36C24618Q9732-006.pdf

ENVIRONMENTAL

MANAGEMENT SERVICE

Ri ch m on d

VA

M C

In te gr at ed P es t M an ag em en t O pe ra tio ns

P la n

Table of Contents

Page

FOREWORD

ACKNOWLEDGEMENTS

1. Summary

2. Scope

3. Common Definitions

4. Responsibilities

5. Procedures

6. Pest Management Issues

7. Administration

8. Health and Safety

9. Public Laws and Regulations

10. Coordination

11. Environmental Considerations

12. References

13. Follow-up Responsibility

14. Review Date

15. Appendices

FOREWORD

The Department of Veterans Affairs (VA) Veterans Health Administration (VHA) requires a comprehensive approach to maintaining an effective Integrated Pest Management (IPM) Program within VHA. As the largest health care provider in the United States and as the primary care provider for Veterans, it is critical that pest management is addressed in a uniform and comprehensive manner. VHA Pest Management Operations Directive requires each VHA facility to have a Pest Management Operation Plan that contains all elements necessary to establish, administer, and maintain a comprehensive IPM Program.

This document contains the basic elements of a pest management operation plan in accordance with VHA Pest Management Operations Directive. Additionally, there are sample modifiable attachments that can be used to assist for accurate record keeping. The plan provides space for spill control, building/campus site plans and bed bug abatement attachments.

This IPM was designed to provide Pest Management Officers at each facility with an easy and efficient means for establishing, documenting and maintaining an effective facility IPM program. The end results in an operation plan to be used as an addendum to the facility’s pest management policy.

ACKNOWLEDGEMENTS

The development of the 2016 Integrated Pest Management Operations Plan Template would not have been possible without the expertise, guidance and dedication of the following individuals.

Jerry Diggs

Chief, Environmental Management Service, Baltimore VAMC

Jahmal Ross Chief, Environmental Services, John D. Dingell VAMC

Dale Hallam

Chief, Environmental Management Service, Sheridan VAMC

Jamie Sanders Environmental Protection Specialist Supervisory, Dayton VAMC

Chelsea Branchcomb

Green Environmental Management Coordinator, American Lake

Valentino Adricula Pest Controller, Milwaukee VAMC

James Smith

Pest Controller, Northern Indiana Healthcare System

Steven Parrish Program Manager, EPS

INTEGRATED PEST MANAGEMENT OPERATIONS PLAN

Richmond VAMC

1. SUMMARY

The Integrated Pest Management Operations (IPMO) Plan contains the elements necessary to establish, administer, and maintain a comprehensive Integrated Pest Management (IPM) Program. The program’s goal is to deliver safe economical controls that are effective in the control of pests. The IPM program utilizes an integrated approach that relies on monitors and traps in combination with increased emphasis on exclusion and traps than have been used in the past. When applicable, the appropriate amounts of pesticide are used to control and mitigate pest problems. The pests of significant concern are ants, stored pantry pests, bed bugs, rodents, wood destroying and infesting pests, stinging and biting pests including but not limited to bees, wasps, hornets and mosquitoes. Without control, these pests would interfere with the medical mission, destroy property and material, increase maintenance costs, and expose the patients, staff and public to a variety of possible diseases and/ or health issues. The program may use in-house and contract licensed Pest Management Professionals (PMPs) to address pest management issues.

The administration of contracts, safety of personnel, vehicles and required record keeping are included in this plan.

2. SCOPE

The Plan lists the various laws, regulations and instructions, including specific environmental considerations, which govern the facility’s IPM program. The offices and personnel by which such a plan will be coordinated are identified. The Plan references applicable policies, requirements and major actions, which impact the IPM program at the Hunter Holmes McGuire Richmond VAMC. Detailed technical guidance, that addresses most common pests and pest management activities, are provided in the Plan. Adherence to the Plan will ensure effective, economical, and environmentally acceptable controls and will maintain compliance with applicable laws and regulations.

3. COMMON DEFINITIONS:

a. General-Use Pesticide. General-use pesticides are pesticides which may be legally purchased and applied by the general public without the need of any Federal, State, and local licensing requirement on the part of the user.

b. Integrated Pest Management (IPM). Integrated Pest Management (IPM) is a decision-making process which considers cultural, mechanical, biological, and chemical controls. Control mechanisms are selected as each situation warrants. Where chemical control is indicated, specific pest populations are targeted for treatment when they are most vulnerable rather than a general application. Through the use of appropriate control measures and proper application, IPM can result in a reduction in the use of pesticides, which may adversely impact human health and the environment.

c. Licensed Pest Management Professional (PMP). A licensed Pest Management Professional (PMP) (sometimes referred to as a certified PMP) is an individual who has met the skill and competency requirements for those categories of specialization established by the Federal, state, and local governments in which the PMP engages in the trade of pest control.

