1. What is a pesticide?
Pesticides are substances used
to control living organisms - this term includes a wide range
of substances such as insecticides, herbicides, disinfectants,
and rodent baits, among other things. The legal definition
from the state regulations at N.J.A.C. 7:30-1 is the following:
"'Pesticide' means and includes any substance or mixture
of substances labeled, designed or intended for use in preventing,
destroying, repelling or mitigating any pest, or any substance
or mixture of substances labeled, designed, or intended for
use as a defoliant, desiccant, or plant regulator; provided,
that the term 'pesticide' shall not include any substance
or mixture of substances which the US EPA does not consider
to be a pesticide."
2. What is Integrated Pest
Management (IPM)?
IPM is a thoughtful, holistic
approach to controlling pests that uses a wide variety of
tools such as sanitation, structural modifications and other
management techniques rather than automatically turning to
chemical control as a first option. Pesticide use is an important
tool in the pest control "toolbox" but often an
effective IPM program can reduce the reliance on chemical
control. The legal definition for IPM from the state regulations
at N.J.A.C. 7:30-1 is the following: "'Integrated pest
management' or 'IPM' means a sustainable approach to managing
pests by using all appropriate technology and management practices
in a way that minimizes health, environmental and economic
risks. IPM includes, but is not limited to, monitoring pest
populations, consumer education, and when needed cultivation
practices, sanitation, solid waste management, structural
maintenance, physical, mechanical, biological and chemical
controls."
3. What does the School IPM
Act require, in general terms?
Schools will be responsible for
naming an "IPM coordinator" who will oversee the
IPM and pest control activities at the school, retain recorded
information about pest control at the school, and act as a
contact for inquiries from students, staff, and parents. Additional
responsibilities of the school include an annual notice to
parents and staff that describes the IPM program, specific
written notice and posting when pesticides are used, restrictions
on when pesticide can be applied, and re-entry times for pesticide
treated areas. The law requires schools to begin implementing
an IPM Policy by June 12, 2004. A Model
IPM Policy required by the law to be developed by the
DEP is available for use by schools.
4. Why require IPM in schools?
Pests can present risks to property
and health; chemical control methods present an additional
type of risk, particularly to children who are more vulnerable
than adults to the effects of pesticide exposure. The goal
behind the law is reduction of potential risk to school-children
(and staff) from pesticide use through a careful approach
to pest control that seeks to minimize pesticide use, and
through the use of lower risk pesticides when pesticides are
needed.
5. Do all schools have to
comply with school IPM requirements?
Public, private and charter schools
with grades pre-kindergarten through 12 must comply. Not covered
by the law are colleges, universities, or day care centers
(unless the day care center is on a school property). As a
point of clarification and separate from School IPM requirements,
colleges, universities, and day care centers (and the licensed
commercial pesticide applicators they employ) must comply
with other requirements for licensing, proper pesticide use,
notification, etc.
6. Who specifically is responsible
for complying with school IPM requirements?
Public school boards, trustees
of charter schools, and principals or lead administrators
of private schools are responsible for complying. The individual
named by the school as the IPM coordinator has joint responsibility
for many of the requirements as well.
7. Can pesticides be used
at schools?
Yes, pesticides can be used at
schools. A number of regulatory controls are in place such
as licensing, notification, and re-entry restrictions for
treated areas- requirements that to date have been the responsibility
of the licensed commercial pesticide applicator performing
pest control at the school. The School
IPM Act places additional responsibilities on public,
private and charter schools in New Jersey that will be explained
further in these FAQ's and in training materials distributed
to schools.
8. What is the difference
between an IPM Policy and an IPM Plan?
The IPM Policy is the overview
or synopsis of the required elements for practicing IPM in
schools. The IPM Plan is a more detailed and site-specific
document that describes exactly how each component of the
Policy will be carried out.
9. Who is allowed to apply
pesticides at schools?
Licensed commercial pesticide
applicators or persons working under their supervision (known
as "operators") are generally the only people who
can apply pesticides on school grounds (indoors or outdoors).
There are certain exemptions from the licensing requirements
for use of "over-the-counter" disinfectants and
antimicrobials such as Lysol® and toilet-bowl cleaner,
and for use of exempted compounds termed "minimum risk" pesticides published by the federal EPA.
10. Can teachers or custodial
and other staff use products like Raid® or weed-killer
on school grounds?
