Pesticides: Use, Effects, and Alternatives to Pesticides in Schools
(Letter Report, 11/29/1999, GAO/RCED-00-17).

Pursuant to a congressional request, GAO provided information on the use
of pesticides in schools, focusing on: (1) what federal requirements
govern the use of pesticides in schools; (2) what information exists on
the use of pesticides in schools; (3) what data exist on the incidences
of short- and long-term illnesses linked to the exposure to pesticides
in schools, and to the extent data are available, what does this data
show; and (4) what actions are the Environmental Protection Agency (EPA)
and the states taking, where appropriate, to reduce the use of
pesticides in schools, and what are the results of their efforts.

GAO noted that: (1) the Federal Insecticide, Fungicide, and Rodenticide
Act regulates the use of pesticides in the United States, but there are
no specific provisions in the law about the use of pesticides in
schools; (2) EPA will register a pesticide, thereby permitting its sale
and distribution, if it determines that the pesticide will not generally
cause unreasonable adverse effects on human health or the environment;
(3) registration decisions are based in part on studies of the
pesticides' effects and toxicity, some of which are designed to assess
the risks to infants and children; (4) the law requires that regardless
of where they are used, pesticides be used only as directed by their
labels; (5) over 3,000 pesticide labels include provisions applicable to
how, when, and where the pesticides can be used in schools, but these
provisions do not generally afford any greater or lesser protection for
school children than other groups; (6) comprehensive nationwide
information on the amount of pesticides used in the nation's 110,000
public schools is not available; (7) the federal government has not
collected such data, and only one state, Louisiana, requires its school
districts to specifically report the amount of pesticides used; (8) one
other state, New York, requires commercial applicators to report
information on the amount of pesticides they used and the locations
where they used it; (9) neither of these states has yet to analyze the
data collected; (10) six other states require commercial applicators to
report the amounts of pesticides they use, but the reported information
does not identify where the pesticides were used; (11) data on short-
and long-term illnesses linked to pesticide exposure are limited; (12)
information from the American Association of Poison Control Centers
shows that from 1993 through 1996, about 2,300 pesticide-related
exposures involving individuals at schools were reported; (13) however,
there are questions about the completeness and reliability of these data
because some cases are not reported and outcomes are not known for over
40 percent of reported cases; (14) EPA and a number of states have taken
initiatives to reduce the use of pesticides in schools by employing
alternative pest management strategies; (15) EPA has been active in
encouraging schools to adopt integrated pest management since the early
1990's; and (16) six states have enacted laws mandating integrated pest
management in their schools.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-00-17
     TITLE:  Pesticides: Use, Effects, and Alternatives to Pesticides
	     in Schools
      DATE:  11/29/1999
   SUBJECT:  Pesticides
	     Pesticide regulation
	     Safety standards
	     Health hazards
	     Public schools
	     Data collection
	     Labeling law
	     Reporting requirements
	     State law
	     Federal/state relations
IDENTIFIER:  EPA Pesticide Program
	     Louisiana
	     New York
	     EPA Integrated Pest Management Program

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Cover
================================================================ COVER

Report to the Ranking Minority Member, Committee on Governmental
Affairs, U.S.  Senate

November 1999

PESTICIDES - USE, EFFECTS, AND
ALTERNATIVES TO PESTICIDES IN
SCHOOLS

GAO/RCED-00-17

Pesticides in Schools

(160491)

Abbreviations
=============================================================== ABBREV

  EPA - Environmental Protection Agency
  FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act

Letter
=============================================================== LETTER

B-283799

November 29, 1999

The Honorable Joseph I.  Lieberman
Ranking Minority Member
Committee on Governmental Affairs
United States Senate

Dear Senator Lieberman: 

Pesticides destroy, prevent, or repel pests, such as insects, weeds,
and rodents, but may cause a range of harmful health effects in
humans, including cancer, short- and long-term injury to the nervous
system, lung damage, reproductive dysfunction, and possible
dysfunction of the endocrine (hormone) and immune systems.  Children
are at greater risk from pesticide exposure than most adults because,
pound for pound of body weight, children breathe more, eat more, and
have more rapid metabolisms than adults, and they also play on the
floor and lawn where pesticides are commonly applied.  Children have
more frequent hand-to-mouth contact as well. 

