How to Build an IPM Plan That Passes Inspection

Massachusetts daycare centers must file Indoor and Outdoor IPM plans under 333 CMR 14.00 and keep them current with matching records. Indoor plans cover monitoring schedules, pest thresholds, and documentation for classrooms, kitchens, and storage areas. Outdoor plans add a parent notification workflow required before any pesticide application on playgrounds or turf. Most inspection failures come from documentation gaps, not pest problems. This guide walks through building both plans step by step.

Regulation: 333 CMR 14.00 (Protection of Children and Families from Harmful Pesticides)

What This Guide Covers

If an inspector asks to see your IPM binder tomorrow, could you hand it over with confidence? Many daycare operators cannot. The plans they filed years ago sit in a drawer while actual pest work happens without documentation. That gap is what gets facilities cited.

This guide covers the required content for both plans, the outdoor notification workflow that trips up most facilities, and the recordkeeping system that keeps everything audit-ready.

Part 1: Understanding What the State Actually Requires

The Two Plans You Need

Massachusetts requires two separate IPM plans:

1. Indoor IPM Plan: Covers everything inside your building (kitchens, classrooms, bathrooms, storage, mechanical rooms)
2. Outdoor IPM Plan: Covers playgrounds, turf, landscaping, dumpster areas, parking lot edges, and building perimeter

Both plans must include:

• Your facility name, address, and telephone number
• Primary contact information for IPM inquiries (name, email, phone)
• Name and contact information for your IPM Coordinator
• Names of your IPM Committee members for that plan
• Contact information for your pest control company
• A description of how you monitor for pests
• Decision criteria for when to take action
• What actions you will take (non-chemical first, then chemical if justified)
• A list of chemicals that may be used, with product name, active ingredient, EPA registration number, target pest, and rationale for use
• How you keep records

The outdoor plan has additional requirements: a notification workflow for any pesticide applications, a map showing outdoor pest locations by area type, and a statement about on-site well water systems.

Both plans require signatures from your IPM Coordinator AND your Administrator, Director, or Principal.

One Coordinator, Two Committees

Your facility has one IPM Coordinator who oversees both plans. This person’s name appears at the top of both your Indoor and Outdoor plans.

However, you have separate IPM Committees for indoor and outdoor:

• The Indoor IPM Committee reviews indoor pest issues and appears in your Indoor plan
• The Outdoor IPM Committee reviews outdoor pest issues and appears in your Outdoor plan

The committees may have overlapping members (often the coordinator appears on both), but each plan must list the specific committee members for that plan.

In the committee lists, your coordinator is typically identified by their role for that plan (for example, “Jane Smith (Indoor IPM Coordinator)” on the indoor plan and “Jane Smith (Outdoor IPM Coordinator)” on the outdoor plan, even though it is the same person).

The Binder That Matters

Your IPM plans are not standalone documents. They anchor a compliance binder that must include:

• Current indoor plan (signed and dated by Coordinator AND Administrator)
• Current outdoor plan (signed and dated by Coordinator AND Administrator)
• Copies of your pest control company’s license
• Name and license number for any in-house pesticide applicator (if applicable)
• Labels for every pesticide product that might be used
• Monitoring logs (indoor and outdoor)
• Pest sighting reports from staff
• Corrective action tracker
• Pesticide application records
• Outdoor notification packets and posting logs
• Emergency waiver documentation (if you ever needed one)

This binder must be retrievable within minutes. If it takes you 20 minutes to find everything, you have a problem.

Part 2: Building Your Indoor IPM Plan

Step 1: Establish Your Primary Contact for IPM Information

Every facility needs a designated primary contact who can answer IPM questions from parents, staff, or inspectors. This may or may not be the same person as your IPM Coordinator.

Your plan must include:

• Name of the primary contact
• Email address
• Phone number

This information should appear prominently at the top of your indoor plan.

