23R1007_Attachment 1 IPMP_.pdf

FINAL

INTEGRATED PEST MANAGEMENT PLAN

FOR

FORT KNOX, KENTUCKY

November 2016

Digitally signed by

INTEGRATED PEST MANAGEMENT PLAN FOR FORT KNOX

Prepared by: CPT Tosha Nichols, Environmental Science Engineering Officer, Environmental Management Division, Fort Knox

Reviewed by: Signature Date

Mr. Michael Brandenburg

Chief, Natural Resources Branch

Fort Knox, Kentucky

Gildelbrandt Martinez, 1LT

Chief, Environmental Health Services

Ireland Army Community Hospital

Mr. Patrick A. Walsh

Director, Public Works

Fort Knox, Kentucky

Technical Approval by:

Dr. William Miller

Army Environmental Center

Joint Base San Antonio, TX

Approved by:

Stephen K. Aiton, COL

Garrison Commander

Fort Knox, KY

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INTEGRATED PEST MANAGEMENT PLAN

FOR

FORT KNOX, KENTUCKY

TABLE OF CONTENTS

SECTION PAGE

EXECUTIVE SUMMARY ................................................................................................................................. vi

1 BACKGROUND

1.1 PURPOSE

1.2 AUTHORITY

1.3 PLAN MAINTENANCE

2 RESPONSIBILITIES

2.1 GARRISON COMMANDER, US ARMY GARRISON – FORT KNOX

2.2 DIRECTORATE OF PUBLIC WORKS (DPW)

2.3 DIRECTORATE OF PUBLIC WORKS, ENVIRONMENTAL MANAGEMENT DIVISION, FORT KNOX

2.4 INSTALLATION PEST MANAGEMENT COORDINATOR (PMC)

2.5 CONTRACTED AND NON-CONTRACTED PEST MANAGEMENT PERSONNEL

2.6 CONTRACT OFFICER’S REPRESENTATIVE (COR) FOR PEST MANAGEMENT CONTRACTS

2.7 QUALITY ASSURANCE EVALUATORS FOR PEST MANAGEMENT CONTRACTS (QAE)

2.8 FORT KNOX TENANTS

2.9 BUILDING OCCUPANTS

2.10 INSTALLATION SAFETY OFFICE

2.11 ENVIRONMENTAL HEALTH SERVICES

3 INTEGRATED PEST MANAGEMENT PLAN (IPM)

3.1 LEGAL MANDATE

3.2 IPM OPERATIONS

4 PEST MANAGEMENT PRIORITIES

4.1 PUBLIC HEALTH PESTS

4.2 STRUCTURAL PESTS

4.3 STORED PRODUCT PESTS

iv

4.4 ORNAMENTAL PLANT AND TURF PESTS

4.5 UNDESIREABLE VEGETATION

4.6 VERTEBRATE PESTS

4.7 HOUSEHOLD AND NUISANCE PESTS

4.8 QUARANTINE PESTS

4.9 OTHER PEST MANAGEMENT REQUIREMENTS

5 HEALTH AND SAFETY

5.1 MEDICAL SURVEILLANCE OF PEST MANAGEMENT PERSONNEL

5.2 HAZARD COMMUNICATION

5.3 PERSONAL PROTECTIVE EQUIPMENT (PPE)

5.4 PEST MANAGEMENT VEHICLES

5.5 TRANSPORTING PESTICIDES

5.6 MATERIAL DATA SAFETY SHEETS/ SAFETY DATA SHEETS

5.7 PROTECTION OF THE PUBLIC

6 ENVIRONMENTAL CONSIDERATIONS

6.1 SENSITIVE AREAS

6.2 ENDANGERED/PROTECTED SPECIES AND CRITICAL HABITATS

6.3 ENVIRONMENTAL DOCUMENTATION

6.4 PESTICIDE SPILLS AND REMEDIATION

6.5 POLLUTION CONTROL AND ABATEMENT PROJECTS

6.6 PESTICIDE DISPOSITION

6.7 PROHIBITED ACTIVITIES

6.8 PESTICIDE REDUCTION

7 PROGRAM ADMINISTRATION

7.1 PEST MANAGEMENT OPERATIONS

7.2 BLANKET PURCHASE AGREEMENTS (BPA)

7.3 CONTRACTOR REQUIREMENTS

7.4 INTERSERVICE SUPPORT AGREEMENTS (ISA) AND MEMORANDUMS OF AGREEMENT (MOA). 14

7.5 AGRICULTURAL OUTLEASES

7.6 TENANT ACTIVITY SUPPORT

v

7.7 MATERIALS AND EQUIPMENT

7.8 FACILITIES (MIXING AND STORAGE SITE)

7.9 REPORTS AND RECORDS

7.10 TRAINING AND CERTIFICATION

7.11 PESTICIDE SECURITY

7.12 COORDINATION – DOD, OTHER FEDERAL, STATE, AND LOCAL

7.13 DESIGN REVIEW OF NEW CONSTRUCTION

7.14 FIVE-YEAR PLAN

8 SALE AND DISTRIBUTION OF PESTICIDES

9 REGULATED PESTS

10 PEST MANAGEMENT REFERENCES

10.1 FEDERAL AND STATE LAWS

10.2 DOD DIRECTIVES

10.3 ARMY REGULATIONS AND PUBLICATIONS

10.4 TECHNICAL MANUALS, BULLETINS, AND HANDBOOKS

10.5 ARMED FORCES PEST MANAGEMENT BOARD TECHNICAL INFORMATION MEMORANDUMS ... 19

10.6 WEBSITE AND ONLINE DOCUMENTS

APPENDICES

A – Integrated Pest Management Outlines ............................................................................................... A-1

