
  • If a pesticide is applied at a campus due to a pest emergency, the Coordinator shall review the IPM plan to determine whether modification of the plan might prevent future pest emergencies, and provide a written report of such to Cabinet.
  • Cabinet shall review and take formal action on any recommendations in the report.

The declaration of the existence of a pest emergency is the only time a non-low-impact pesticide may be applied.

If a pest emergency is declared, the area must be evacuated and cordoned off before taking any other steps.

If a pest emergency makes it impracticable to give a pesticide application notice no later than 24 hours before the pesticide application occurs, the IPM Plan Coordinator shall send the notice no later than 24 hours after the application occurs.

The Coordinator or designee shall place notification signs around the area as soon as practicable but no later than at the time the application occurs.

Note: ORS 634.700 also allows the application of a non-low-impact pesticide “by, or at the direction or order of, a public health official”. If this occurs, every effort must be made to comply with notification and posting requirements above.

C. Record Keeping of Pesticide Applications

The IPM Plan Coordinator or designee shall keep a copy of the following pesticide product information on file in the facilities office:

  • A copy of the label
  • A copy of the MSDS
  • The brand name and USEPA registration number of the product
  • The approximate amount and concentration of product applied
  • The location of the application
  • The pest condition that prompted the application
  • The type of application and whether the application proved effective
  • The pesticide applicator’s license numbers and pesticide trainee or certificate numbers of the person applying the pesticide
  • The name(s) of the person(s) applying the pesticide
  • The dates on which notices of the application were given
  • The dates and times for the placement and removal of warning signs
  • Copies of all required notices given, including the dates the IPM Plan Coordinator gave the notices

The above records must be kept on file in the facilities office for at least four years following the application date.

D. Annual Report of Pesticide Applications

In January of each year, the IPM Plan Coordinator will provide Cabinet an annual report of all pesticide applications made the previous year. The report will contain the following for each application:

  • The brand name and USEPA registration number of the product applied
  • The approximate amount and concentration of product applied
  • The location of the application
  • The prevention or management steps taken that proved to be ineffective and led to the decision to make a pesticide application
  • The type of application and whether the application proved effective

VIII. APPROVED LIST OF LOW-IMPACT PESTICIDES

Note: All pesticides used must be used in strict accordance with label instructions.

According to ORS 634.705 (5), the governing body of a school district shall adopt a list of low-impact pesticides for use with their integrated pest management plan. The governing body may include any product on the list except products that:

  • Contain a pesticide product or active ingredient that has the signal words “warning” or “danger” on the label;
  • Contain a pesticide product classified as a human carcinogen or probable human carcinogen under the United States Environmental Protection Agency 1986 Guidelines for Carcinogen Risk Assessment; or
  • Contain a pesticide product classified as carcinogenic to humans or likely to be carcinogenic to humans under the United States Environmental Protection Agency 2003 Draft Final Guidelines for Carcinogen Risk Assessment.

As a part of pesticide registration under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) and re-registration required by the Food Quality Protection Act (FQPA), EPA Office of Pesticide Programs (OPP) classifies pesticide active ingredients (a.i.) with regards to their potential to cause cancer in humans. Depending on when a pesticide active ingredient was last evaluated the classification system used may differ as described above.

The National Pesticide Information Center (http://npic.orst.edu/) can be contacted at 1.800.858.7378 or npic@ace.orst.edu for assistance in determining a pesticide a.i. cancer classification.