No, not without being properly
licensed as a commercial pesticide applicator or operator.
11. When will DEP adopt regulations
to formalize requirements of the School IPM Act?
The DEP expects to propose rules
in May 2004, and adopt these rules in the fall of 2004. Please
monitor the Pesticide Control
Program website for details and the posting of the rule
proposal. The purpose of the rules will be to implement the
intent of the law. Since the language in the law was very
prescriptive and detailed, much of the wording has been taken
"as is" from the law and put into the rules. Additional
requirements for training school IPM coordinators and commercial
pesticide applicators will appear in the rule proposal. Adoption
of the rules allows DEP to enforce the requirements for IPM
Policies in schools.
12. Why is June 12, 2004 important
if there are no final rules by then?
The law requires schools to implement
an IPM Policy within 18 months of law being enacted. This
18-month deadline falls on June 12, 2004. Compliance assistance,
model IPM Policies and Plans and "how-to-comply"
materials are being offered to help schools comply by that
deadline.
13. Once rules are adopted,
how will they be enforced?
DEP inspectors as well as county
health inspectors from certain counties with delegated authority
from DEP will enforce rules on IPM in schools, typically through
routine inspections or in response to a complaint of non-compliance.
14. Are there penalties for
not complying?
The law specifies that no monetary
penalties may be issued for failing to implement IPM requirements
in a school. However, DEP or county inspectors may issue a
Notice of Violation or Administrative Order to a school for
failure to comply.
FAQs FOR SCHOOL COMPLIANCE
1. Who should be the IPM coordinator
for the school?
The decision regarding who will
serve as the IPM Coordinator ultimately rests with the public
school board, trustees for a charter school, or the principal
or lead administrator of a private school. The IPM Coordinator
should be someone who is familiar with the school buildings
and grounds, such as the supervisor of buildings and grounds
or janitorial services. It may also be a teacher or other
school staff member. The IPM Act does not intend for the IPM
Coordinator and the pesticide applicator servicing the school
to be one in the same; however, there is nothing in the statute
that prohibits the school from employing an outside pesticide
contractor or consultant in this capacity.
2. Who is responsible for
naming the IPM coordinator?
The school board of a local school
district, the board of trustees of a charter school, and the
principal or lead administrator of a private school are responsible
for naming the IPM coordinator.
3. What is the IPM coordinator
specifically responsible for?
The IPM coordinator is responsible
for carrying out the IPM Policy and Plan at the school. In
addition, the coordinator is responsible for maintaining information
about IPM activities at the school, copies of the Policy and
Plan, records of pesticide application on school property
and other records such as pest monitoring results, Material
Safety Data Sheets (MSDS) when available for pesticides used,
and labels for pesticides used on school property. In addition,
the coordinator will be responsible for notification regarding
the Policy and pesticide use, and act as the contact for inquiries
from students, staff and parents on any aspect of IPM activities
and pest control at the school. Public school boards, trustees
for charter schools, and principals or lead administrators
of private schools are jointly responsible with the coordinator
for complying with these requirements.
4. Can there be more than
one IPM coordinator for a school district?
The law does not prohibit a school
from naming more than one coordinator. In a school district
with many schools and school-owned sites, it may be preferable
to have more than one coordinator. It must be clear, however,
which sites or schools are under each coordinator's responsibility.
If one coordinator is named for many schools, then "assistants"
may be needed at each school to relay important information
and site specific needs back to the coordinator. The coordinator
named for a school or schools (not "assistants")
will be ultimately responsible for complying with the requirements.
5. Does the IPM coordinator
need training?
The DEP anticipates proposing
rules that would require the coordinator to receive DEP-approved
training that provides an overview of the principles of IPM,
legal requirements, and how to implement the IPM Policy and
Plan at the school. Once rules are adopted (approximately
by the Fall of 2004) DEP will begin to record and track New
Jersey schools and coordinators who have received training.
6. How does the IPM coordinator
obtain training?
There will be several different
options for training, all based on the "How-to-Comply"
manual posted on the web site. This material may be incorporated
into training programs that presently exist for buildings
and grounds personnel. Also, training can be obtained at a
number of sessions that will be offered to IPM coordinators.
For those unable to attend a training session, using the on-line
manual and a "self-test" will be another option
offered once rules are adopted.
7. When should annual notification
be done?