Step 2: Name Your IPM Coordinator

Your facility has one IPM Coordinator who oversees both indoor and outdoor pest management. This is usually the director or assistant director, but it can be any staff member who will actually do the work.

The IPM Coordinator:

• Receives pest reports from staff
• Contacts the pest control company when needed
• Reviews service reports and signs off on recommendations
• Maintains the IPM binder
• Coordinates with committees for both indoor and outdoor issues
• Signs both plans alongside the Administrator

Write this person’s name and contact information in your indoor plan. The same person’s name will also appear in your outdoor plan.

Step 3: Establish Your Indoor IPM Committee

Your indoor plan must list the names of your Indoor IPM Committee members. The committee typically includes:

• The IPM Coordinator (listed as “Indoor IPM Coordinator” in this plan)
• Facility director or administrator
• Maintenance or custodial representative
• At least one classroom staff representative

The committee reviews indoor pest issues, approves control strategies, and ensures the plan stays current.

Important: Your plan must designate which Indoor IPM Committee member is responsible for applying for emergency waivers if an urgent indoor pest situation requires immediate pesticide use outside normal procedures. Write this person’s name in your plan.

Step 4: List Your Pest Control Company and Any In-House Applicators

Include your commercial pest management company information:

• Company name
• License number
• Primary technician name (if you have a regular tech)
• Phone number for scheduling and emergencies

Your pest control company should provide you with a copy of their license for the binder.

If your facility employs any in-house pesticide applicators (staff members who hold pesticide applicator licenses and may apply products themselves), your plan must include:

• Name of each in-house applicator
• License number for each in-house applicator

If you do not have in-house applicators, state this explicitly: “This facility does not employ in-house pesticide applicators. All pesticide applications are performed by [Company Name], License #[Number].”

Step 5: Define How Staff Report Pests

The plan must describe how pest sightings get reported. Keep it simple:

“Staff who see pests or pest evidence (droppings, damage, dead insects) report to the IPM Coordinator the same day using the Pest Sighting Report form. Forms are kept in the staff break room.”

Then actually stock forms in the break room. A plan that says one thing while your facility does another is a compliance failure.

Step 6: Define Your Monitoring Schedule

Your plan needs a baseline inspection frequency. For most daycares:

• Routine inspections: Monthly by the pest control company
• Triggered inspections: Within 48 hours of a credible pest report

Your pest control company should be documenting every inspection, even when they find nothing. “No pest evidence observed” is a valid finding that belongs in your records.

Step 7: List Identified Indoor Pests and Control Plans

Your indoor plan must include a list of identified indoor pests at your facility. Common indoor pests for Massachusetts daycares include:

• Mice
• Ants (including carpenter ants)
• Cockroaches
• Flies
• Spiders
• Occasional invaders (centipedes, silverfish, etc.)

For each identified pest, your plan must describe:

• What triggers action (the threshold)
• Non-chemical controls to try first
• Chemical controls (only if non-chemical fails)

Example for mice:

Worcester County daycares see peak rodent pressure from October through March. Facilities in Sterling, Holden, and West Boylston often experience mice seeking interior warmth when overnight temperatures drop below 20°F. Older buildings with fieldstone foundations are particularly vulnerable because deteriorating mortar creates quarter-inch gaps that mice easily pass through.

Threshold: Any mouse sighting, droppings, gnaw marks, or nesting material.

Non-chemical controls (first priority):

• Seal entry points with copper mesh and caulk (steel wool rusts in Worcester County’s wet climate)
• Remove food sources (secure storage, clean spills same day)
• Install snap traps in tamper-resistant stations in inaccessible areas

Chemical controls (only if non-chemical controls insufficient):

• Rodenticide only in tamper-resistant bait stations
• Stations placed only in areas inaccessible to children
• Stations numbered and mapped
• Check intervals per label requirements

Example for ants:

Carpenter ants become active in Worcester County from April through July, with swarms typically appearing 2 weeks later than coastal Massachusetts due to inland elevation. Facilities near wooded areas in Princeton, Paxton, and rural Sterling see higher carpenter ant pressure, especially in buildings with moisture problems.