Concerned about the potential exposure of children to pesticides, you
asked us to review a number of issues concerning the use of
pesticides in schools.  Specifically, this report addresses the
following questions:  (1) What federal requirements govern the use of
pesticides in schools?  (2) What information exists on the use of
pesticides in schools?  (3) What data exist on the incidences of
short- and long-term illnesses linked to exposure to pesticides in
schools, and to the extent data are available, what do these data
show?  (4) Are the Environmental Protection Agency (EPA) and the
states taking actions, where appropriate, to reduce the use of
pesticides in schools, and if so, what are the results of these
efforts? 

   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

The Federal Insecticide, Fungicide, and Rodenticide Act regulates the
use of pesticides in the United States, but there are no specific
provisions in the law about the use of pesticides in schools.  EPA
will register a pesticide, thereby permitting its sale and
distribution, if the agency determines, among other things, that the
pesticide will not generally cause unreasonable adverse effects on
human health or the environment.  Registration decisions are based in
part on studies of the pesticides' effects and toxicity, some of
which are designed to assess the risks to infants and children.  The
law requires that regardless of where they are used, pesticides be
used only as directed by their labels.  Over 3,000 pesticide labels
include provisions applicable to how, when, and where the pesticides
can be used in schools, but these provisions do not generally afford
any greater or lesser protection for school children than other
groups, such as hospital and nursing home patients. 

Comprehensive nationwide information on the amount of pesticides used
in the nation's 110,000 public schools is not available.  The federal
government has not collected such data, and according to EPA's 10
regional offices and the state officials we spoke with, only one
state, Louisiana, requires its school districts to specifically
report the amount of pesticides used.  In addition, one other state,
New York, requires commercial applicators to report information on
the amount of pesticides they used and the locations where they used
it.  While this information could be used to help analyze pesticide
exposure incidents, neither of these states has yet to analyze the
data collected.  Six other states require commercial applicators to
report the amounts of pesticides they use, but the reported
information does not identify where the pesticides were used. 
Because EPA believes this information would be useful to help
determine the risks posed by pesticides, the agency is considering
conducting a survey (pending adequate funding) on the use of
pesticides in schools and other public settings in the near future. 

Data on short- and long-term illnesses linked to pesticide exposure,
whether in schools or other settings, are limited.  Information on
incidents of short-term pesticide exposure that EPA obtained from the
American Association of Poison Control Centers shows that from 1993
through 1996, about 2,300 pesticide-related exposures involving
individuals at schools were reported.  However, there are questions
about the completeness and reliability of these data because some
cases of pesticide exposure are not reported and outcomes are not
known for over 40 percent of the reported cases.  Information on the
long-term illnesses linked to pesticide exposure, not only for school
children but also for the public in general, is even more limited. 
While the federal government has recently initiated several studies
to identify what long-term illnesses are linked to pesticide
exposure, many will not be completed for several years. 

EPA and a number of states have taken initiatives and actions over
the last decade to reduce the use of pesticides in schools by
employing alternative pest management strategies.  Taken together,
these alternatives are commonly referred to as integrated pest
management and may include making structural repairs to prevent pests
from getting into a building, improving sanitation, and using baits
and traps as needed.  If pesticides are needed, integrated pest
management suggests that the least-toxic chemical controls be used. 
EPA has been active in encouraging schools to adopt integrated pest
management since the early 1990s, including providing financial
support to some states and school districts and developing manuals
and education kits.  A number of states are also taking actions to
implement or encourage integrated pest management in schools. 
Specifically, six states have enacted laws mandating the use of
integrated pest management in their schools, while another has
provided for voluntary participation. 