B – Annual Plan Update Form (PUF; Optional for AEC) .............................................................................B-1

C – Installation Points of Contact...............................................................................................................C-1

D – Five-Year Plan ..................................................................................................................................... D-1

E – Small Animal Control (Standard Operating Procedure) ....................................................................... E-1

F – Memorandum of Agreement (Stray Animals)...................................................................................... F-1

G – Zika Virus Surveillance ........................................................................................................................ G-1 vi

EXECUTIVE SUMMARY

SITE. Fort Knox’s primary military mission is to develop leaders and train soldiers for the armed forces. Officers and enlisted personnel are trained and equipped to ensure assigned combat readiness posture. The Center controls, coordinates, and prepares administrative and logistical support plans for mobilization forces and missions. Fort Knox provides training, administrative and logistics facilities, and support as required for United States Army Reserve units, Army

National Guard units, and Reserve Officers’ Training Corps (ROTC) activities within the assigned geographical area.

SCOPE. The contents of this Integrated Pest Management Plan (IPMP) apply to all activities and individuals working, residing, or otherwise doing business on Fort Knox.

OVERVIEW. Federal Agencies are mandated by Public Law (Section 136 r-l of title 7, United

States Code) to use Integrated Pest Management (IPM). This IPMP for Fort Knox describes past and anticipated pests and outlines the resources necessary for surveillance and control of these pests including any administrative, safety, or environmental requirements. The program uses certified Government and contract pest management technicians to control pests.

RESPONSIBILITIES. The Fort Knox Pest Management Coordinator (PMC) oversees the program. Pest prevention, through good sanitation practices, is the responsibility of all individuals that occupy or maintain buildings or open spaces on the installation. Pest management personnel will follow the Integrated Pest Management Outlines located in

Appendix A of this document. Before any pesticides are applied, non-chemical control efforts will be used to the maximum extent possible. At no time will pest management operations be done in a manner that may cause harm to personnel or the environment.

IMPACT. Without an IPM program for Fort Knox, pests can interfere with the military mission, lower morale, damage real property, increase maintenance costs, and potentially expose installation personnel to disease.

PEST MANAGEMENT COMPONENTS. Major aspects of the pest management program are addressed in the plan and deal specifically with administration, pest surveillance, storage and handling locations of pesticides, and pest control are addressed in the plan.

MAINTENANCE. This plan is a working document that is updated annually. Please send comments or suggested changes to:

Pest Management Coordinator (Acting): Mr. Michael Brandenburg

Mailing Address:

Environmental Management Division, Building 9297 4916 Wilson Rd, Fort Knox, KY 40121

Office Phone Number: 502-624-7368

FAX Number: 502-624-1868

Email Address: Michael.G.Brandenburg2.civ@mail.mil mailto:Michael.G.Brandenburg2.civ@mail.mil

1 BACKGROUND

1.1 PURPOSE

Integrated Pest Management (IPM) is a sustainable approach to managing pests by combining biological, cultural, physical, mechanical, and chemical tools in a way that minimizes economic, health, and environmental risks. This plan is a framework through which an IPM program is defined and accomplished on the installation. It describes program elements including health and environmental safety; pest identification; pest management methodologies; and pesticide storage, transportation, use and disposal. This Integrated Pest Management Plan (IPMP) is a guide to reduce reliance on pesticides, to enhance environmental protection, and to maximize the use of integrated pest management techniques. It reflects current Department of Defense (DoD)/Army policies, procedures and standards and incorporates the requirements of the Environmental Protection Agency (EPA), and the State of Kentucky.

1.2 AUTHORITY

This IPMP is written under the authority of:

a. Section 136 et seq. of title 7, United State Code, Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) as amended.

b. DOD Instruction 4150-7, DOD Pest Management Program, 29 May 2008.

c. AR 200-1, Environmental Protection and Enhancement, 13 December 2007

1.3 PLAN MAINTENANCE

The Fort Knox Pest Management Coordinator (PMC) maintains this IPMP. While pen and ink changes are made to this plan throughout the fiscal year, this plan is reviewed and updated annually to reflect all changes made in the pest management program during each fiscal year.

The Annual Plan Update Form (PUF; Appendix B) is recommended for use by the Army Environmental Command (AEC) to help streamline the plan update process, but is not mandated. Annual updates of this plan are sent to the AEC Pest Management Consultant (AEC- PMC) not later than 30 October of each year by the PMC. Annual updates to the plan should be submitted using the AEC website.

2 RESPONSIBILITIES

2.1 GARRISON COMMANDER, US ARMY GARRISON – FORT KNOX

a. Designate an Installation Pest Management Coordinator (PMC) for all pest management activities.

b. Approve and support the pest management plan.

c. Ensure that all pest management operations are conducted safely and have minimal impact on the environment.

d. Ensure that installation personnel performing pest management functions receive adequate training and achieve pest management or Quality Assurance Evaluator (QAE) certification as required.

e. Provide adequate resources for the proper implementation of this plan.

2.2 DIRECTORATE OF PUBLIC WORKS (DPW)

a. Obtain and maintain adequate supplies of pesticides and pesticide application equipment.

b. Coordinate training and pest management certification for Fort Knox personnel performing pest management and ensure contractors performing pest management are properly trained and certified.

c. Maintain and forward records of pest management operations per guidance of the PMC.

d. Coordinate all pest management contracts through the PMC to ensure regulatory compliance.

2.3 DIRECTORATE OF PUBLIC WORKS, ENVIRONMENTAL MANAGEMENT DIVISION,

FORT KNOX

a. Provide administrative liaison between the Pest Management Program and Fort Knox activities.

b. Assist the Pest Management Program in abiding by environmental requirements.