Threshold: Repeated sightings (more than one day) or trails observed.

Non-chemical controls (first priority):

• Identify and eliminate food/water sources
• Seal entry points at windows, doors, utility penetrations
• Clean affected areas with soapy water to remove pheromone trails

Chemical controls (only if non-chemical controls insufficient):

• Gel bait in cracks and crevices away from children
• Perimeter treatment during unoccupied hours

Write similar protocols for cockroaches, flies, and any other pests identified at your facility.

Step 8: Create Your Indoor Chemical List

Your indoor plan must include a list of all chemicals that may be used to control indoor pests. For each product, include five columns:

This list must match the product labels in your binder. If a product is not on this list, it should not be used at your facility without updating the plan first.

Review this list annually and remove products you no longer use.

Step 9: Create Your Indoor Recordkeeping System

Your indoor plan must describe how you keep records. At minimum:

• Pest sighting log: Date, location, pest type, who reported it
• Inspection reports: From every pest control visit
• Corrective action tracker: What needs fixing, who owns it, when it was completed
• Pesticide application records: Date, location, product, amount, target pest, applicator name

Use consistent location names. “Room 3” means nothing six months from now. “Toddler classroom, east wall near cubbies” tells you exactly where.

Step 10: Add Signature Lines

Your indoor plan must be signed and dated by both:

1. IPM Coordinator (signature line with date)
2. Administrator, Director, or Principal (signature line with date)

Include a statement above the signatures: “I attest, to the best of my knowledge, that the above information is complete, accurate and true.”

Both signatures indicate that the people responsible for the facility have reviewed and accepted the plan.

Part 3: Building Your Outdoor IPM Plan

Step 1: Name Your IPM Coordinator

Your outdoor plan names the same IPM Coordinator who appears on your indoor plan. This person oversees pest management for the entire facility.

Write this person’s name and contact information in your outdoor plan.

Step 2: Establish Your Outdoor IPM Committee

Your outdoor plan must list the names of your Outdoor IPM Committee members. This committee may overlap with or be identical to your Indoor IPM Committee, but the names must appear explicitly in the outdoor plan.

The Outdoor IPM Committee typically includes:

• The IPM Coordinator (listed as “Outdoor IPM Coordinator” in this plan)
• Facility director or administrator
• Maintenance or grounds representative
• Playground supervisor or lead outdoor staff

Important: Your plan must designate which Outdoor IPM Committee member is responsible for:

• Assembling and issuing notification documents whenever pesticides are applied outdoors
• Applying for emergency waivers if an urgent outdoor pest situation requires immediate pesticide use outside normal notification procedures

Write these names in your plan.

Step 3: List Your Pest Control Company, Landscaping Vendors, and Any In-House Applicators

Include your commercial pest management company information:

• Company name
• License number
• Phone number for scheduling and emergencies

If you use a separate landscaping or lawn care company that applies any pesticides, herbicides, or fungicides, include their information as well:

• Company name
• License number
• Phone number

If your facility employs any in-house pesticide applicators for outdoor work, your plan must include:

• Name of each in-house applicator
• License number for each in-house applicator

If you do not have in-house applicators, state this explicitly.

Step 4: Identify Your Priority Areas and Create an Outdoor Pest Location Map

Walk your property and list every outdoor area where children spend time or pests could be a problem.

Your outdoor plan must include a map of outdoor areas showing the locations of identified pests, organized by area type:

Turf areas:

• Main lawn
• Play field
• Grass areas adjacent to playground

Landscaping areas:

• Mulch beds
• Shrub borders
• Tree rings
• Flower beds

Outdoor grounds (including structure exterior and equipment):

• Building perimeter (2-3 feet out from foundation)
• Playground equipment and surfacing
• Sandbox and borders
• Dumpster pad and surrounding area
• Parking lot edges
• Fence lines
• Outdoor storage sheds
• Any standing water areas (drainage, birdbaths, puddles)

Your map should show where specific pests have been identified or are likely to occur. This does not need to be professionally drawn. A hand-drawn site map with labeled areas and pest notations is acceptable. Update the map when new pest activity is identified.