   BACKGROUND
------------------------------------------------------------ Letter :2

Pesticides are designed to control or eliminate pests such as
insects, rodents, weeds, bacteria, and fungus.  Although pesticides
play a significant role in increasing food production and eliminating
diseases, exposure to pesticides can be harmful to humans.  The
ill-effects may follow from short- or long-term exposure and from
low- or high-level exposure through skin contact, inhalation, or
ingestion.  Some pesticides are highly toxic, with a few drops
causing extremely harmful effects; although other pesticides are less
toxic, too much exposure to them can also cause harmful effects. 
Symptoms may appear within minutes or hours after an exposure to a
pesticide and range from relatively mild headaches to fatigue, skin
rashes, eye irritation, burns, paralysis, and even death.  Because
some of these symptoms are similar to those of other illnesses (such
as the flu), the effects of pesticides can be misdiagnosed, which may
mask the true extent of the illnesses caused by pesticides. 
Long-term illnesses and those with delayed onsets, such as cancer,
which may only appear years after exposure to pesticides, can also
occur.  Some long-term illnesses linked to pesticide exposure may be
subtleï¿½such as neurological disorders or reduced cognitive skills. 

Because of the potentially harmful effects of pesticides on human
health and the environment, a number of governmental agencies, such
as EPA, and interest groups, such as the National Coalition Against
the Misuse of Pesticides, have advocated the use of alternative pest
management strategies.  Integrated pest management is not a new
concept.  It has been used in agriculture for several decades, and
its use in schools has been emphasized by EPA and some states since
the early 1990s. 

   FEDERAL REQUIREMENTS GOVERNING
   PESTICIDES DO NOT SPECIFICALLY
   REFER TO THEIR USE IN SCHOOLS
------------------------------------------------------------ Letter :3

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
regulates the use of pesticides in the United States.  Under FIFRA,
pesticides must generally be registered with EPA to be sold or
distributed.  EPA will register a pesticide if it determines, among
other things, that the pesticide will not generally cause
unreasonable adverse effects on human health or the environment when
used in accordance with commonly recognized practices.  EPA makes
this determination based on studies of a pesticide's effects.  Some
of the studies are designed to assess the risks to infants and
children.  EPA may cancel a registration if it later determines that
a pesticide poses an unreasonable risk to health or the environment. 
EPA's principal means of ensuring proper use of pesticides is
enforcement of the agency-approved label directions, restrictions,
and precautions.  Failure to use a pesticide in accordance with the
label may result in civil or criminal penalties.  While FIFRA itself
does not contain any provisions specifically about the use of
pesticides in schools, some pesticide labels do specify how, when,
and where the pesticides can be used in schools. 

According to an official of EPA's pesticide program, more than 3,000
pesticide labels (out of over 17,000) include provisions applicable
to how, when, and where the pesticides can be used in schools.  For
example, one insecticide label we reviewed stated that school
classrooms should only be treated when students are not present and
that all treated surfaces should be dry before the students are
allowed to return.  It further stated that hospital and nursing home
patients should be removed from their rooms while the pesticide is
being applied and not allowed to return until all treated surfaces
are dry.  An EPA pesticide program official said that the labels that
mention use in schools do not generally afford any greater or lesser
protection for school children than for other groups, such as
hospital and nursing home patients. 

   NATIONWIDE INFORMATION ON THE
   USE OF PESTICIDES IN SCHOOLS IS
   NOT READILY AVAILABLE
------------------------------------------------------------ Letter :4

Comprehensive nationwide information on the amount of pesticides used
in the 110,000 public schools of the nation's 12,000 school districts
is not available.  According to EPA, there is no federal requirement
that such data be collected.  We identified only one state that
requires its school districts to specifically report the amount of
pesticides used and one other state that requires commercial
applicators to report information on the amounts of pesticides they
used and where they used them.  Consequently, little information
exists nationwide on the extent to which children are exposed to
pesticides while at school.  EPA headquarters officials said that
having information on the use of pesticides would be useful and,
pending adequate funding, is considering conducting a survey on the
use of pesticides in schools and other public settings in the near
future. 