The annual notice that must be
sent to parents or guardians, and all staff members, should
be sent at the beginning of each school year as part of school
handbooks or calendars. Once the annual notice has been sent,
it must be also given to new staff or the parents/guardians
of new students who arrive after the annual notice has been
sent.
8. When does the notice for
specific pesticide applications need to be given?
At least 72 hours in advance
of an application of a pesticide other than a low impact pesticide. A notice must be sent to all parents/guardians
of students and staff members.
9. Does a sign have to be
physically posted on school property as well?
Yes, signs need to be posted
in a prominent location near the pesticide application, and
also at the entrances to the building or grounds where the
application takes place. The signs must be posted at least
72 hours in advance and remain posted for at least 72 hours
after the application.
10. The notification and posted
signs require the pesticide "trade name", "common
chemical name", and "EPA Registration number"
as part of the notice- where does the school get this?
The commercial applicator must
provide notification information to the school prior to any
pesticide application. This information will contain, among
other things, the trade name and common chemical name (if
there is one) of the pesticide proposed for use. The applicator
also has EPA Registration numbers for all pesticides applied,
and will provide these as well as pesticide labels, upon request.
11. What information must
the IPM coordinator keep and make available to students, staff,
and parents or guardians?
The coordinator must keep and
make available for review several things: pesticide application
records (obtained from the pesticide applicator), the labels
for each pesticide used, and the Material Safety Data Sheet
(MSDS) if available, for each pesticide used. The IPM coordinator
must also be the contact for inquiries and be available to
answer questions about the IPM program in the school.
12. Other school district
or municipal athletic teams use the athletic fields and gymnasiums
for events- does the school have to provide a notice to staff
or parents of these athletes when pesticides are used?
No, this is not mandatory and
would often prove to be logistically impossible to provide.
The staff or team members may ask for information from the
IPM coordinator in which case it should be provided. Other
forms of pesticide notification requirements currently in
state regulations are available for visiting teams such as
warning flags for turf areas. Additionally, under current
regulations, any individual visiting staff or team member,
and any parent or guardian may request notification information
about a specific pesticide application directly from the commercial
pesticide applicator that services the school.
13. What is the role of the
licensed commercial pesticide applicator in school IPM?
The commercial pesticide applicator
that provides pest control services for the school (both for
indoor pests as well as outdoor) must be a working partner
with the school and IPM coordinator. While responsibility
for carrying out IPM rests with the school, the pesticide
applicator must have familiarity with the principles and practices
of IPM, and provide pesticide application records to the school
to help it effectively carry out its IPM mission. An anticipated
component of new state pesticide rules being proposed is an
additional licensing requirement for IPM education for those
pesticide applicators operating on school grounds. This will
standardize the working knowledge pesticide applicators must
have when providing pest control for schools.
FAQs FOR COMMERCIAL PESTICIDE APPLICATORS
1. What kind of license is
required for pesticide use at schools?
A commercial pesticide applicator
or operator license is required for pesticide use on school
property. Rules are being proposed that would require an additional
category ("IPM in Schools") for commercial applicators
that apply pesticides on school property. If these rules are
adopted as final, applicators would be given a grace period
during which the new category exam would need to be taken.
This IPM in Schools category would be required in addition
to any other category (such as ornamental & turf, or termite
control) required depending on the type of work performed.
2. What is the role of the
licensed commercial pesticide applicator in school IPM?
The commercial pesticide applicator
that provides pest control services for the school (both for
indoor pests as well as outdoor) must be a working partner
with the school and IPM coordinator. While responsibility
for carrying out IPM rests with the school, the pesticide
applicator must have familiarity with the principles and practices
of IPM, and provide pesticide application records to the school
to help it effectively carry out its IPM mission.
3. Does the notification performed
by the school affect existing notification requirements that
the pesticide applicator must perform when applying pesticides
on school property?
No, existing regulations that
require consumer notification to the school before any applications,
central posting of application information, flags in turf
areas, and notification to individuals upon request (see N.J.A.C.
7:30-9.12(d), 9.13(e) and 9.15 for specifics) remain unchanged.
4. Is it mandatory for a pesticide
applicator to obtain a form signed by the school IPM Coordinator
stating that the school has done the required notification
and posting?
No, it is not mandatory. This
form is designed to give the pesticide applicator confidence
that the school has met its notification obligations under
the law before the applicator proceeds with the pesticide
application. Although it is not mandatory, if the pesticide
applicator requests this form to be signed, the IPM Coordinator
must sign it in order for the pesticide application to take
place. Note that the school's obligation for notices to parents
and staff, and posting of signs only applies when a pesticide
other than a low impact pesticide is used.