Step 5: Define Outdoor Monitoring

Your outdoor plan needs a monitoring schedule and methods:

Baseline schedule: Monthly walkthrough of all priority areas during pest season (April through October in Massachusetts)

Monitoring methods by pest:

• Ticks: Drag white flannel cloth through grass and vegetation edges
• Stinging insects: Visual inspection for nests on structures, in ground, in landscaping
• Grubs: Cut and lift 1-square-foot turf sections in suspicious areas
• Weeds: Visual assessment of turf density and weed coverage
• Rodent activity at perimeter: Look for burrows, droppings, gnaw marks on building exterior

Document what you find, even when you find nothing.

Step 6: List Identified Outdoor Pests and Control Plans

Your outdoor plan must include a list of identified outdoor pests at your facility. Common outdoor pests for Massachusetts daycares include:

• Ticks
• Mosquitoes
• Wasps, hornets, and yellow jackets
• Ants (at building perimeter)
• Grubs (in turf)
• Mice and rats (at exterior)
• Weeds (in turf and landscaping)

For each identified pest, your plan must describe:

• What triggers action (the threshold)
• Non-chemical controls to try first
• Chemical controls (only if non-chemical fails)

Example for ticks:

Worcester County has documented Lyme disease cases every year, with blacklegged ticks active from April through October. Facilities bordering conservation land or wooded areas in towns like Princeton, Sterling, and Holden need aggressive tick monitoring. Ticks quest from low vegetation, not trees, so the grass-to-woods transition zone is your highest risk area.

Threshold: Any ticks found during monitoring, or tick-borne illness reported in community.

Non-chemical controls (first priority):

• Keep grass mowed to 3 inches or less
• Create 3-foot gravel or wood chip barrier between lawn and wooded areas
• Remove leaf litter and brush piles
• Discourage deer and rodents (secure trash, remove bird feeders)

Chemical controls (only if non-chemical controls insufficient):

• Perimeter treatment of high-risk areas during unoccupied hours
• Requires completion of outdoor notification workflow before application

Example for stinging insects:

Yellow jackets and bald-faced hornets peak in late summer (August through September) across Worcester County. Ground-nesting yellow jackets are particularly dangerous on playgrounds because children can disturb nests while running. Inspect sandbox borders, mulch edges, and any bare soil areas weekly from July through September.

Threshold: Any nest within 50 feet of areas used by children.

Non-chemical controls (first priority):

• Physical nest removal (if safe and nest is small)
• Seal entry points on structures

Chemical controls (for established nests or ground-nesting species):

• Treatment during unoccupied hours
• Requires completion of outdoor notification workflow before application

Write similar protocols for mosquitoes, grubs, perimeter rodents, and weeds.

Step 7: Create Your Outdoor Chemical List

Your outdoor plan must include a list of all pesticides, herbicides, and fungicides that may be used to control outdoor pests. For each product, include five columns:

This list must match the product labels in your binder. Products not on this list should not be used at your facility without updating the plan first.

If your landscaping vendor uses products, those products must be on this list with labels in your binder.

Review this list annually and remove products you no longer use.

Step 8: Build Your Notification Workflow

This is where most daycares fail. Any outdoor pesticide application requires advance written notification to parents and staff.

The notification packet includes:

1. Standard Written Notification form (MassNRC provides a template)
2. MDAR Consumer Information Bulletin (download from mass.gov)
3. Pesticide-specific fact sheet for each product being applied

The workflow:

1. Pest control company or landscaper contacts IPM Coordinator with treatment recommendation
2. IPM Coordinator reviews justification (pest evidence documented?)
3. If approved, designated committee member assembles notification packet
4. Notification sent to all parents/staff at least 2 working days before application (no more than 7 working days)
5. Signs posted at treatment area boundaries on day of application
6. Treatment performed during unoccupied hours when possible
7. Signs remain until re-entry is safe per label
8. IPM Coordinator files notification packet with posting dates in binder

Timing clarification: If the scheduled application cannot happen on the proposed date, the application may occur within the following 72 hours without issuing a new notification.

