4.2 Pesticide Use in Ohio Schools (OAC 901:5-11-15)

4.2 Pesticide Use in Ohio Schools (OAC 901:5-11-15)

Schools are one of the publicly accessible sites in ORC 921.06 that force in-house staff into commercial licensure, and they are also governed by a dedicated pesticide rule. Any Category 10A applicator working in Ohio will meet it.

Which Schools Are Covered

The rule applies to:

1. School classroom buildings established under ORC Chapter 3311 (public school districts)
2. Educational service centers and community schools established under ORC Chapter 3314
3. STEM schools established under ORC Chapter 3326
4. Non-public schools chartered by the state board of education under ORC 3301.16

Note the scope: classroom buildings. Athletic fields, grounds, and bus garages are not classroom buildings, though other rules - lawn notification, WPS where applicable, recordkeeping - still apply there.

When Pesticides May Be Applied

Pesticides may be applied on or in a school classroom building only if one of the timing conditions is met.

Option A - outside occupied hours

Apply the pesticide:

• after the school day has concluded, or
• when school is not in session, or
• at least four hours - or the minimum time specified by the product label, whichever is longer - before the school day begins.

The "whichever is longer" clause matters: a product with a 12-hour re-entry statement controls over the rule's four-hour floor.

Option B - while school is in session, with restrictions

An application may be made while school is in session only if all three of the following are true:

1. People other than pesticide applicators and necessary school staff are not scheduled to be in the treatment area during treatment and for the longer of four hours or the label's minimum time, measured from the time the application is completed.
2. The entrances to the treated area are posted with signs that:
   • measure at least 8.5 inches by 11 inches, and
   • are printed with letters at least one inch in height reading: "Pesticide Treatment Area. Do Not Enter Before (the date and time when re-entry will be permitted into the treatment area)." The time is the later of four hours or the label's minimum, measured from completion of the application.
3. The product applied is one of the following, applied in strict accordance with label instructions:
   • manufactured paste or gel baits
   • paraffin-based rodent control products placed in industry-identified tamper-resistant bait stations
   • termite-baiting stations
   • rodenticides placed in wall voids or other areas inaccessible to humans and domestic animals
   • disinfectants, sanitizers, germicides, and anti-microbial agents
   • dusts used in unoccupied areas of the structure

That list is the practical heart of the rule. A general perimeter spray, a broadcast crack-and-crevice liquid, or an aerosol fog cannot be applied while school is in session under any circumstance.

What the Applicator Reports to the School

After an application - except for disinfectants, sanitizers, germicides, and anti-microbial agents - the applicator provides the school's designated contact person, as soon as practicable following the application:

1. Date and time the pesticide was applied
2. Treatment area
3. Target pests
4. Brand name and EPA registration number of the pesticide applied
5. If applied while school was in session, the time or conditions for re-entering the treatment area as specified by the label

This is in addition to - not instead of - the OAC 901:5-11-10 application record the applicator keeps.

The School's Own Duties

Products applied under the disinfectant/sanitizer/germicide/anti-microbial exception are excepted from the school notification policy requirements.

How This Interacts With the IPM Standard

School pest management is the classic case for OAC 901:5-11-14, Ohio's IPM standard for non-agricultural uses. A contract that combines site assessment, sanitation and exclusion recommendations, monitoring, and targeted bait placement satisfies both the schools rule's product limits and the IPM standard's process requirements, and it is what most Ohio districts expect a bidder to propose.