2.4 INSTALLATION PEST MANAGEMENT COORDINATOR (PMC)

a. Determine the pest management requirements for Fort Knox.

b. Annually update the IPMP.

c. Coordinate pest management activities between Fort Knox and AEC.

d. Gather pest management relevant information (e.g. pesticide use on the installation), report requested information to AEC on an annual basis (e.g. Pesticide Use Proposal;

PUP), and provide answers to questions concerning pest management from AEC.

e. Submit all pest management contracts to AEC for review and approval.

f. Maintain current pest management coordinator training.

g. Ensure that installation and contractor personnel performing pest control are certified, as required.

h. Coordinate with local, State, and Federal agencies, as necessary, to conduct the installation’s pest management program.

i. Maintain adequate records of pesticide application, contracts, and a list of all trained and certified personnel on the installation.

2.5 CONTRACTED AND NON-CONTRACTED PEST MANAGEMENT PERSONNEL

a. Use integrated pest management techniques to the maximum extent possible; as outlined in Appendix A of this document.

b. Control pests according to the provisions of this plan.

c. Operate pesticide applicators in a manner that minimizes risk of contamination to the environment and exposure to personnel.

d. Provide written records of pest surveillance and control efforts to the PMC.

e. Maintain State/DoD certification and provide written records of technician certification status annually or as changes in status occur to the PMC.

f. Coordinate with law enforcement and/or veterinary officials in handling suspicious wild or domestic animals on post.

2.6 CONTRACT OFFICER’S REPRESENTATIVE (COR) FOR PEST MANAGEMENT

CONTRACTS

a. Coordinate with and supply documentation of pesticide usage to the PMC.

b. Oversee contract pest management operations to ensure specifications are met.

c. Ensure that pest management contract specifications refer to, or are based upon, specific IPM procedures detailed in Appendix A.

d. Modify pest management contract specifications if they do not to incorporate the latest, most effective and least toxic IPM methodologies, in coordination with the QAE and

PMC.

e. Coordinate with the PMC to ensure that contractor applied pesticides have been approved and that they are detailed on the annual PUP. The PUP is located in the PMC’s office (BLDG 9297).

2.7 QUALITY ASSURANCE EVALUATORS FOR PEST MANAGEMENT CONTRACTS

(QAE)

a.

b. Evaluate contract pest management operations to ensure contract specifications are met.

c. Evaluate the functions or tasks of the contract pest managers while in progress to ensure that effective integrated pest management services are being provided.

d.

e. Notify COR and PMC of changes needed or deviations observed regarding pest management operations.

f. Monitor pest management contract operations for compliance with health, safety, and environmental standards.

g. Document results of the evaluation criteria for contract pest management operations.

2.8 FORT KNOX TENANTS

a. Coordinate with the PMC regarding any planned pest management services or contracts.

b. Abide by the principles of the Fort Knox IPMP, ensuring that personnel conducting pest management are certified to transport, handle, and apply pesticides in a safe manner.

2.9 BUILDING OCCUPANTS

a. Apply good sanitary practices to prevent pest infestations.

b. Use practical nonchemical pest management techniques prior to requesting assistance from DPW.

c. Cooperate with DPW personnel and contractors in scheduling pest management operations, including preparing the areas to be treated.

2.10 INSTALLATION SAFETY OFFICE

a. Provide safety and occupational health guidance to pest management personnel.

b. Coordinate HAZCOM, DOT, and other training as appropriate for pest management personnel.

1 for the appropriate pest categories.

Obtain training and certification in accordance with DoD Instruction 4150.7 and AR 200-

Monitor type, concentration, and application method of pesticides used by contractor.

c. Evaluate the pest management operations adherence to safety and occupational health standards.

d. Provide respirator fit testing to DoD certified pesticide applicators.

2.11 ENVIRONMENTAL HEALTH SERVICES

a. Conduct surveillance for pests which could adversely affect the health and welfare of installation occupants and report results to appropriate parties.

b. Coordinate with local health officials to determine the prevalence of disease.

c. Evaluate the health aspects of the pest management program.

d. Document results of all evaluations and health inspections; provide a copy to PMC and appropriate service managers.

3 INTEGRATED PEST MANAGEMENT PLAN (IPM)

3.1 LEGAL MANDATE

Federal Agencies are mandated by Public Law to use Integrated Pest Management (IPM). IPM is a sustainable approach to managing pests by combining biological, cultural, physical, and chemical tools in a way that minimizes economic, health, and environmental risks. The AEC is committed to IPM at its facilities and installations as the best approach to control pests and reduce pesticide reliance and resistance.

3.2 IPM OPERATIONS

Although IPM emphasizes the use of non-chemical strategies, chemical control may be an option when used in conjunction with other methods. The IPM Outlines (Appendix A) describe methods for detecting, monitoring, and controlling specific pests. The annual Pesticide Use Proposal (PUP) lists all the pesticides Fort Knox intends to use during the upcoming calendar year. It is a working document and can be reviewed at any time by contacting the PMC. The PUP will include pesticide names, active ingredients and percentages, EPA registration numbers, label signal words, target pests, and intended sites. Department of Defense (DoD) policy mandates that professional pest management personnel approve all pesticides applied to DoD installations. New pesticides lists will be submitted through the PMC and/or AEC or appointee for approval before application.

4 PEST MANAGEMENT PRIORITIES

4.1 PUBLIC HEALTH PESTS

Mosquitoes. While mosquitoes are potentially medically important pests, their impact on Fort Knox has been minimal to date. Over twenty different mosquito species are found on Fort

Knox. Several mosquito species found have the potential to transmit several diseases including Eastern Equine Encephalitis, St. Louis Encephalitis, and West Nile Virus. Fort Knox is known to have Aedes albopictus mosquitoes, which could possibly transmit the Zika Virus. Appendix G of this document outlines mosquito surveillance, testing, and control.