Write this workflow into your outdoor plan. Then follow it every single time.

Step 9: Coordinate with Your Landscaping Vendor

If you use a lawn care company that applies fertilizers or pesticides, they must coordinate with your IPM Coordinator before any application.

Add language to your plan:

“All outdoor pesticide applications, including those by lawn care vendors, must be pre-approved by the IPM Coordinator. No application may occur without completion of the notification workflow. Vendors must provide product names, EPA registration numbers, and application details at least 5 business days before proposed treatment.”

Then put this requirement in your landscaping contract.

Step 10: Include Your Well Water System Statement

Your outdoor plan must include a statement about whether your facility has an on-site well water system.

If you have a well:

“This facility has an on-site well water system located [describe location]. All outdoor pesticide applications must consider well protection zones and setback requirements.”

If you do not have a well:

“This facility does not have its own on-site well water system.”

Step 11: Add Signature Lines

Your outdoor plan must be signed and dated by both:

1. IPM Coordinator (signature line with date)
2. Administrator, Director, or Principal (signature line with date)

Include a statement above the signatures: “I attest, to the best of my knowledge, that the above information is complete, accurate and true.”

Both signatures indicate that the people responsible for the facility have reviewed and accepted the plan.

Part 4: The Notification Workflow in Detail

This section expands on the outdoor notification workflow because it is the most common failure point.

When Notification Is Required

Standard Written Notification is required:

• Before any outdoor pesticide application
• Before indoor termiticide applications

Standard Written Notification is not required for:

• Indoor applications other than termiticides
• Applications of EPA-exempt products (25(b) products with no EPA registration number)
• Applications when children and staff will not be present for 5 or more consecutive days after application (but you must get a written statement confirming this and include it in your records)

For year-round baiting programs (like rodent bait stations), notification is required:

• At the start of the program
• Annually on the anniversary of the program start date

The Notification Packet Contents

Every notification must include three items:

1. Standard Written Notification Form

This form must include:

• Description of the purpose of the application (what pest, why now)
• Approximate start and end dates of the application
• Specific location of the application (playground border, turf area, etc.)
• Product name, type, and EPA registration number for every product to be used
• A statement describing precautions and ways to minimize exposure

2. MDAR Consumer Information Bulletin

This is a standardized document from the Massachusetts Department of Agricultural Resources explaining IPM and pesticide use in schools and daycares. Download the current version from mass.gov.

3. Product-Specific Fact Sheets

For each pesticide product being applied, include a fact sheet explaining what it is, how it works, and safety information. Your pest control company can provide these, or they are available from the product manufacturer.

Notification Timing Rules

• Notification must be sent at least 2 working days before the application
• Notification must be sent no more than 7 working days before the application

If you notify on Monday, the earliest you can apply is Wednesday (2 working days). If you notify on Monday, you must apply by the following Monday (7 working days) or re-notify.

How to Send Notification

You may use one of the following methods:

Email: Send all three notification components to parents and staff. You must have a signed permission letter from each parent and staff member (from the current school year) authorizing email notification.

Website with phone or letter notification: Post all notification components on your website, then use a phone notification system (like Reverse 911 or Connect Ed) or a one-page letter to tell parents that a notification is posted and where to find it.

Hard copy: Physically distribute all three notification components to parents and staff.

