There was a time when students who wanted to cheat on tests wrote answers on their palms or created a tiny cheat sheet to slip up their sleeves.
And when messages were exchanged, the modes were whispers or notes passed surreptitiously.
Those moves were fairly easy for a teacher to spot. But now, school officials say, hand-held electronic devices make it possible for students to pass information silently via cell phone text-messaging or faxing, or by using the radio waves or infrared technology in personal digital assistants such as Palm Pilots.
Some of the devices also allow Internet access -- yet another possible avenue to cheating or inappropriate activity, such as viewing Web sites that would otherwise be blocked from students.
This burst of technological development has school officials busy devising policies to regulate gadgets.
But as school directors across the region are finding, it's hard to come up with the right wording to restrict -- but not stifle -- technology that seems to change daily.
A policy that bans specific devices could be outdated as soon as it is printed. In addition, some school officials argue, some of the devices can have legitimate uses in the classroom.
For example, electronic organizers can keep track of homework assignments, and having on-the-spot Internet access for research can be useful. But the line between legitimate and inappropriate uses can be blurry.
While most districts don't allow students to have their cell phones on during classroom hours to prevent disruptions, some cell phones have the same capabilities as electronic organizers.
And while hand-held computers may have legitimate use for such tasks as scheduling and research, some can make and receive phone calls, take digital photos and record sound. That creates opportunity for questionable use.
"There used to be a distinction between cell phones and PDAs," said Peters Township school board member Mark Buzzatto. "Cell phones are to be turned off. But cell phones are turning into PDAs. I can schedule on mine."
Banning all hand-held electronic devices during the school day is one way to deal with the problem. That's what some districts such as McKeesport have done.
But for school officials who are wrestling with a viable policy in Peters, the issue isn't that simple because they don't want to discourage students' use of cutting-edge technology.
"It definitely has potential for abuses in and around the school," said John Hoover, assistant superintendent of Peters schools who is in charge of drafting policy with board members.
"But it's a whole new era that we live in and we know that there are wonderful uses for this technology and we know that our students live very much in a digital world. We want them to be prepared and facile with all of the technology that would be helpful to them."
The fear that "a small number" would use the devices inappropriately creates the need for the policy, Hoover said.
As Peters works to develop a policy, board members are using wording that would ban certain activities and uses of the devices but not outlaw specific devices.
Sharon Fissel, director of policy services for the Pennsylvania School Boards Association, said such an approach makes sense. She said the biggest concerns of school boards have been cheating, the use of inappropriate photographs and the invasion of students' privacy by other students with devices that can photograph and record.
Phones and hand-held gadgets that allow access to the Internet could be used to visit inappropriate Web sites during school hours. Internet-accessible computers provided by the school block such sites.
Some devices have digital picture-taking capabilities that could allow students to photograph tests or sections of tests to share with students who face the same test later in the day.
Hoover also warned that camera phones could be used for inappropriate picture-taking in such places as locker rooms.
That's what happened earlier this year when, according to district court records and police reports, a Moon Area School District wrestler used a camera cell phone belonging to a female student trainer from West Allegheny to take a picture of another wrestler's penis.
"Schools have run into problems when these things are used in a malicious way. The possibilities are endless, and we are trying to prevent those kinds of things," Hoover said.
But at McKeesport High School, despite the ban, the phones were found to be useful in preventing abuse.
Principal Harry Bauman said he was able to discipline a girl who was harassing a boy by wearing a shirt that had a negative message about the boy printed on it.
She wore a coat over the shirt when she was in front of teachers. When she took the coat off, the boy was able to snap a photo of the shirt with his camera cell phone and he took the photo to the principal.
"I was able to discipline the girl for the harassment," Bauman said. "Unfortunately, I had to discipline the boy who used the camera phone as well, though her discipline was much worse."
The Bethel Park School District enacted a policy that allows students to use electronic devices with "instructional or educational purposes" if they have a teacher's permission. Teachers have the authority to limit the types of devices and when and how they may be used.