Ticks. Ticks and tick-borne diseases are well documented on Fort Knox. The important tick species include the Black-legged tick (Ixodes scapularis) which can carry Lyme disease and Human Ehrlichiosis, and the American dog tick (Dermacentor variabilis) which can transmit Rocky Mountain spotted fever. The most prevalent tick species is the Lone Star tick (Amblyomma americanum), which can carry Human Monocytic Ehrlichiosis and Rocky Mountain spotted fever. Preventive and protective measures are stressed though public education by the Fort Knox medical personnel, primarily through Environmental Health Services. During the summer months, surveillance efforts are made to monitor tick populations. Only when significant populations occur should treatments be made. The use of non-chemical control measures such as consistent mowing and habitat reduction can significantly reduce tick populations.

Bees and Wasps. Bees and wasps are found throughout Fort Knox. The stings are painful and can illicit serious allergic responses in some individuals. These insects are most prevalent during late summer and fall at Fort Knox. Treatment for bees and wasps is accomplished through contractors and/or self-help efforts.

Filth Flies. Filth flies have created problems during the warm months in the past. Most are directly related to sanitation deficiencies.

Spiders. Spiders can be found in undisturbed places, outdoor storage areas, below-grade utility access, and in and around other buildings and structures. The Brown recluse spider (Loxosceles recluse) is native to the area, however, it and other venomous spiders having medical importance are rare, so other potential sources of alleged “spider bite” wounds such as ring worm or community-acquired methicillin-resistant Staphylococcus aureus (MRSA) should be considered. Medical attention should be sought following any suspected spider bite. Spiders are controlled by sanitation, physical exclusion, and reducing their food source (other insects).

Fleas. Fleas are also medically important because they serve as vectors of disease and act as intermediate hosts of certain tapeworms that may be parasitic to humans. Fleas can be annoying to humans due to their blood sucking habits, which may produce dermatitis (inflammation of the skin) in hypersensitive individuals.

Commensal rodents. Mice and rat populations are of concern due to their potential for harboring disease and causing damage to both facility structures and their contents. There are a number of diseases that can be transmitted to humans through rodent activity. These include, but are not limited to: Plague, Leptospirosis, Salmonellosis, Lymphocytic Choriomeningitis, Rickettsial Pox, Rat Bite Fever, Tapeworms, Tetanus, and Hantavirus. Most of these diseases are transmitted to humans via rodent bites or through contact with surfaces, soils, water, or food contaminated with infected rodent feces and/or urine.

4.2 STRUCTURAL PESTS

Termites. Subterranean termites may cause damage to wooden buildings and other structures on the installation. Surveys of wooden structures and treatment, when termites are found, have kept damage to a minimum. All new construction will meet Corps of Engineer design standards for termite pre-treatment. Carpenter ants and carpenter bees also invade wooden structures, particularly where wet conditions exist.

Commensal rodents. Mice commonly damage buildings or structures as a result of their attempts to gain entry, reach stored foods, or create a nest or den. Their efforts often result in widened openings where pipes or wires pass through exterior walls. Within buildings, rats and mice will enlarge existing openings or create new ones in walls, doors, cabinetry, and furniture.

Mice frequently nest around stationary electrical appliances, damaging wires and affecting appliance performance. Odors from feces and urine are generally offensive to most people, as is any destruction of personal property. Rodent control is periodically required in and around the various buildings located on site.

4.3 STORED PRODUCT PESTS

Food items stored in food service locations, the Post Exchange and Commissary, and other areas may become infested by stored products pests. Occasional complaints are received from family housing residents, but insect infestations usually originate in the home. “First in, first out” rotation procedures for infestible commodities which have been instituted have substantially reduced the probability that goods become infested while in storage at Fort Knox. However, some goods may be pre-infested at the production source. These include: saw-toothed grain beetles, red flour beetles, carpet beetles and other dermestids. Warehouse invaders such as raccoons, rats, mice, and pest birds can also have economic and health impacts.

4.4 ORNAMENTAL PLANT AND TURF PESTS

Trees and shrubs on Fort Knox can be infested by various insect pests, resulting in damage or destruction of the plants. Tent caterpillar populations cyclically increase to levels that have caused tree defoliation in the past. Hemlock Woolly Adelgids are present in Kentucky and may present a problem on Fort Knox. Pests which damage lawns and recreational grass areas (ball field) do cause damage and require continuing surveillance and control.

4.5 UNDESIREABLE VEGETATION

Weeds along fence lines, on road shoulders, on paved surfaces, along decorative perimeter walls, and on turf associated with the lawns of the Fort Knox and the family housing areas require control using appropriate herbicides. Some control of unwanted plants is done mechanically (e.g., mowing, string trimmers). Several noxious weeds and exotic invasive plants are found on Fort Knox requiring control measures when problems are identified and resources available. A list of noxious weeds in Kentucky may be found at the United States Department of Agriculture: Natural Resources Conservation Service website (Reference 10.8.b)

4.6 VERTEBRATE PESTS

Stray dogs and cats are occasionally reported at Fort Knox. Stray animal control is accomplished by Knox Hills LLC or the Provost Marshal. Appendix E is the Directorate of Emergency Services Annex 52: Standing Operating Procedure (SOP) #54 Small Animal Control. This SOP outlines the procedures and responsibilities for the Desk/Patrols regarding pest control on Fort Knox. Appendix F is the Memorandum of Agreement (MOA) (Stray Animals) between Knox Hills LLC and Hardin County, Kentucky. Knox Hill LLC is responsible for the transportation of any stray, or abandoned dogs or cats to a designated Hardin County Animal Shelter. The MOA outlines the responsibilities of both parties.