Emergency Waivers

An Emergency Waiver allows you to skip the 2-day notification requirement or use a product not otherwise permitted. Waivers are granted only when:

• The pest situation poses an immediate threat to human health, AND
• There is no viable alternative to using a pesticide

To obtain an Emergency Waiver:

1. Complete the MDAR-approved Emergency Waiver form
2. Get it signed by your municipal Board of Health, Director of Public Health, or MDAR
3. Post MDAR-approved signs at the application site before the application and for at least 72 hours after
4. Provide notification to parents and staff immediately before or after the emergency application
5. Keep the waiver form and records of the emergency event (including underlying causes and actions taken) for 5 years

As a condition of waiver approval, you must commit to identifying and addressing the underlying causes of the pest outbreak in your IPM plan.

Part 5: Common Inspection Failures

Documentation Gaps

The most common failures:

• Plan filed but not updated: Your 2019 plan names a coordinator who left three years ago
• Chemical list does not match labels: Products in your binder are not on your plan list, or vice versa
• Missing monitoring logs: You do inspections but do not document them
• Notification packets incomplete: Missing fact sheets or bulletins
• No posting log: You posted signs but cannot prove when

Notification Failures

• Notification sent too late: Sent Monday, applied Tuesday (must be 2 working days)
• Missing components: Sent the form but forgot the fact sheet
• No permission letters for email: Using email notification without documented consent
• No notification for annual baiting: Year-round program with no anniversary notice

Structural Failures

• Indoor-only plan: No outdoor plan filed
• Missing coordinator designation: Plan does not name who is responsible
• Missing emergency waiver designee: Plan does not say who handles emergencies
• No signatures: Plans not signed by Coordinator and Administrator

Part 6: Making Your Plans Work in Practice

The Monday Morning Audit

Once a month, spend 15 minutes checking:

1. Can you locate your binder within 2 minutes?
2. Is the last monitoring log entry less than 30 days old?
3. Is the corrective action tracker current?
4. Do all products in your chemical storage match your plan lists?
5. Are notification packets complete for all outdoor applications this year?

If any answer is “no,” fix it before an inspector finds it.

When to Update Your Plans

Update and resubmit your plans to MDAR when:

• Your IPM Coordinator changes
• Committee membership changes
• Pest control company changes
• You add or remove products from your chemical list
• You identify a new pest problem requiring different protocols
• Your contact information changes

Plans must be reviewed annually even if nothing has changed.

Training Your Staff

Staff training should cover:

• How to recognize common pests and pest evidence
• How to fill out a pest sighting report
• Where to submit pest sighting reports
• What to do if they find a pest during class (hint: do not panic, do not spray anything)
• Who to contact with questions

Training does not need to be elaborate. A 15-minute session at the start of the school year, with a refresher in spring, is sufficient. Document that you did it.

Working with Your Pest Control Company

Your pest control company should:

• Provide inspection reports for every visit, even when nothing is found
• Check your IPM plan before any treatment
• Coordinate all outdoor applications through your IPM Coordinator
• Provide notification packet materials (fact sheets, product information)
• Alert you when products need to be added or removed from your plan

If your company does not do these things, find a different company.

Part 7: Worcester County Seasonal Planning

Worcester County’s inland location creates pest timing that differs from coastal Massachusetts. Use this calendar to plan your monitoring emphasis:

October through March: Rodent Pressure

Peak season for mice seeking indoor warmth. Facilities along the Route 12 corridor (Sterling, West Boylston, Holden) see pressure earlier due to rural surroundings and older housing stock. When overnight temperatures drop below 20°F, mice that were living in outbuildings or fields move toward heated structures.

Focus monitoring on:

• Kitchen and food storage areas
• Mechanical rooms (warm, often cluttered)
• Exterior door seals and foundation gaps

Fieldstone foundations common in older Worcester County buildings require copper mesh rather than steel wool for sealing. Steel wool rusts within one season in the local wet climate.

April through July: Carpenter Ant Season

Carpenter ants (Camponotus pennsylvanicus) swarm in Worcester County approximately 2 weeks later than coastal Massachusetts due to inland elevation and cooler spring soil temperatures. Peak swarm activity typically occurs late April through early June.