5. What should pesticide applicators
do if they know that the school has not done proper notice
when a pesticide application is about to begin?
The application should be rescheduled
to allow the school to give proper notice and post signs 72
hours in advance. If it is an "emergency" application
as defined by the law, then the school can post signs right
at the start of the application, and send notices to parents
and staff within 24 hours or by the next school morning, whichever
is earlier.
6. If a utility company or
state DOT uses pesticides on rights-of-way on school property,
does notification and posting apply?
Yes, the law specifically states
that notification and posting are to be done whenever a non
low-impact pesticide is used on school property. The utility
company or DOT must provide information to the school in order
that the school may fulfill notification and posting requirements
72 hours in advance.
FAQs - WHEN PESTICIDES ARE USED AT SCHOOLS
1. What is a "low impact"
pesticide?
A low impact pesticide is a pesticide that is considered
to have relatively minimal risk as compared to pesticides
in general. The School IPM law defines what a low impact pesticide
is in two parts. The first part consists of a federal EPA
list of pesticides that it considers to be minimal risk and
thus do not require formal registration. These pesticides
are listed in the federal code at 40 CFR § 152.25. The
second part consists of a list of pesticide ingredients (such
as boric acid or diatomaceous earth) and formulation types
(such as gels or pastes) that are considered low impact. It
is important to note that a substance considered "low
impact" does not necessarily mean zero risk. The How-to-Comply
manual has a more detailed discussion of low impact pesticides.
All pesticides must be used properly to reduce potential risk
from their use.
2. Why do schools have to
consider these low impact pesticides?
The law and resulting model policy
published by DEP make it clear that when pesticide use is
needed, preference should be given to choosing a low impact
pesticide, if possible. This is not meant to take away any
flexibility the school or pesticide applicator need to respond
to pest problems. It is meant to foster a decision making
process that may reduce risk by considering the least hazardous
(when used properly), yet effective pest control solution.
3. Is there a list of low
impact pesticides, and how do I obtain a copy?
There is no list, exactly. But
some of these pesticides can be listed because they are categorized
by the name of the chemical. Others, though, are a type of
formulation (bait, gel, or paste) thus they are not associated
with any one chemical ingredient. Please see the more detailed
explanation of low impact pesticides in the "How-to-Comply"
manual for schools and on the low
impact pesticide page.
4. When does the school need
to give notice for specific pesticide applications?
At least 72 hours in advance
of an application of a pesticide other than a "low-impact"
pesticide, the school must send a notice to all parents/guardians
of students, and staff members.
5. Does a school have to
do 72-hour notice to parents and staff, and post signs, when
using a low impact pesticide?
No, using a pesticide classified
as low impact does not require the school to send notices
to parents and staff or posting of signs at the entrances
to the school as required by the School IPM Act. However,
when a pesticide applicator uses any pesticide registered
with the federal EPA (even though some may be considered low
impact, such as pesticide gels, baits, etc.) then current
state rules still require certain notification that is the
responsibility of the pesticide applicator. For example "Premise®
Gel Insecticide" (EPA Registration # 3125-544) is an
insecticide that qualifies as low impact under the School
IPM Act since it is a "gel" formulation. Thus, the
school is not required to send notices to parents and staff,
or post signs. However, this is a regulated pesticide that
has been registered by the federal EPA. This means that the
pesticide applicator still needs to do certain notification
to the school and posting on a central bulletin board (see
N.J.A.C. 7:30-9.12(d), 9.13(e) and 9.15 for specifics).
6. What constitutes an "emergency"
pesticide application, and what notification must be done?
A "school pest emergency"
is defined in the law as "
an urgent need to mitigate
or eliminate a pest that threatens the health or safety of
a student or staff member." One example would be the
presence of stinging insects such as ground hornets in an
athletic field where events are scheduled. If a pest emergency
exists, the school may use pesticides without the normal 72-hour
notice to parents and staff, and the posting of signs 72 hours
prior to the application. Rather, the posting must be done
at the time of the application, and the notice to parents
and staff must be done within 24 hours after the emergency
application. The notice that goes to parents and staff must
explain what the reason for the emergency was, and if possible,
what could be done to prevent such an emergency use next time.