While many of the EPA regional and state officials said that
obtaining, sorting, organizing, and analyzing data on the overall use
of pesticides in schools would be costly, a current requirement in
FIFRA could be used to document the use of some pesticides in
schools.  FIFRA requires that in the absence of state reporting
requirements, certified applicators of restricted-use pesticides
(ones that are particularly toxic that can only be applied by
certified pesticide applicators) must maintain records that contain
the product names, amounts, approximate dates of application, and
locations where any restricted-use pesticides were applied and to
retain the records for 2 years after the pesticides' use.  While the
records must be made available to any federal or state agency that
deals with pesticide use or with any health or environmental issue
connected with the use of these pesticides, FIFRA does not currently
require this information to be reported to EPA. 

The EPA regional and state officials identified eight states that
collect information on the use of pesticides in their states, but
only two collect information on pesticides used in schools.  In 1995,
Louisiana passed a law requiring school districts to reduce their use
of pesticides, as well as to annually report the amounts of
pesticides used.  New York passed a law in 1996 requiring commercial
applicators to report the amounts of pesticides they used, including
where they used them.  While this information could be used to help
analyze incidents of pesticide exposure, neither state has yet
analyzed the information reported.  Six other statesï¿½Arizona,
California, Connecticut, Massachusetts, New Hampshire, and New
Mexicoï¿½require commercial applicators to submit information on the
total amounts of specific pesticides used.  However, these states do
not require the applicators to identify where the pesticides were
applied. 

EPA headquarters officials said that information on the use of
pesticides in schools would be useful.  In fact, EPA is considering
conducting a feasibility study in fiscal year 2000 and a full-scale
statistical survey in fiscal years 2001 and 2002 (pending adequate
funding) on the use of pesticides in schools and other public
settings to gather the data needed to determine the risks posed by
pesticides. 

   DATA ON SHORT- AND LONG-TERM
   ILLNESSES LINKED TO PESTICIDE
   EXPOSURE IN SCHOOLS ARE LIMITED
------------------------------------------------------------ Letter :5

Data on the extent to which school children, and people in general,
are experiencing short- or long-term illnesses and injuries due to
pesticides are limited.  The data sources that are available to track
pesticide exposures in schools have limitations that could result in
significant underestimation of both the frequency and the severity of
pesticide exposuresï¿½not only the exposures occurring in schools, but
those occurring in all settings.  Recognizing the limitations of
these data sources, EPA and others have recently undertaken a number
of initiatives to improve the quality of the data on the short-term
illnesses linked to pesticide exposures in schools and elsewhere, but
it is too early to assess the results of these initiatives. 
Information on the long-term illnesses linked to pesticide exposure,
not only for school children, but generally, is even more limited. 
While the federal government has recently initiated several studies
to identify what long-term illnesses are linked to pesticide
exposure, most will not be completed for several years. 

      INFORMATION ON THE EXTENT OF
      SHORT-TERM PESTICIDE
      EXPOSURE IN SCHOOLS IS
      LIMITED
---------------------------------------------------------- Letter :5.1

EPA provided us with information from two data sources that contain
information on the extent of pesticide exposures at school sites: 
the American Association of Poison Control Centers' Toxic Exposure
Surveillance System and the so-called FIFRA section 6(a)(2) reporting
system.  While these two data sources can isolate pesticide exposures
that occurred at schools and other locations, both have limitations
that affect the reliability and completeness of their information. 

Specifically, EPA's analysis of the Poison Control Centers' data
showed that from 1993 through 1996, about 2,300 pesticide exposures
involving individuals at schools were reported.  Of these, 329
individuals were seen in health care facilities, 15 were
hospitalized, and 4 were treated in intensive care units.  However,
EPA officials expressed a number of concerns about the reliability
and completeness of these numbers: 

  -- Some cases of known or suspected pesticide exposure are simply
     not reported. 

  -- Some Poison Control Centers do not report to the national
     database.  Poison Control Centers represented in the national
     database covered only 81 percent of the nation's population
     during the period from 1993 through 1996. 

  -- Outcomes are not known for over 1,000 of the 2,300 reported
     exposure cases. 

