2531.02 Attachment D

Department of Entomology

To: U.S. EPA, Environmental Stewardship Branch, Office of Pesticide Programs Date: November 7, 2019

RE: IPM Award Applications Process

Thank you for permitting me to review your upcoming School IPM Awards process. As someone who was hired from one of the original School IPM grants, I’m excited to see this program move forward. Below is my review of each of the categories with some comments on implementation and time burdens.

For each category the personnel mentioned could be one person or multiple depending on the location and award category. Times will vary based on size of school district as well, there is a huge difference between Houston ISD and Amarillo ISD, as such gathering of information will be different.

I do have reservations regarding the “Model of Sustained Excellence” award category. Do not roll this one out until you have the first three school IPM awards worked out. Speaking from experience from the International IPM Symposium Awards committee and having a state school IPM award program these first three will take time for school districts to warm to and apply. I am also strongly suggesting EPA work within its own Agency and others like USDA NIFA and Cooperative Extension to make this a third-party type audit that would be submitted to headquarters for grading. Adopt an IPM Star, state audit (a way to engage SLAs), narrative type of submission that could garner some really good press.

I hope you find my review adequate enough for submission. Trying to gauge how much time it will take people to compile is difficult, but I tried my best to give you my best estimates. If you should have any questions, please feel free to contact me via email or phone.

Good luck with this program, I hope you can launch in 2020. Best regrds,

Janet A. Hurley, ACE, MPA

Extension Program Specialist III – School IPM Texas A&M AgriLife Extension Service

Texas A&M AgriLife Research & Extension Center

School IPM Program 17360 Coit Road | Dallas, Texas 7552

Tel. 972-952-9213 | schoolipm.tamu.edu | AgriLifeExtension.tamu.edu

Texas A&M AgriLife Extension is an equal opportunity employer and program provider.

Great Start:

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Read instructions	Read Application Guide and application for relevant Tier.	School IPM Coordinator/Facilities Manager	15 minutes
Plan activities	Plan gathering of information that will be submitted to EPA.	School IPM Coordinator/Facilities Manager/Administrative Assistant	30 to 60 minutes
Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	School IPM Coordinator/Facilities Manager/Pesticide Applicator/Administrative Assistant	1 to 3 hours
Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	School IPM Coordinator/Facilities Manager/Administrative Assistant	1 to 3 hours
Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	School IPM Coordinator/Administrative Assistant	1 hour
Store/Maintain data	File and maintain copies of materials submitted to EPA.	School IPM Coordinator/Administrative Assistant	10 minutes

Comments:

Overall this is a fairly easy application for a school district employee to complete. They will need cooperation of the district to submit the application, but the burden of gathering the information needed for this award process is minimal. Depending on the size of the district 1 – 3 campuses or more than 300 campuses will depend on length of time to complete. But overall should be easy to do in less than a week with everyday workload.

Stakeholder Response by: Dawn H. Gouge, University of Arizona

Leadership Award:

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
1. Read instructions	Read Application Guide and application for relevant Tier.	School IPM Coordinator/Facilities Manager	30 to 60 minutes
2. Plan activities	Plan gathering of information that will be submitted to EPA.	School IPM Coordinator/Facilities Manager/Administrative Assistant	1 to 3 hours depending on size of district
3. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	School IPM Coordinator/Facilities Manager/Pesticide Applicator/Administrative Assistant	5 hours per campus
4. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	School IPM Coordinator/Facilities Manager/Administrative Assistant	5 hours
5. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	School IPM Coordinator/Administrative Assistant	3 to 5 hours depending on size of district
6. Store/Maintain data	File and maintain copies of materials submitted to EPA.	School IPM Coordinator/Administrative Assistant	30 minutes

Comments:

Some of the information requested of schools is a burden and needs mentioning here. To focus on the overall IPM program which is what is mentioned in the criteria, ask the District to submit their School Board Approved IPM Policy, along with their written IPM action plans with thresholds, plus the roles of the key players within the program. This will tie in the committee question and get you the documents you need to assess their level of IPM adoption.