NOTE: A PMP can be certified in one or multiple categories.

d. Safety Data Sheets (SDS). Safety Data Sheets (SDS) are written or printed material concerning a hazardous chemical, which contains all information required by the Occupational Safety and Health Administration (OSHA) and Title 29 Code of Federal Regulations (CFR) 1910.1200(g). SDS provides workers and emergency personnel with the proper procedures for handling or working with a hazardous substance.

e. Pest. A pest is an organism that is regarded by humans as injurious or unwanted.

f. Pest Control. Pest control refers to the actions of engaging in, recommending, advertising, soliciting the use of, supervising the use of, or using, a pesticide or device for the identification, control, eradication, mitigation, detection, inspection, or prevention of a pest in, on, or around a building, water area, air, land, plant, structure, or animal.

g. Pest Management Professional Helper (PMPH). The PMPH refers to the un-licensed personnel that are partaking in a training program or working under supervision and/or leadership of a licensed PMP.

h. Pest Infestation. Pest infestation is multiple sightings of or the presence of pests (e.g., insects, rodents, birds, etc.) in numbers or quantities large enough to be harmful, threatening, or obnoxious.

i. Pesticide. A pesticide is a chemical preparation used to kill or diminish pest activity.

j. Pest Management Officer (PMO). The PMO is the Chief Operating Officer for the service that oversees pest management operations of the VA facility.

k. Restricted-Use Pesticide. Restrictive-use pesticides are legally purchased and applied only by licensed pest control applicators, or applied under the direct supervision of trained and licensed applicators.

l. The term or reference to “applying pesticides”. The use of an apparatus to apply pesticides (i.e. herbicides). This includes the application of non-restricted pesticides or herbicides (i.e. Round-Up) by means of hand-pumped sprayer.

m. IPM Log Book. A document repository centrally located for short and long-term storage and filing (e.g., note books, file folders, file cabinets) of pest management documents required by federal, state and local government and as prescribed by this IPM facility plan. Such documentation is listed in section 8 “Administration”. Document retention and disposition for pest management records are prescribed in the Environmental Management Service Section of the VHA Records Control Schedule 10-1.

n. Contracting Officer's Representative (COR). The COR is responsible for monitoring the contractor's progress in fulfilling the technical requirements specified in the contract. Should the contractor fail to fulfill the contractual requirements, the COR informs the Contracting Officer of such failure. The COR maintains administration records, approves invoices and performs quarterly monitoring reports to confirm that the contractor is meeting the terms and conditions under the contract.

4. RESPONSIBILITIES

a. Chief, Environmental Management Service (EMS). Is the Pest Management Officer

(PMO) and is responsible for all facility pest management activities in accordance with VHA policy governing pest management operations.

b. Chief, Facilities Management Service (FMS). FMS provides facility structure support for any pest issues such as sealing pest entrances.

c. GEMS Program Manager. The GEMS Program Manager assists with compliance guidance on purchasing, use, storage and disposal of pesticides and associated apparatus.

d. Industrial Hygienist. The Industrial Hygienist provides guidance and training on use of personal protective equipment (PPE) and general chemical safety.

e. Sanitation Supervisors. Sanitation Supervisors are responsible for assuring that their assigned work areas are kept free from conditions that might create pest management issues and for reporting potential problems to the designated office.

f. All Employees are encouraged to:

(1) Exercise good sanitation practices in their work areas; including cleaning up or reporting spills, always storing food in a tightly closed rigid container, ensuring boxes are not stored on floors, keeping work areas clean and clutter-free to eliminate harborage for pests.

(2) Never introduce insect sprays of any type into the facility. Aerosols can compromise the respiratory health of patients.

(3) Alerting the designated office of current and potential pest activity.

(4) Remaining alert to the absence of physical defects, such as doors not closing, gaps in door sweeps, missing window/door screens, doors blocked open, etc., and reporting such items to the appropriate office for repairs.