  -- Standardized criteria do not exist to clearly identify illnesses
     linked to pesticide exposure, and thus misclassification of
     pesticide illnesses may have occurred when symptoms were
     reported over the phone and were not confirmed by a physician or
     laboratory test. 

The second data source, required by section 6(a)(2) of FIFRA,
requires those responsible for registering a pesticide with EPA to
report adverse effects to EPA if they become aware of such effects
through studies or incidents.  EPA's analysis of these data showed
that from 1992 through 1997, 80 incidents (each of which may have
involved one or more individuals) occurred involving pesticides at
schools.  An EPA pesticide program official told us that these data
may not be complete because (1) those responsible for registering the
pesticides may not be aware of all incidents, (2) not all incidents
occurring in schools are clearly identified as such, and (3) EPA
relies heavily on voluntary reporting by those responsible for
registering the pesticides. 

An August 1999 internal memorandum concerning pesticides in schools,
prepared by EPA pesticide program officials, stated that no one data
source has complete national and age-group coverage and that the
definition of a pesticide poisoning incident varies across data sets. 
The memorandum also stated that underreporting is a known problem for
pesticide poisoning surveillance systems in general and thus for
incidents at schools as well.  Recognizing these data limitations and
concerns, EPA has taken or is considering a number of actions to
address them.  For example, EPA, in conjunction with the National
Institute for Occupational Safety and Health, collaborated with other
federal agencies, state health departments, and others to develop a
standardized list of information states should collect to improve
data consistency.  The collection of this standardized information is
now being undertaken in eight states. 

   VIRTUALLY NO INFORMATION EXISTS
   ON THE LONG-TERM ILLNESSES
   LINKED TO PESTICIDE EXPOSURES
------------------------------------------------------------ Letter :6

Information on long-term illnesses from the use of pesticides in
schools, and in general, is even more limited than the information on
short-term illnesses.  EPA and the National Institutes of Health have
recently sponsored a number of studies on children's environmental
health to fill this information void, but it will be several years
before these studies are completed.  Among the studies being
conducted, we identified one that will measure the exposure of school
children in kindergarten through the fifth grade to pesticides and
other chemicals.  The sample group comprises children from two
low-income, racially diverse neighborhoods in Minneapolis, Minnesota. 
The results of this study are intended to provide information about
how children are exposed to pesticides. 

   EFFORTS ARE UNDER WAY TO REDUCE
   THE USE OF PESTICIDES IN
   SCHOOLS
------------------------------------------------------------ Letter :7

Because of the potential harm pesticides can do to human health and
the environment, EPA and a number of states have taken steps over the
last decade to reduce the use of pesticides in schools by employing
alternative pest management strategies.  Generally, these strategies
include actions such as monitoring for pests, making structural
repairs to prevent pests from getting into buildings, improving
sanitation, using baits and traps as needed as opposed to routinely
spraying for pests, and if pesticides are needed, using the
least-toxic chemical controls. 

      EPA HAS ENCOURAGED THE USE
      OF INTEGRATED PEST
      MANAGEMENT IN SCHOOLS
---------------------------------------------------------- Letter :7.1

Over the last decade, EPA has undertaken numerous initiatives to
encourage the implementation of integrated pest management in
schools.  For example, EPA has provided financial support to some
states and school districts to help them implement integrated pest
management programs.  EPA provided a grant to Louisiana to measure
the effect of integrated pest management techniques in controlling
pests in school facilities and another grant to Florida's Department
of Health to develop a national integrated pest management Web
site.\1 EPA has created a national directory with specific
information about each state program and the appropriate state
contacts.\2 EPA has also developed several different integrated pest
management manuals and brochures, education kits, and videos.\3 In
addition, EPA has hosted conferences and workshops on the use of
pesticides in schools. 

--------------------
\1 www.ifas.ufl.edu/~schoolipm/index.html

\2 www.epa.gov/reg5foia/pest/matilla/imp.html

\3 For instance, EPA developed Pest Control in the School
Environment:  Adopting Integrated Pest Management (EPA 735-F-93-012,
Aug.  1993) and IPM for Schools:  A How-to-Manual (EPA 909-B-97-001,
Mar.  1997). 