Inspections are great but asking this question might not result in the answer you can measure. However, if you ask for them to submit scenarios in which they had a problem and they solved using IPM that can help you see how well they are following IPM.

Trash areas, door sweeps and vegetation questions – this will be considered a burden by some districts.

This is also something you really cannot measure uniformly. A dry, arid climate will have a very different outdoor area, rather than a residential area with lots of tress and people. You can fake this in an application like this. Make the district get letters of support from the school staff – vary that depending on leadership versus excellence.

Something else to consider pesticide usage can also be skewed – schools in the south will have fire ant baits and termites; whereas, northern schools may not.

Excellence:

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Read instructions	Read Application Guide and application for relevant Tier.	School IPM Coordinator/Facilities Manager/School Administrator	30 minutes
Plan activities	Plan gathering of information that will be submitted to EPA.	School IPM Coordinator/Facilities Manager/School Administrator/Risk Manager/Pest Management Professional	2 to 4 hours depending on size of district and if IPM Star or not
Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	School IPM Coordinator/Facilities Manager/Administrative Assistant (s)/School Administrator/Risk Manager/Pest Management Professional/Third Party Auditor (Cooperative Extension)	Less than 5 campuses – 16 hours 5 to 40 campuses – 24 hours 40 to 80 campuses 48 hours
Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	School IPM Coordinator/Facilities Manager/Administrative Assistant (s)/School Administrator/Risk Manager/Pest Management Professional/Third Party Auditor (Cooperative Extension)	5 to 10 hours
Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	School IPM Coordinator Administrative Assistant	2 hours
Store/Maintain data	File and maintain copies of materials submitted to EPA.	School IPM Coordinator Administrative Assistant	30 minutes

Comments:

If the school district has been through IPM Star then this will not be that huge of a burden; however, if they have not gone through IPM Star this is going to be very difficult for EPA to measure. The areas of difficulty that I mentioned in Leadership Award are here as well. For this category I strongly suggest that EPA consider working with the regional offices and cooperative extension to conduct an on-site audit.

As a person who has conducted IPM Star and what you are asking schools to compile this is a multiple day event for someone of my level of expertise, I do not see schools taking this on without support.

Model of Sustained Excellence:

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Read instructions	Read Application Guide and application for relevant Tier.	School IPM Coordinator/Facilities Manager/School Administrator
Plan activities	Plan gathering of information that will be submitted to EPA.	School IPM Coordinator/Facilities Manager/School Administrator/Risk Manager/Pest Management Professional
Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	School IPM Coordinator/Facilities Manager/Administrative Assistant (s)/School Administrator/Risk Manager/Pest Management Professional/Third Party Auditor (Cooperative Extension)
Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	School IPM Coordinator/Facilities Manager/Administrative Assistant (s)/School Administrator/Risk Manager/Pest Management Professional/Third Party Auditor (Cooperative Extension)
Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	School IPM Coordinator Administrative Assistant
Store/Maintain data	File and maintain copies of materials submitted to EPA.	School IPM Coordinator Administrative Assistant

Comments:

For this award giving a time estimate is difficult. As it is currently written this should be an award category that a school system would apply for after receiving the “Excellence” category. Truly for this type of recognition the application should be written so that a third-party auditor like Extension or a Regional IPM Center, or EPA Office could prepare and nominate. If that is the case something like that – hands on approach would take at least 3 days and several days afterwards to complete a packet. But if

done correctly could have a LASTING impact on school IPM. The trouble with IPM Star is schools are reluctant to pay for the audit, since no one thinks what they do is real or important. An award like this that myself, Dawn Gouge, Kathy Murray (Maine), EPA regional folks, northcentral IPM Center or others could conduct and then submit for grading would be really cool. I would be willing to invest time to give schools this type of recognition.

As for the school districts smaller ones less than 30 campuses will have interest, but the bigger the district the less likely they will participate. Keeping up with day to day operations is the best they can do.