Bethel Park students are not permitted to use the devices for recording, and students who use them for communication, entertainment or any noneducational purpose will have them confiscated and will face disciplinary action.
Once the student complies with the disciplinary action, parents may pick up the device at the school office.
Spokeswoman Vicki Flotta said the policy has served the district well. "So far, what we have is working for us and, really, our kids respect the teachers' right to limit the usage of these kinds of devices."
Bans on the use of electronic equipment date to 1989 when the state Legislature passed a law barring pagers from school property, school-sponsored functions and buses except for special circumstances, such as students with a sick family member or those who were members of volunteer fire departments.
At the time, school officials complained about pagers interrupting classes and they said they suspected they were being used to set up drug deals.
Following that legislation, a number of districts created policies that banned the possession of cell phones on school property. But most of those districts have eased those policies since the Sept. 11, 2001, terrorist attacks when students found cells phones to be a great comfort because they allowed them to check on the safety of family members.
Now, most districts allow students to carry cell phones, but they must be turned off during school hours.
In the Quaker Valley School District, for example, all electronic devices except for cell phones are banned from school premises. The policy does not include calculators or the laptop computers given to every high school student in the district.
"The thinking," said district spokesman John Hanna, "is that with extracurricular activities, sports, the band and so on, the kids may want to contact someone who's going to pick them up. That sort of thing. But they all are to be turned off during school hours."
To be caught with an unauthorized device in Quaker Valley is considered a level two offense on the district's "Misconduct/Response Structure," somewhere between tardiness, a level one offense, and the distribution of a controlled substance, a level three offense.
But, Hanna said, there is little call for application of the policy because the district doesn't have much of a problem with the devices.
"Since we have individual laptops for all our high school kids, they can do pretty much anything they would need to do, which negates the need for other types of devices they might want to bring in."
Parents of North Allegheny students who want to contact their children while school is in session should call school offices and not dial their youngsters' cell phones, according to the district's administrative rules.
And a student who needs to call home during the school day should use the building's pay phone or an office telephone.
Those are the best ways to avoid running afoul of district regulations covering use of the popular devices.
North Allegheny's school board has not set cellular-phone policies but left it up to administrators and teachers to develop broad rules covering all kinds of communications equipment, according to Joy Ed, the district's manager for communications and public relations.
The wording of the rules in student handbooks differs slightly for each school building, but one principle remains constant: No use of cell phones during the instructional day.
During school hours, use of the phones is banned not only in classrooms but in gyms, halls and auditoriums. Also because some phones have photo capabilities, students are barred from using cell phones at any time in locker rooms.
Students can use them while riding the school bus in the morning and after classes end.
District officials always seek to write general guidelines that will cover changing technology as well as fads and fashions, Ed said.
For example, the ban on cell phones does not extend to Palm Pilots, an electronic organizer, notebook and Rolodex that students use to keep track of things such as homework assignments, she said.
The Woodland Hills School District policy has a strict policy on cell phones. Simply possessing a cell phone is a violation of the student conduct code, according to Pat Dawson, district spokeswoman.
Dawson said the board has not even broached a discussion about hand-held computer devices because the big problem in the district right now is getting kids to leave cell phones at home.
McKeesport's Bauman said he gave his daughter, who attends a neighboring school district, a cell phone specifically so he could keep in touch with her when she stays after school for activities.
"Some of these kids who are heavily involved in activities don't get home until 7 p.m.," he said. "It doesn't seem fair to tell them they can't be in touch with their parents."
Bauman said he sees a day when the McKeesport board might try to revisit its policy and allow some limited use of hand-held computer devices in the classroom.
But he knows that his board will face the same challenges as the Peters board in devising appropriate language.
Peters board President Denise Abraham said at a recent board meeting the task was frustrating.
"This is sort of like herding cats," she said.
Mary Niederberger can be reached at firstname.lastname@example.org , or 412-851-1866. Staff writers Philip Stephenson and Len Barcousky contributed to this report.