Facilities near wooded areas in Princeton, Paxton, and rural Sterling see higher pressure. Moisture problems (leaky windows, condensation, roof leaks) attract carpenter ants because they need damp wood for nesting.

Focus monitoring on:

• Window frames and door frames
• Areas with past water damage
• Exterior wood in contact with soil

April through October: Tick Season

Blacklegged ticks (Ixodes scapularis) that transmit Lyme disease are active throughout Worcester County from April through October. The grass-to-woods transition zone is highest risk. Facilities in Princeton, Sterling, Holden, and other towns bordering conservation land need weekly tick monitoring during this period.

Focus monitoring on:

• Property edges adjacent to woods
• Tall grass and brush areas
• Playground perimeters near vegetation

August through September: Stinging Insect Peak

Yellow jackets (Vespula spp.) and bald-faced hornets (Dolichovespula maculata) reach peak colony size in late summer. Ground-nesting yellow jackets are the primary concern for playgrounds because children can unknowingly disturb nests in bare soil or mulch.

Focus monitoring on:

• Sandbox borders and edges
• Bare soil areas in play zones
• Mulch beds
• Building eaves and overhangs
• Outdoor storage sheds

Regardless of season, maintain your monitoring logs. An empty log entry (“No pest evidence observed, playground perimeter, 10/15/2025”) is better than no entry. Gaps in documentation raise questions during inspections.

Frequently Asked Questions

Do I need separate plans for indoor and outdoor, or can I combine them?

You need two separate plans. The outdoor plan has notification requirements that do not apply indoors, and the monitoring approaches are completely different. Combining them creates confusion.

Can the same person be IPM Coordinator for both plans?

Yes, and this is typical. Most facilities have one IPM Coordinator who oversees both indoor and outdoor pest management. That person’s name appears on both plans.

Do I need separate IPM Committees for indoor and outdoor?

You have separate committee lists in each plan, but the members may overlap or even be identical. The key requirement is that each plan explicitly names the committee members for that plan, and each plan designates who handles emergency waivers for that plan.

What if my pest control company handles all the paperwork?

Your pest control company can help you build and maintain your plans, but the daycare is ultimately responsible. You need to understand what is in your plans and verify that actual practice matches. If an inspector asks you questions about your IPM program, “my pest control company handles that” is not an acceptable answer.

How long do I need to keep records?

The regulation requires records to be retained for 5 years (per 333 CMR 14.08(2)).

What counts as a “pesticide” for notification purposes?

Any product with an EPA registration number is a pesticide. This includes many products people do not think of as pesticides, like certain disinfectants and antimicrobial coatings. Check the label. If it has an EPA Reg. No., it requires the notification workflow for outdoor use.

“Minimum risk” products exempt from EPA registration (25(b) products) may not require the same notification, but you should still document their use and include them in your records.

Can I do my own pest control?

You can perform some non-chemical controls (sealing gaps, setting snap traps, removing food sources). However, any pesticide application should be performed by a licensed applicator. If a staff member holds a pesticide applicator license, their name and license number must be in your plan, and they must follow all the same documentation and notification requirements as outside vendors.

What if a parent opts out of notifications?

Parents cannot opt out. The regulation requires you to notify all parents before outdoor pesticide applications. If a parent says they do not want notifications, explain that it is a state requirement, not a choice.

How do I handle a pest control company that does not want to follow these procedures?

Find a different pest control company. Any reputable company working with daycares in Massachusetts understands 333 CMR 14.00 requirements. A company that pushes back on documentation and notification requirements is a liability.

Does my outdoor pest location map need to be professional?

No. A hand-drawn site map showing your building, outdoor areas, and pest activity locations is acceptable. The point is to document where pests have been identified so you can track patterns and demonstrate you know where problems occur. Update it when you find new activity.

What happens if I violate these requirements?

MDAR may assess a civil administrative penalty of up to $1,000 per violation. Before assessing a penalty, the Department must provide written notice and an opportunity to correct the violation within 90 days.