Connector:

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Read instructions	Read Application Guide and application for relevant Tier.	Administrator/Extension Professional/Regional IPM Implementor	10 minutes
Plan activities	Plan gathering of information that will be submitted to EPA.	Administrator/Extension Professional/Regional IPM Implementor/Steering Committee	1 hour
Gather information	Canvass / Contact personnel from school districts to gather information for application. Compile measurable data for review and placement into application.	Administrator/Extension Professional/Regional IPM Implementor/Administrative assistant/Program Coordinator	18 hours
Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	Administrator/Extension Professional/Regional IPM Implementor/Administrative assistant/Program Coordinator	18 hours
Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	Administrator/Extension Professional/Regional IPM Implementor/Administrative assistant/Program Coordinator	2 hours
Store/Maintain data	File and maintain copies of materials submitted to EPA.	Administrative assistant	10 minutes

Comments:

I based my estimates on what I would personally submit for this award for the work we have done for AgriLife Extension. This too could vary depending on how you have been keeping data.

Great Start Award

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
1. Read instructions	Read Application Guide and application for relevant Tier.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or Accounts Manager, 2-5.	5 minutes
2. Plan activities	Plan gathering of information that will be submitted to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or Accounts Manager, 2-5.	1 hour
3. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or Accounts Manager, 2-5.	1 hour
4. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or Accounts Manager, 2-5.	30 minutes
5. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, and/or Superintendent, 2-4.	1 hour
6. Store/Maintain data	File and maintain copies of materials submitted to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, or Superintendent, 1.	5 minutes

Leadership Award

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
1. Read instructions	Read Application Guide and application for relevant Tier.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or Accounts Manager, 2-5.	10 minutes
2. Plan activities	Plan gathering of information that will be submitted to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or Accounts Manager, 2-5.	1.5 hours
3. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	IPM Coordinator, Facilities, Manager, 2.	2 hours/school site unless all information and data are centrally stored
4. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	IPM Coordinator, Facilities, Manager, 2.	2 hours
5. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, and/or Superintendent, 2-4.	2 hours depending upon how many campuses are being included
6. Store/Maintain data	File and maintain copies of materials submitted to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, or Superintendent, 1.	5 minutes

Excellence Award

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
1. Read instructions	Read Application Guide and application for relevant Tier.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or Accounts Manager, 2-5.	30 minutes
2. Plan activities	Plan gathering of information that will be submitted to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or Accounts Manager, 2-5.	5 hours
3. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	IPM Coordinator, Facilities, Manager, 2.	2 hours/school site unless all information and data are centrally stored
4. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	IPM Coordinator, Facilities, Manager, 2.	5 hours
5. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, and/or Superintendent, 2-4.	5 hours depending upon how many campuses are being included
6. Store/Maintain data	File and maintain copies of materials submitted to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, or Superintendent, 1.	5 minutes

Model of Sustained Excellence Award

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
7. Read instructions	Read Application Guide and application for relevant Tier.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or Accounts Manager, 2-5.	30 minutes
8. Plan activities	Plan gathering of information that will be submitted to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or Accounts Manager, 2-5.	8 hours
9. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	IPM Coordinator, Facilities, Manager, Risk Manager, and/or Superintendent, 2-4.	8 hours
10. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or IPM/sustainability committee 2-X.	8 hours
11. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or IPM/sustainability committee 2-X.	5 hours
12. Store/Maintain data	File and maintain copies of materials submitted to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, or Superintendent, 1.	5 minutes

Connector Award

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
1. Read instructions	Read Application Guide and application for relevant Tier.	IPM Coordinator, Facilities, Manager, Risk Manager, and/or Superintendent, 2-4.	10 minutes
2. Plan activities	Plan gathering of information that will be submitted to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, and/or Superintendent, 2-4.	1 hour
3. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	IPM Coordinator, Facilities, Manager, Risk Manager, and/or Superintendent, 2-4.	8 hours
4. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or IPM/sustainability committee 2-X.	8 hours
5. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, Superintendent, and/or IPM/sustainability committee 2-X.	5 hours
6. Store/Maintain data	File and maintain copies of materials submitted to EPA.	IPM Coordinator, Facilities, Manager, Risk Manager, or Superintendent, 1.	5 minutes

Presented by Dr. John A. Bailey, Chesapeake Public Schools

All calculations of time were based on the staff and resources I have available in my school division.