As mentioned above, raccoons can cause damage to stored food products and occasionally invade offices and barracks. When vertebrate pests infest a structure exclusionary efforts should be made to prevent future infestations. When animals enter a structure, live traps are used to capture and remove the animal for relocation to a natural area on the installation.

Nuisance birds do exist at Fort Knox. Pigeons, starlings, and house sparrows roost under building eves and around areas where food is an attractant. Barn swallows nesting in building entry ways are a continuing problem. Exclusionary tactics are made to keep bird pests from infesting structures.

4.7 HOUSEHOLD AND NUISANCE PESTS

Crawling insects (e.g., ants, cockroaches, crickets, ground beetles, earwigs, centipedes, millipedes, and silverfish) and spiders may require control in billets, family housing, food service facilities, warehouses, and offices. The pests in this category constitute minor pest problems on the installation. Proper sanitation and housekeeping will do much to discourage these pests.

4.8 QUARANTINE PESTS

Emerald Ash Borer (Agrilus planipennis) is a potential quarantine pest. Currently it is quarantined for the majority of New England states and has been identified in several counties in Northern Kentucky. This pest is the cause of widespread ash (Fraxinus spp.) tree decline and mortality. Hemlock Woolly Adelgid (Adelges tsugae) is also a potential quarantine pest for Fort Knox. Currently Active populations have been observed in the southeastern portion of Kentucky. This pest is a small, aphidlike insect that threatens the health and sustainability of eastern hemlock (Tsuga canadensis) and Carolina hemlock (Tsuga caroliniana) in the Eastern United States.

4.9 OTHER PEST MANAGEMENT REQUIREMENTS

Provost Marshall or DPW Personnel are responsible for large animal carcass removal.

Removal of small animal carcasses in the Knox Hills housing areas is the responsibility of Knox Hills Maintenance. The carcass will be either taken to the Kentucky Board of Health if being tested for pathogens or properly disposed of.

the process of hazard communication.

(including contractors) for pesticides used that day and with all other organizations involved in handled. Copies of labels and MSDS/SDS’s are to be kept on each pest control vehicle Additionally, labels and MSDS/SDS’s are kept in each facility where pesticides are stored or toxic substances used in the pest management program can be found in the PMC office.

into the workplace. Material Safety Data Sheets/ Safety Data Sheets for all pesticides and other additional training is given to new employees or when new hazardous materials are introduced hazardous materials in the workplace. Following initial hazard communication classes, Installation pest management personnel are given hazard communication training, including

5 HEALTH AND SAFETY

5.1 MEDICAL SURVEILLANCE OF PEST MANAGEMENT PERSONNEL

Medical surveillance for Fort Knox golf course and Natural Resource Branch pesticide applicator personnel is coordinated by the Fort Knox Safety Office Industrial Hygienist, and provided by the Ireland Army Community Hospital. Medical surveillance for Fort Knox personnel includes a physical examination and various tests to determine suitability for pesticide application and to monitor exposure to pesticides. Rabies prophylaxis is provided to employees with potential occupational exposure. Personnel that require respirators are monitored under the respiratory protection program and a respirator fit test is administered. Medical surveillance of contracted pest management personnel is the responsibility of their employer. Pest management contracts specify this requirement and provide minimum standards of acceptance for operators on Fort Knox.

5.2 HAZARD COMMUNICATION

All Fort Knox pest control personnel shall be provided access to all appropriate health and safety information pertaining to pesticide use at the installation. The following items are made available for use and review at the Directorate of Public Works: Fort Knox Integrated Pest Management Plan, copy of Fort Knox Hazard Communication Program, copies of all labels and Material Safety Data Sheets (MSDS)/ Safety Data Sheets (SDS) of pesticides currently used at the installation.

5.3 PERSONAL PROTECTIVE EQUIPMENT (PPE)

Approved masks, respirators, chemical resistant gloves and boots, and protective clothing, will be worn by all personnel exposed to pesticides in accordance with the requirements set forth in the Federal Insecticide, Fungicide, and Rodenticide Act (40 CFR 162), Occupational Safety and Health Administration Standards (29 CFR 1910), DoD Directive 4150.7, Army Regulation 200-1, and individual pesticide labels. Pest management contractors are to provide all employees with required PPE. Any contaminated items are to be disposed of according to the contaminants label. Due to the awareness of human disease risks that can be associated with rodents and rodent waste (hantaviruses; hantavirus pulmonary syndrome), emphasis is placed on using the appropriate respiratory protection, specifically N95 rated filter cartridges, when pest management is necessary in enclosed areas that may be rodent infested. Additional protective

Additionally, MSDS/SDS’s are kept in BLDG 117 and 4011 toxic substances used in the pest management program can be found in the pest management Material Safety Data Sheets (MSDS)/ Safety Data Sheets (SDS) for all pesticides and other measures are followed (e.g., using disposable gloves while disposing of trapped rodents, disinfection measures).

5.4 PEST MANAGEMENT VEHICLES

Pest Control Operators on Fort Knox will comply with Kentucky and EPA regulations regarding marking and placarding of vehicles. Government vehicles used for transporting materials to and from job sites are not required to be placarded unless the quantity of pesticide concentration(s) exceed 55 gallons. Currently this quantity is not used, however, in such cases appropriate placards will be utilized. To avoid damage to pesticide containers and prevent spillage, all chemicals are secured within the storage compartments. At no time will pesticides be left unsecured or in an unattended vehicle. Pesticides or contaminated equipment are never transported in the passenger compartment of any vehicle. Every vehicle will be equipped with a portable eye lavage, spill kit, product MSDS, label, and two-way mobile communications are carried in each vehicle when in use. Under no circumstances are these vehicles used for any purpose other than pest management. These vehicles are identified as being pesticide contaminated. Any contractor pest management vehicles used on post will follow the same procedures as stated above.