      SOME STATES HAVE TAKEN
      INITIATIVES TO REDUCE THE
      USE OF PESTICIDES IN SCHOOLS
---------------------------------------------------------- Letter :7.2

Seven states have enacted laws on the implementation of integrated
pest management programs, according to EPA officials.  Six of these
states mandate the use of integrated pest management in schools,
currently or in the near future:  Illinois, Louisiana, Maryland,
Michigan, Texas, and West Virginia.  The seventh state, Montana, has
enacted a law that encourages school districts to voluntarily
implement integrated pest management.  Of the six states with
mandatory programs, Texas enacted the first law (1991), but it did
not become effective until 1995.  Texas officials said that 74
percent of the state's school districts responded to a recent survey
and all indicated that they were complying with the state's
requirement to adopt an integrated pest management program.  The
officials said that because the remaining 26 percent did not respond,
they were concerned that these school districts were not complying
with the requirements and planned to follow up with these school
districts to ascertain the status of their integrated pest management
programs.  Rather than adopting a mandatory integrated pest
management program, Illinois enacted a voluntary program in 1992.  At
that time, 91 percent of the state's schools reported that they
routinely sprayed pesticides.  A survey conducted in 1998 showed that
82 percent of the state's schools were still routinely spraying
pesticides.  Concerned about the lack of progress in reducing the use
of pesticides, state officials told us that the state's integrated
pest management law had been amended to change the program from
voluntary to mandatory, effective in August 2000. 

In addition to states' enacting legislation on the implementation of
integrated pest management programs, EPA officials also noted that
some states have passed laws requiring advance notification and the
posting of signs whenever pesticides are used in schools.  Nine
states require some type of notification before applying pesticides. 
Specifically, two of these states require that all parents or
guardians be notified, while the other seven states require that
school districts develop a registry of those who want or need to be
notified.  In addition, 18 states require schools to post signs
whenever pesticides are applied.  Appendix I provides a table showing
which states have integrated pest management laws and the
notification or posting requirements. 

In the absence of laws discouraging the use of pesticides in schools,
some other states are pursuing integrated pest management efforts in
schools.  For example, officials from Minnesota's Department of
Agriculture said that their agency is developing a voluntary
integrated pest management program for schools.  The state also plans
to survey schools on their current pest management practices to help
determine what information the schools need about integrated pest
management.  In Florida, the Department of Agriculture's Cooperative
Extension Service has conducted several workshops on integrated pest
management for representatives from every school district in the
state.  A state official said that as a result of these workshops, 70
to 75 percent of the 67 school districts in the state are
implementing integrated pest management activities.  Some school
districts are also trying to implement integrated pest management
activities on their own.  For example, the Monroe County, Indiana,
school district, comprising 18 schools, has implemented its own
initiative over the last several years and has reduced its use of
pesticides by 92 percent. 

      EPA, STATE, AND SCHOOL
      DISTRICT OFFICIALS GENERALLY
      SUPPORT INTEGRATED PEST
      MANAGEMENT BUT IDENTIFIED
      ISSUES CONCERNING ITS
      IMPLEMENTATION
---------------------------------------------------------- Letter :7.3

There was general consensus among the officials of EPA's regional
offices, states, and school districts we contacted that using
integrated pest management in schools is beneficial.  Some of the
primary benefits cited were reducing the risk of pesticide accidents
and the related liability issues and generally reducing the potential
harm to children.  They cautioned, however, that implementing an
integrated pest management program often involves increased costs in
the beginning.  Additionally, integrated pest management entails more
knowledge of the pests and greater labor to control or eliminate
them.  The EPA regional and state officials told us that start-up
costs include training the school staff and obtaining professional
expertise.  Several officials told us that after the first year or
two of the integrated pest management program, the costs drop to a
level that is equal to or below those of traditional pest control
programs.  However, these officials generally did not have detailed
information on the costs prior to or after integrated pest management
was implemented. 