Scroll down for all 5 tiers.

Tier 1 Great Start Award Application

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
1. Read instructions	Read Application Guide and application for relevant Tier.	School Plants Administrator	5 minutes
2. Plan activities	Plan gathering of information that will be submitted to EPA.	School Plants Administrator	15 minutes
3. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	School Plants Administrator Most data stored electronically for easy retrieval	30 minutes
4. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	School Plants Administrator	30 minutes
5. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	School Plants Administrator	30 minutes
6. Store/Maintain data	File and maintain copies of materials submitted to EPA.	School Plants Administrator	10 minutes

Tier 2: Leadership Award

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
7. Read instructions	Read Application Guide and application for relevant Tier.	School Plants Administrator	30 minutes
8. Plan activities	Plan gathering of information that will be submitted to EPA.	School Plants Administrator	1 hour
9. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	School Plants Administrator	3 hours
10. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	School Plants Administrator	3 hours
11. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	School Plants Administrator: I have advantage because of electronic access saves time	3 hours
12. Store/Maintain data	File and maintain copies of materials submitted to EPA.	School Plants Administrator	1 hour

Tier 3: Excellence Award Application

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
13. Read instructions	Read Application Guide and application for relevant Tier.	Safety Coordinator or Risk Management	0.5 hours
14. Plan activities	Plan gathering of information that will be submitted to EPA.	Safety Coordinator, Risk Management, certified pest technician, custodian, nurse	3 hours
15. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	Safety Coordinator, Risk Management, certified pest technician, custodian, nurse, food services	10 hours
16. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	Executive Director or Chief of Operations and certified 7A/B or higher technician,	2 hours
17. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	Executive Director or Chief of Operations and certified 7A/B or higher technician	2 hours
18. Store/Maintain data	File and maintain copies of materials submitted to EPA.	Executive Director or Chief of Operations	1 hour

Tier 4 Sustained Excellence Award

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
19. Read instructions	Read Application Guide and application for relevant Tier.	Executive Director 1, Director	1 hour
20. Plan activities	Plan gathering of information that will be submitted to EPA.	Executive Director 1, Director	7 hours
21. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	Executive Director 1, Director Certified Pest technicians 2	7 hours
22. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	Executive Director 1, Director Certified Pest technicians 2	7 hours
23. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	Executive Director 1, Director Certified Pest technicians 2	2 hours
24. Store/Maintain data	File and maintain copies of materials submitted to EPA.	Executive Director 1, Director	1 hour

Tier 5 Connector Award

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
25. Read instructions	Read Application Guide and application for relevant Tier.	Director	0.5 hours
26. Plan activities	Plan gathering of information that will be submitted to EPA.	Director	0.5 hours
27. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.	Director	1.5 hours
28. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.	Director	4 hours
29. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.	Director	3 hours
30. Store/Maintain data	File and maintain copies of materials submitted to EPA.	Director	0.5 hours

Stakeholder Response by: Peggy Caruso: Assistant Director of Maintenance and Environmental Services, Katy Independent School District

Respondent Paperwork Activity Category	Description of Category (Specific task performed)	Job Title and Number of Employees Performing this Task	Average Time (in hours) Spent by Each Employee on this Task
Example: Gather information	Request information from schools	IPM Coordinator, 1	1.5
Example: Gather information	Gather requested information and submit to district	Administrative assistant, 4	5.0
1. Read instructions	Read Application Guide and application for relevant Tier.
2. Plan activities	Plan gathering of information that will be submitted to EPA.
3. Gather information	Canvass / Contact personnel from schools within the district to gather information for application.
4. Compile and review	Assemble data, evaluate for accuracy, appropriateness, and completeness.
5. Complete and submit paperwork	Complete all appropriate application documents and send to EPA.
6. Store/Maintain data	File and maintain copies of materials submitted to EPA.

Great Start:

Leadership Award:

Excellence:

Model of Sustained Excellence:

Connector:

The Texas A&M University System, U.S. Department of Agriculture, and the County Commissioners Courts of Texas Cooperating