7. How long must students
wait to re-enter an area treated with pesticides?
Students cannot enter a pesticide
treated area for at least seven hours after the application
of a non low impact pesticide, unless the pesticide label
states a specific numerical re-entry time that is different
than this. The use of low impact pesticides does not require
an automatic seven-hour wait. Students can generally re-enter
after the pesticide application has dried or settled, but
may have to wait longer if the pesticide label specifies a
longer time period.
8. Can a non low impact pesticide
be applied in a school building as long as students are in
another area of the building?
Yes, but only if the area being
treated with the pesticide is served by a different air handling
system and is separated from the students by smoke or fire
doors.
9. Can pesticides be applied
for student instructional purposes?
Yes, pesticides can be applied
for student instructional purposes (such as for horticultural
class), and of course all pesticide label precautions and
instructions (including re-entry) must be followed. Staff
applying pesticides must be licensed appropriately by the
DEP. The law exempts student instructional use from the generic
7-hour re-entry time, and does not require other students
to be in an area of the building on a different ventilation
system, or separated by smoke or fire doors. However, pesticide
use for instructional purposes does trigger the need for 72
hour notice to parents and the posting of signs 72 hours in
advance (unless it is a low impact pesticide as defined in
the law).
10. Can health inspectors
apply pesticides (such as "flushing agents" used
to detect pests) during the course of their inspection?
Yes, health inspectors can apply
pesticides during the normal course of their duties. Of course
all pesticide label precautions and instructions (including
re-entry) must be followed. Health inspectors applying general
use or "over-the-counter" pesticides are exempt
from licensing by the DEP. The School IPM Law exempts health
inspector pesticide use from the generic 7-hour re-entry time,
and does not require students to be in an area of the building
on a different ventilation system, or separated by smoke or
fire doors. However, pesticide use for health inspection purposes
does trigger the need for 72 hour notice to parents and the
posting of signs 72 hours in advance (unless it is a low impact
pesticide as defined in the law).
FAQs FOR RIGHT-OF-WAY AND MOSQUITO CONTROL
PESTICIDE APPLICATION ON SCHOOL PROPERTY
Download Right-of-Way/Mosquito policy (pdf file)
1. Question: What is a school?
For the purposes of the School
IPM Act, a school is any educational facility, public, private
or charter, devoted to children grades pre-kindergarten through
grade 12. "Early learning centers" serving pre-kindergarten
children are considered schools. Day-care centers are not
considered schools.
2. Question: Do right-of-way
and mosquito control agency pesticide applicators have to
become certified in the new commercial pesticide applicator
license Category 13 for School IPM?
Since the Category 13 exam was
intended for service providers that the school hires, DEP
will exempt power line, roadway and other right-of-way pesticide
applicators as well as mosquito agency personnel from license
Category 13 requirements when using pesticides on school grounds.
This is because Category 13 is designed for pest control service
providers to schools who must have a working partnership with
the school to make school IPM a success. Right-of-way and
mosquito agency applicators are not service providers hired
by schools. However, since the law requires the school to
give notice to parents and staff of applications of non low-impact
pesticides on school property, notification must be provided
by the applicator.
3. Question: What are the
requirements for schools to notify parents and staff of pesticide
applications?
Since the law requires a school
to inform parents and staff of a "non low-impact"
pesticide application on school property, the school must
comply regardless of whom is making the application. This
notice must be given by the school 72 hours in advance of
the pesticide application (certain exceptions apply). There
is also a requirement for the school to post signs with certain
information about the pesticide application. The exception
to the 72-hour requirement is if there is a "school pest
emergency" defined by law as
"an urgent need
to mitigate or eliminate a pest that threatens the health
or safety of a student or staff member", in which case
notice may be given within 24 hours after the application
or the morning of the next school day, whichever is earlier.
4. Question: Are there any
circumstances where notification does not have to be given
by the school to parents and staff?
Yes. One circumstance is when
something called a "low
impact pesticide" is used. Some examples are pesticide
gel, paste, and bait formulations, microbial pesticides such
as bacillus thuringiensis, disinfectants, and any pesticides
listed by the Federal EPA on its "minimum risk"
pesticide list.
Another circumstance is when the pesticide application is
taking place during summer recess or extended holiday such
as spring break, and no students or staff will be using the
school in an authorized manner.
5. Question: What information
must right-of-way and mosquito control pesticide applicators
give to a school so that the school can comply with its own
notification obligations, and when must it be given?