Adopting integrated pest management may not eliminate the use of
pesticides in schools.  EPA regional, state, and school district
officials frequently said that if the stakeholders (including school
administrators, teachers, custodial staff, parents, and students) do
not all support integrated pest management, it may not be effectively
implemented.  For instance, if an administrator wants to adopt
integrated pest management, but other school staff do not support the
program, they might continue using pesticides rather than trying
integrated pest management methods.  For example, several of the
officials we spoke with told us that some teachers apply pesticides
in their classrooms rather than waiting to see whether the integrated
pest management activities prove to be effective.  Similarly, if
custodial staff implement integrated pest management without the
other stakeholders' support, others in the school may not understand
that some pests might be present while the source of the problem is
being identified and eliminated. 

While generally supportive of the benefits of integrated pest
management, most of the EPA regional and state officials expressed
some reservations about a national requirement for integrated pest
management for schools.  They said that (1) because pest problems
differ across the nation, a national requirement could be too
prescriptive; (2) adequate resources would have to be devoted to
assisting school districts in implementing integrated pest
management; and (3) adequate resources would have to be devoted to
monitoring the implementation of the law and enforcing it. 

   AGENCY COMMENTS
------------------------------------------------------------ Letter :8

We provided EPA with a draft of this report for its review and
comment.  EPA supported our inquiry into this matter, stating that
one of its highest priorities is the protection of children's health,
including any risk from their exposure to pesticides in schools.  EPA
also provided additional information on the process it uses to
register pesticides, as well as on additional ongoing or planned
efforts it has to encourage the use of integrated pest management in
schools.  The full text of EPA's comments is included as appendix II. 

---------------------------------------------------------- Letter :8.1

We conducted our review from May through November 1999 in accordance
with generally accepted government auditing standards.  See appendix
III for the details of our scope and methodology. 

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 30 days after the date of this letter.  At that time, we will
send copies to other appropriate congressional committees and to
Carol M.  Browner, Administrator of EPA.  We will also make copies
available to others upon request. 

Should you need further information, please call me at (202)
512-6111.  Key contributors to this report are Charles Barchok,
Harriet Drummings, Richard Johnson, Stephanie Luehr, Mary Nugent, and
David A.  Rogers. 

Sincerely yours,

David G.  Wood
Associate Director, Environmental
 Protection Issues

STATES' LEGISLATION AND
REQUIREMENTS ON THE USE OF
PESTICIDES IN SCHOOLS AS OF
SEPTEMBER 1999
=========================================================== Appendix I

                                                          Requires
                                                          signs be
                                            Requires      posted in
                              Enacted       notification  areas where
                              integrated    that          pesticides
                              pest          pesticides    will be or
                              management    will be       have been
State                         law\a         used\b        used\c
----------------------------  ------------  ------------  ------------
Alabama

Alaska

Arizona

Arkansas

California

Colorado                                                  X

Connecticut                                 Registry

Delaware

District of Columbia

Florida

Georgia                                                   X

Hawaii

Idaho

Illinois                      X             Registry      X

Indiana                                                   X

Iowa                                                      X

Kansas

Kentucky

Louisiana                     X             Registry

Maine                                                     X

Maryland                      X             All parents   X

Massachusetts                               Registry      X

Michigan                      X             Registry      X

Minnesota

Mississippi

Missouri

Montana                       X                           X

Nebraska

New Hampshire                                             X

New Jersey                                                X

New Mexico

New York

Nevada

North Carolina

North Dakota

Ohio                                                      X

Oklahoma

Oregon

Pennsylvania                                Registry

Rhode Island                                              X

South Carolina

South Dakota

Tennessee

Texas                         X             All parents   X

Utah

Vermont                                                   X

Virginia

Washington                                                X

West Virginia                 X             Registry

Wisconsin                                                 X

Wyoming
----------------------------------------------------------------------
\a Six states--Illinois, Louisiana, Maryland, Michigan, Texas, and
West Virginiaï¿½mandate the use of integrated pest management in
schools currently or in the near future.  A seventh state, Montana,
has a law that encourages school districts to voluntarily implement
integrated pest management in schools. 