5.5 TRANSPORTING PESTICIDES

Any personnel transporting bulk pesticides off post must complete training a 16 hour Department of Transportation level VIIB class on the transport of regulated hazardous materials.

All safety precautions should be taken when pesticide vehicles are in motion, regardless of location.

5.6 MATERIAL DATA SAFETY SHEETS/ SAFETY DATA SHEETS

office in Building 9297. All employees have continuous access to the MSDS/SDS’s. Personnel who work with these chemicals are informed of the potential hazards and trained in the use of personal protective equipment.

5.7 PROTECTION OF THE PUBLIC

Precautions are taken during pesticide application to protect the public, on and off the installation. Pesticides are not applied outdoors when the wind speed exceeds five miles per hour when spraying near sensitive areas such as housing, hospitals, and office buildings;

otherwise label restrictions will dictate at what wind speeds a pesticide may be applied.

Whenever pesticides are applied outdoors, care is taken to make sure that any spray drift is kept away from non-target areas and individuals, to include the applicator. Pesticide application indoors is accomplished by individuals wearing proper personal protective clothing and equipment. At no time are personnel permitted in a treatment area during pesticide application unless they have met the medical monitoring standards and are appropriately protected.

where pesticides are stored.

DOD Pest Management rules do not apply to persons living in Quarters they are assigned to and treating with over the counter products they have obtained for their own "relief". Persons that buy and utilize pesticide products are required to read, understand and follow the label.

Most products have a statements that read "Apply this product only as specified on this label” and "It is a violation of Federal law to use this product in a manner inconsistent with its labeling."

Certain products like foggers should be prohibited in multiplex type structure with regard to potentially exposing adjacent neighbors to hazardous materials. Occupants living in Quarters should read and understand their contract or resident guidelines as it pertains to the use of pesticides.

6 ENVIRONMENTAL CONSIDERATIONS

6.1 SENSITIVE AREAS

6.1.1 OUTDOOR

Several ball fields and playground areas are located on Fort Knox. Pesticides will not be used in or around these areas unless all other options have been exhausted and appropriate placarding will be posted regarding application and safe reentry times.

6.1.2 CHILD DEVELOPMENT CENTERS

Pesticides will not be used in or around the child development centers unless all other options have been exhausted, and/or with special permission from the Army Environmental Command.

Consideration is being made to become IPM STAR certified by the IPM Institute of North America, or equivalent, should a certifying program become established within the DoD.

6.1.3 HEALTH CARE FACILITIES

Pesticides applied in patient areas of the hospital are used in strict conformance with the pesticide label.

6.2 ENDANGERED/PROTECTED SPECIES AND CRITICAL HABITATS

Fort Knox and the immediate surroundings provide suitable habitat for certain endangered species, species that are candidates for federal T&E listing, state threatened and state species of special concern.

Protected migratory birds which occur on Fort Knox facilities cannot be controlled without a permit. The PMC periodically evaluates ongoing pest control operations and will evaluate all new pest management operations to ensure compliance with the Endangered Species Act and Migratory Bird Treaty Act. No pest management operations will be conducted that are likely to have a negative impact on endangered or protected species or their habitats without prior approval from the Fort Knox DPW Environmental Management Division and the U.S. Fish and Wildlife Service (USFWS). The Fort Knox installation habitats have been inventoried for rare, threatened, or endangered species. An Integrated Natural Resources Management Plan and Endangered Species Management Plans have been prepared for the installation. Endangered

Species Management Plans have been prepared for the gray bat, Indiana bat, northern cavefish, cave crayfish, Bald Eagle, Henslow’s sparrow, and the cerulean warbler. When outdoor pesticide applications are planned in unimproved/wilderness areas, the Natural Resources Branch of the DPW Environmental Management Division is consulted for information on potential impact on any endangered or protected species and habitat. In turn, USFWS, and the Kentucky Department of Fish and Wildlife Resources are consulted whenever a proposed pest management activity could potentially be detrimental to protected, rare, threatened, or endangered species or environmentally sensitive or critical areas.

6.3 ENVIRONMENTAL DOCUMENTATION

In accordance with 32 CFR 651.10, an Environmental Assessment (EA) was prepared for the implementation of the Integrated Pest Management Plan dated 1 December 2005 and a finding of no significant impact signed by the Garrison Commander 17 March 2006. As there is no significant potential effects to the human and natural environment from the update of this plan, a Record of Environmental Consideration will be prepared.

6.4 PESTICIDE SPILLS AND REMEDIATION

Pesticide spill cleanup kits are maintained in the BLDG 117 pesticide storage facility, BLDG 116 mixing facility, BLDG 9297D mixing facility, Lindsey Golf Course BLDG 4011 mixing facility, and on pest management vehicles. Additional information on pesticide spills can be found in AFPMB TIM 15 (Reference 10.6.b). Any pesticide spill shall be reported to the Fort Knox Fire Department (phone: 624-6016/1876) and the Environmental Management Division (phone:

624-3629/4654).

6.5 POLLUTION CONTROL AND ABATEMENT PROJECTS

There are currently no pesticide related pollution control or abatement projects at Fort Knox.

6.6 PESTICIDE DISPOSITION

Improper or careless disposal of pesticides are common causes of pesticide misuse and environmental contamination. Consequently, many pesticides have specific disposal requirements imposed by federal, state, and DoD regulations, such as the Federal Resource Conservation and Recovery Act (RCRA) and Army Regulation AR 200-1. Disposal requirements are normally contained on the product label. Adherence to these requirements is the law. Following these procedures is the responsibility of all personnel applying or handling pesticides.