Quick Reference: Required Plan Elements

Indoor IPM Plan Must Include:

Administration

• Facility name, address, and telephone number
• Primary Contact name, email, phone number
• IPM Coordinator name and contact information
• Indoor IPM Committee member names
• Committee member designated for emergency waivers
• Commercial pest management company name, license number, contact information
• In-house applicator names and license numbers (or statement that none employed)

Pest Information

• List of identified indoor pests
• Control plan for each identified pest (threshold, non-chemical controls, chemical controls)
• Chemical list with product name, active ingredient, EPA registration number, target pest, and rationale for use

Recordkeeping

• Description of how pest sighting reports are handled
• Description of monitoring schedule and methods
• Description of how pesticide applications are documented

Signatures

• IPM Coordinator signature and date
• Administrator, Director, or Principal signature and date

Outdoor IPM Plan Must Include:

Administration

• Facility name, address, and telephone number
• Primary Contact name, email, phone number
• IPM Coordinator name and contact information
• Outdoor IPM Committee member names
• Committee member designated for notifications
• Committee member designated for emergency waivers
• Commercial pest management company name, license number, contact information
• Landscaping vendor name, license number, contact information (if applicable)
• In-house applicator names and license numbers (or statement that none employed)

Pest Information

• Outdoor pest location map showing:
  • Turf areas with pest locations
  • Landscaping areas with pest locations
  • Outdoor grounds (structure exterior, playground, equipment) with pest locations
• List of identified outdoor pests
• Control plan for each identified pest (threshold, non-chemical controls, chemical controls)
• Chemical list (pesticides, herbicides, fungicides) with product name, active ingredient, EPA registration number, target pest, and rationale for use

Notification Workflow

• Written description of notification procedure
• Timeline requirements (2-7 working days advance notice)
• Posting requirements
• Committee member responsible for assembling notifications

Additional Sections

• Well water system statement (have one or do not have one)

Recordkeeping

• Description of outdoor monitoring schedule and methods
• Description of how pesticide applications are documented
• Description of how notification packets are maintained

Signatures

• IPM Coordinator signature and date
• Administrator, Director, or Principal signature and date

Quick Reference: Your IPM Binder Checklist

Use this checklist to verify your binder is complete:

Plans and Contacts

• Indoor IPM Plan (current, signed by Coordinator and Administrator, dated)
• Outdoor IPM Plan (current, signed by Coordinator and Administrator, dated)
• Pest control company license copy
• Landscaping vendor license copy (if they apply pesticides)
• In-house applicator license copies (if applicable)

Product Documentation

• Labels for all indoor-use products
• Labels for all outdoor-use products
• Indoor chemical list matches products in binder (all five columns complete)
• Outdoor chemical list matches products in binder (all five columns complete)

Maps

• Outdoor pest location map (current, showing Turf / Landscaping / Outdoor Grounds)

Monitoring Records

• Indoor monitoring logs (current year and 4 prior years)
• Outdoor monitoring logs (current year and 4 prior years)
• Pest sighting reports from staff

Service Documentation

• All pest control service reports filed
• Corrective action tracker current
• All actions have completion dates or open status

Pesticide Application Records

• Indoor application records (if any)
• Outdoor application records with notification packets
• Posting logs for outdoor applications

Emergency Documentation

• Emergency waiver requests and justifications (if any)

Resources

State Requirements

• 333 CMR 14.00 Regulation: mass.gov/regulations/333-CMR-1400
• MDAR Consumer Information Bulletin: mass.gov/doc/community-information-bulletin-schools

Templates and Tools

• MassNRC Standard Written Notification Form: massnrc.org/ipm/docs/standard_written_notification.pdf
• MassNRC IPM Plan Maker: massnrc.org/ipm/schools-daycare/ipm-tools-resources/ipm-plan-maker

Commercial IPM Services

• PESTalytix Integrated Pest Management