\b Some states require that all parents or guardians be notified when
pesticides are being applied.  Other states require school districts
to develop a registry of those who want or need to be notified. 

\c The posting requirements vary by state.  The requirements can
apply to indoor or outdoor settings as well as to the periods prior
to or after pesticides have been used. 

Source:  EPA regional officials. 

(See figure in printed edition.)Appendix II
COMMENTS FROM THE ENVIRONMENTAL
PROTECTION AGENCY
=========================================================== Appendix I

(See figure in printed edition.)

(See figure in printed edition.)

SCOPE AND METHODOLOGY
========================================================= Appendix III

To determine what federal requirements govern the use of pesticides
in schools, we reviewed applicable federal statutes and regulations. 
We then corroborated this information with the Environmental
Protection Agency's (EPA) Office of Pesticide Programs, EPA's Office
of General Counsel, and the U.S.  Department of Education's Office of
Elementary and Secondary Education.  We also worked with officials of
EPA's Office of Pesticide Program to determine the number of
pesticide labels that were listed in its label database that refer to
school use. 

To determine what information exists on the use of pesticides in
schools, we conducted interviews with pesticide program officials in
EPA's headquarters and its 10 regional offices.  We asked these
officials about, among other things, which states have reporting
requirements.  If states were collecting information, we asked what
the data showed.  We also conducted interviews with officials from 10
states--California, Connecticut, Florida, Illinois, Indiana,
Louisiana, Maryland, Minnesota, New York, and Texas--to discuss
similar points.  In selecting the states to contact, we considered
geographic distribution and which states had legislative mandates to
reduce the use of pesticides or had reporting requirements on the use
of pesticides.  Finally, we discussed the usefulness of the reporting
requirements with interest groups that included the National Pest
Control Association and the National Coalition Against the Misuse of
Pesticides. 

To determine what data exist on the incidences of short- and
long-term illnesses linked to exposure to pesticides in schools, and
to the extent data were available, what these data show, we conducted
interviews with EPA pesticide program officials to determine what and
how information on illnesses is collected at a national level.  We
reviewed several EPA documents that described and critiqued the
databases used to collect information on short-term illnesses.  We
also conducted interviews with pesticide program officials in EPA's
10 regional offices.  We asked the officials about which states in
their respective regions track incidences of short-term illnesses and
what the data show.  In addition we conducted interviews with
officials from the 10 states listed above to discuss similar points. 
We also interviewed health officials from two states--Florida and
Texas--that are actively involved with tracking pesticide-related
illnesses to determine how information is collected.  Finally, we
discussed the usefulness of tracking pesticide-related illnesses with
interest groups that included the National Pest Control Association
and the National Coalition Against the Misuse of Pesticides.  We
interviewed EPA pesticide program officials about long-term illnesses
linked to pesticide exposure.  They provided us with information on
several ongoing EPA-funded studies on children's environmental
health. 

To determine whether EPA and the states are taking actions to reduce
the use of pesticides in schools and what the results of these
efforts are, we conducted interviews with EPA pesticide program
officials.  We obtained some manuals and education kits that EPA has
prepared and distributed to states and school districts to encourage
less use of pesticides in schools.  We also conducted interviews with
pesticide program officials in EPA's 10 regional offices.  We asked
these officials about which states in their regions have undertaken
actions to reduce the use of pesticides in schools and discussed the
benefits, costs, and start-up issues involving integrated pest
management, as well as EPA's efforts to assist the states and school
districts.  In addition, we conducted interviews with officials from
the 10 states listed above to discuss the status of their efforts,
including the benefits, costs, and start-up issues of implementing an
integrated pest management program.  We reviewed manuals, Web sites,
and videos the states have prepared to assist school districts in
reducing the use of pesticides.  We also interviewed officials of
several school districts that have reduced their use of pesticides
about the associated benefits, costs, and start-up issues.  Finally,
we discussed the benefits, costs, and start-up issues of implementing
an integrated pest management program with interest groups that
included the National Pest Control Association and the National
Coalition Against the Misuse of Pesticides. 

*** End of document. ***