6.7 PROHIBITED ACTIVITIES

a. A pesticide will not be used in any manner that is inconsistent with its label.

b. Herbicides will not be used to control weeds at the child development centers or in areas where children play.

c. No pesticide will be used whose registration has been suspended or cancelled by the EPA or the Commonwealth of Kentucky.

d. Pesticide misuse, which includes use inconsistent with the label, is a violation of Federal Law. Fort Knox personnel will record and report any instances of pesticide misuse and falsification of records by contractors to the Commonwealth of Kentucky. Furthermore, Fort Knox personnel will cooperate with Kentucky regulators and the EPA in any subsequent investigation or actions.

6.8 PESTICIDE REDUCTION

Contracting pesticide applicators will employee IPM techniques and exhaust control measures with the least impact on the environment prior to application of pesticides. Following an IPM plan encourages a reduction in pesticide usage.

7 PROGRAM ADMINISTRATION

7.1 PEST MANAGEMENT OPERATIONS

Pest management operations are conducted IAW Appendix A (IPM Outlines) and the Pesticide Use Proposal (PUP).

Fort Knox pest management operations are performed from a mixture of DoD certified applicators and contracting companies. The following chart illustrates areas of responsibility and the corresponding service providers.

Area of Responsibility Service Provider NAF - Lindsey Golf Course DoD certified applicator – Golf Course

Forestry/Wildlife DoD certified applicator – Natural resources Branch

Garrison Cantonment Various contractors

Fort Knox Schools IPM Services/ staff applicators(herbicides)

Grounds/Ranges Herbicides Source America

Family Housing Various Contractors

Termite Pretreatments Various contractors

Sewer Plant perimeter Various Contractors

7.2 BLANKET PURCHASE AGREEMENTS (BPA)

Currently no Blanket Purchase Agreements for pest management related work are established.

However, consideration is being made to change several existing contracts to BPA’s.

7.3 CONTRACTOR REQUIREMENTS

Contractors who conduct pest control at Fort Knox must:

a. Show proof of liability insurance.

b. Comply with all components of the IPMP and Performance Work Statements (PWS).

c. Have a current Kentucky State commercial certification and licensing in the category or categories of work to be performed for each employee performing pest management operations.

d. Use only EPA and State registered pesticides.

e. Furnish Fort Knox PMC with legible copies of specimen labels and the MSDS/SDS of all pesticides proposed for use.

f. Furnish Fort Knox PMC sufficient information for pest management on DD Form 1532 or equivalent.

g. Apply Pesticides IAW label directions.

h. Follow sound IPM practices with an emphasis on pesticide reduction.

i. Comply with all Federal, State, and local regulations.

j. Mix, store, and dispose of pesticides IAW Federal, State, local regulations, and the provisions of this plan. Minimize need for disposal by reuse of pesticide rinsate.

7.4 INTERSERVICE SUPPORT AGREEMENTS (ISA) AND MEMORANDUMS OF

AGREEMENT (MOA)

Fort Knox supports all organization and tenant activities on its property. ISAs and MOAs exist for this support.

7.5 AGRICULTURAL OUTLEASES

No agricultural out leases currently exist on Fort Knox properties.

7.6 TENANT ACTIVITY SUPPORT

Primary tenant activities supported by the Fort Knox pest management operation include the Post Exchange, medical clinic, ancillary food service locations, barracks dining, schools, and child development centers. Other minor tenants may be supported, as needed. It should be noted that in some cases tenants may contract pest management services without the knowledge of the PMC. Every effort will be made to prevent this and to ensure that all contract pest control services will abide by the Fort Knox IPMP and be monitored by the PMC.

7.7 MATERIALS AND EQUIPMENT

All pesticide stored on the installation will be processed thru the HAZMART, located at BLDG 2953, and stored in approved storage locations. Pesticides are ordered to maintain approximately a three (3) month supply, but not exceeding one year supply. Pesticides which are required for use during a specific time of year are ordered in a timely manner to ensure effective application. Pesticides approved for use are updated annually and listed in PUP.

7.8 FACILITIES (MIXING AND STORAGE SITE)

All Fort Knox pesticides used by Natural Resources Branch are stored and mixed in BLDG 9297D storage/mixing rooms designed for this purpose with appropriate climate control, ventilation and spill containment. The GINN Group and Ft. Knox Schools pesticides are stored in BLDG 117. This building is a separate facility used only for pesticide storage. This facility is constructed of fire resistive materials, has continuous four-inch curbing to contain any spill, epoxy sealant coated floors, and a dedicated ventilation system. Pesticides are stored on non-absorbent shelving or pallets. Sufficient space is provided to allow a clear display of pesticide containers as well as spatial separation between pesticide classes. The Ginn Group and Ft Knox Schools pesticides are mixed in the BLDG 116 mixing facility. This facility has a sealed concrete floor and is outfitted with four-inch curbing and a spill containment reservoir to contain any spill. The room has separate, dedicated ventilation. BLDG 4011 is the storage/mixing facility for use by golf course personnel. These mixing facilities are designed to contain any spill and are equipped with backflow prevention devices to protect potable water sources. Indoor storage and mixing facilities are equipped with compliant ventilation systems. All pesticide storage and mixing facilities maintain a pesticide spill kit. These facilities meet the standards set forth in Military Handbook 1028/8A and the criteria described in 40 CFR 165.