Right-of-way and mosquito control
pesticide applicators must give the school notification more
than 72 hours in advance of a pesticide application in order
that the school can comply with its own 72-hour advance notification
obligation under the law. See exceptions explained in the
answer to # 7 below. The following is the complete list of
what schools must provide to parents and staff at least 72
hours in advance. Right-of-way and mosquito control pesticide
applicators must provide the information in # 1, 2, 3, 6,
and 8 below, the pesticide label, and MSDS sheets for the
pesticide if it is available.
1. The common name, trade name, and Federal
Environmental Protection Agency registration number of
the pesticide;
2. A description of the location of the application of
the pesticide;
3. A description of the date and time of application,
except that, in the case of outdoor pesticide applications,
one notice shall include three dates, in chronological
order, on which the outdoor pesticide applications may
take place if the preceding application date is canceled;
4. A statement that The Office of Pesticide Programs of
the United States Environmental Protection Agency has
stated: "Where possible, persons who potentially
are sensitive, such as pregnant women, infants, and children,
should avoid any unnecessary pesticide exposure";
5. A description of potential adverse effects of the pesticide
based on the material safety data sheet, if available,
for the pesticide;
6. A description of the reasons for the application of
the pesticide;
7. The name and telephone number of the IPM coordinator
for the school or the school district; and
8. Any additional label instruction and precautions related
to public safety.
6. Question: What is the best
strategy for right-of-way and mosquito control agency pesticide
applicators to comply?
Give as much information as
possible up front, before any applications are made. This
will allow the school IPM coordinator to be prepared with
information they must provide to parents and school staff
when a pesticide application happens. Give all pesticide labels
and MSDS sheets for products anticipated to be used, including
both "low-impact" and "non low-impact"
pesticides. This information can be used when the school does
its required annual notice to parents and staff of all pesticides
used on school grounds. Then, as applications of non low impact
pesticides happen, call the contact at the school with the
other information described in # 5 above.
7. Question: Can pesticide applications
take place on school property while the children are in school?
Yes (the following answer is
specifically directed at outdoor applications- there is a
slightly different answer for indoor applications). Low-impact
pesticides can be applied during school hours as long as students
will not contact treated areas until the pesticide has dried
or settled, or the prescribed re-entry time on the pesticide
label (if there is one) has elapsed. For all other pesticides,
they can be applied during school hours in areas that students
are not expected to be for academic instruction or extracurricular
activities prior to the re-entry time on the pesticide label,
or if the label has no specific time in hours for re-entry,
for a minimum of seven hours.
Important Note: DEP has a regulatory requirement to
take "
reasonable precautions, before, during, and
after..." a pesticide application to avoid exposure to
people or the environment. Thus, whether or not an applicator
is allowed to apply to school grounds caution and common sense
should prevail when students are using school property.
8. Question: What are the
exceptions for mosquito control personnel for the timing of
their notification to a school?
It is expected that the nature of mosquito control activities
including larviciding and adulticiding, will not always allow
for notice to schools far enough in advance for the school
to comply with its own 72-hour notice to parents and staff.
For Adulticiding and Larviciding: When possible, notification
must be given to schools more than 72 hours in advance if
a non low-impact pesticide is being used. If this is not possible, the provision in the
School IPM Act that allows for pest control in an "emergency"
will be applicable. The school must give notice to parents
and staff as soon as possible, but no later than 24 hours
after the application, or on the morning of the next school
day, whichever is earlier. The school must also post signs
on school property at the time of application (or as soon
as possible after an application, if an emergency). This means
that mosquito control personnel must notify the school with
the information in Answer #5 in order for the school to post
signs at the time of application, and follow up with the notices
to parents and staff.
9. Question: What must schools do with notification given
to them for right-of-way and mosquito control pesticide applications?
Information about right-of-way
and mosquito control pesticide applications must be included
in the annual notice schools must provide under N.J.A.C. 7:30-13.5.
Mosquito adulticide, larvicide, and right-of-way pesticide
applications using non low-impact pesticides must conform
to the 72-hour notification or emergency notification procedures,
whichever is legally appropriate. These applications will
also trigger the school to post signs at the entrances to
the treated area with the information required in N.J.A.C.
7:30-13.6(e).
10. Question: Does a school
have to ask for notification, or do right-of-way and mosquito
control pesticide applicators have to provide notice without
being asked?