7.9 REPORTS AND RECORDS

7.9.1 DAILY RECORDS

Daily pesticide application and surveillance records are maintained by the certified pest management professional using the Pest Management Maintenance Record (DD Form 1532-1 or equivalent). These forms provide a permanent historical record of pest management operations for each building, structure or outdoor site on the installation. Separate records of daily pest management operations are maintained by DCFA NAF, Integrated Pest Management Services, Inc., other contractors, and PVNTMED SVC personnel. These pesticide use records are forwarded electronically to the installation PMC in the DPW Natural Resources Branch on a monthly basis.

7.9.2 MONTHLY RECORDS

The monthly Pest Management Report (DD Form 1532) is used to summarize and report all pest management operations on the installation. These reports are prepared by the Fort Knox PMC. Completed Pest Management Reports are kept on file by the PMC in the DPW Natural Resources Office in BLDG 9297.

7.10 TRAINING AND CERTIFICATION

Government employees who apply or oversee the application of pesticides are DoD-certified for pesticide application. Certified personnel are recertified every three years. Installation pest management personnel will be certified in the appropriate EPA categories (ornamental and turf pest control (EPA category 3), aquatic pest control (EPA category 5), right-of-way pest control

(EPA category 6), Industrial, institutional, structural and health-related pest control (EPA category 7), public health pest control (EPA category 8), and aerial application (EPA category 11). Contractor personnel performing pest management services on Fort Knox will be certified by the Commonwealth of Kentucky in the appropriate categories for which work is performed.

Fort Knox personnel performing PMC and pest management QAE functions require certification on a three year cycle. A list of certified personnel, along with their certification expiration dates and training certificates can be found in Appendix D. Personnel who are certified in pesticide application will attend pest management classes, workshops, and seminars in order to keep abreast of pest problems and pest management techniques that are unique to the area surrounding the installation. Other personnel who deal directly with pest control operations, but who may not need to be certified, are also encouraged to attend local seminars to better understand the pest management needs of the installation. The QAE for pest management contracts will be DoD-certified in the EPA categories for which pest control work is performed.

7.11 PESTICIDE SECURITY

All vehicles entering the installation are checked and validated by security personnel. Only approved and licensed pesticide applicators (and delivery vehicles) in vehicles marked according to DOT requirements are permitted to carry pesticides on the installation. All pesticide storage facilities are kept locked when not in use, and surrounded by security fencing when possible.

7.12 COORDINATION – DOD, OTHER FEDERAL, STATE, AND LOCAL

The Army Pest Management Program is responsible for protecting personnel and material from illness and damage by pests, wherever in the world they may be. The program includes both medical and operational responsibilities. While these responsibilities do overlap, U.S. Army Medical Command (MEDCOM) focuses on preventing and minimizing medical consequences of pests and pest management operations while the Assistant Chief of Staff for Installation Management and the Army Environmental Command (AEC) concentrate on safe, effective implementation of day to day pest management operations and environmental considerations of pest management operations.

The AEC-PMC have oversight responsibilities for the Fort Knox Pest Management Program.

This includes reviewing the pest management plan, and giving special attention to any operation that: uses restricted use pesticides; uses any pesticide that may significantly contaminate surface or ground water; includes 259 or more hectares (640 acres) in one pesticide application;

may adversely affect endangered or other protected species or habitats; or involves aerial application of pesticides.

Liaison is maintained between the Fort Knox PMC and Preventive Medicine personnel to determine the prevalence of disease vectors and other public health pests in the area surrounding the installation.

Contact is maintained with the Kentucky Departments of Health concerning any pest or arthropod-related health issue (e.g., mosquito, tick, and rodent-borne diseases).

The U.S. Fish and Wildlife Service is consulted whenever any proposed pest management activity may be detrimental to protected, rare, threatened, or endangered species or sensitive areas.

Contact is maintained with the Kentucky Pesticide Regulation and Certification Office to ensure local pesticide use regulations are being met.

The Corps of Engineers (COE) will coordinate with Fort Knox Pest Management Personnel to assure that termite pretreatment of new construction is properly performed and documented.

7.13 DESIGN REVIEW OF NEW CONSTRUCTION

Construction project design specifications shall be reviewed with pest prevention and control in mind. Personnel having pest management knowledge (e.g., engineering, preventive medicine environmental health) should review construction projects prior to completion to ensure that design and architectural features do not allow access or harbor arthropods, rodent, or birds.

New construction should follow industry standard termite pre-treatment procedures; COE construction projects have a standard design requirements for termite treatments. It is recommended that new construction design consider thorough pest exclusion measures to reduce potential future issues. The PMC can provide recommendations as requested by proponent and forward to AEC Pest Management Consultant for review, as required.

7.14 FIVE-YEAR PLAN

Many administrative elements of the program such as recurring and projected requirements are addressed in the five-year plan. This serves as a tool to identify these requirements and propose timeframes for implementation. The five-year plan also helps installation personnel to anticipate program changes and requirements. The five-year plan is found in Appendix D.

8 SALE AND DISTRIBUTION OF PESTICIDES

There is a small self-help program located at BLDG 2954. Minimal records are being kept, however these are not routinely sent to the PMC. Products containing pesticides are sold to pet owners by the Veterinary Clinic. The Commissary and Post Exchange (PX) sell consumer product pesticides. A new enclosed garden center has been built and the majority of garden pesticides are stored here. However, historically overstock items have been stored outside of this area, exposing pesticides to the elements. Plans are being made to minimize end of the season overstock, and to provide a designated location within the enclosed garden center to store excess materials.

9 REGULATED PESTS

There are no requirements for plant or animal quarantine on Fort Knox. Retrograde cargo such as tactical equipment returning from a foreign country is cleared by the USDA, APHIS prior to arriving at Fort Knox. Fort Knox complies with Federal and State noxious weed laws.

Historically noxious weeds have not been a problem on Fort Knox.