5. PROCEDURES

a. Objective. The objective of the IPMO Plan is to facilitate an interdisciplinary approach of all services to maintain an effective control program for pests (insects, rodents, decay organisms, etc.). This concept is essential if effective control is to be accomplished. IPM must be considered an integral part of the overall delivery of quality patient care at this facility. This requires total cooperation by all services in resolving problem areas once identified. The Plan identifies and prioritizes the pests and their destructive effects so that decisions can be made for the desired level of protection. The Plan is consistent with current standards and criteria of IPM and VHA policy, and is integrated with the mission of the facility.

b. IPMO Plan Maintenance. Maintenance of the Plan is provided through annual reviews and is updated to incorporate appropriate changes as new regulations and policy are received.

This review will have three objectives: (1) Identify new pest problems not covered in the existing plan and recommend a control method; (2) Determine if there are any exceptions to the standards and requirements set forth in the plan and identify corrective measures where required; and (3) Provide an evaluation of the measure of the facility’s control program effectiveness.

c. Facility.

The Hunter Holmes McGuire VAMC, located in Richmond, Virginia, is a 399-bed facility offering primary, secondary, and tertiary health care in medicine, surgery, neurology, rehabilitation medicine, intermediate care, acute and sustaining spinal cord injury, skilled nursing home care, and palliative care. Primary and secondary levels of care are provided in psychiatry beds, along with a substance abuse rehabilitation program. Richmond offers a broad range of diagnostic and therapeutic services including a 12-station dialysis unit, magnetic resonance imaging, cardiac catheterization, mammography, radiation therapy, electrophysiology, photophoresis and lithotripsy. Richmond is a national referral center for heart, lung and liver transplantations, and the medical center acts as a tertiary care referral center for subspecialty treatment, traumatic brain injury, open-heart surgery, oncology, and vascular diseases. The medical center has three community-based outpatient clinics located in Charlottesville, Fredericksburg and Emporia, Virginia, and a strong and mutually beneficial affiliation with the Medical College of Virginia. Residency programs exist in virtually all general and specialty areas of medicine, rehabilitation, surgery, psychiatry, and dentistry. The medical center is the host site for a Parkinson's Disease Research, Education and Clinical Center (PADRECC), one of six in the nation.

6. PEST MANAGEMENT ISSUES:

Indoor/outdoor populations of rats, mice, cockroaches, ants, flies, spiders, wasp, mosquitoes, bed bugs and any other arthropod pests not specifically excluded from the contract.

Populations of the above pests that are located outside, but within the boundaries of the buildings. Termites and other wood-destroying organisms, winged termite swarmer’s emerging indoors/outdoors. Raccoons, skunks, woodchucks, pigeons, deer, dogs, bed bugs, cats, birds, bats, snakes and all other vertebrates other than commensal rodents. Trapping and removal will be performed at a per occurrence basis. Bird exclusion, trapping and/or other control measure on a per occurrence basis

a. Significant Facts about common pest and their impact.

(1) General Household and Nuisance Pests. This category includes but is not limited to spiders, bees and other stinging insects, cockroaches, ants, bed bugs, silverfish (firebrats), crickets, fleas, flies and other occasional invaders. Some pests in this category are known to cause significant health related concerns to humans and animals and may be classified under additional categories due to their vectoring of disease. Control of these pests is required to maintain the welfare and morale of patients, employees and residents. Effective controls reduce these pests to tolerable levels or temporarily eliminate them as well as eliminate entry points into the facility. Actual eradication of these pests may not be achievable. The cockroach is the most important and common pest of this category. It is significant because of its adverse effect on morale and possible health risks as a potential disease vector and the possibility of allergic reaction by some people. Of the approximately 50 cockroach species that occur in the U.S., the German and American cockroaches are two of the most common species. An integrated approach includes multiple methods (e.g., sanitation, monitoring, trapping, baiting and exclusion).

(2) Structural Pests. This category includes termites, powder post beetles, carpenter ants, and wood decay fungi, as well as others of minor concern. Termites are a major concern due to their ability to destroy wood in structures. Uncontrolled termites can cause serious to fatal weakening in wood structures in a very short time, as their presence can go undetected for a considerable amount of time. Pretreatment of soil for termite control is recommended on all new construction sites. Damage done by other structural pests, such as powder post beetles and carpenter ants, is not a routine occurrence. An intensive inspection is accomplished throughout the calendar year with treatments only as needed. An integrated approach includes multiple methods (e.g., exclusion and chemical).

(3) Stored Product Pest. Stored product pests are an occasional pest, but when they are introduced into a food storage/production area, they can very quickly become a significant problem. Their ability to reproduce rapidly is second only to their appetite. The amount of food they contaminate can quickly become very significant. They feed on all types of products made from grain. Prevention and control involves monitoring in high risk areas and inspections to ensure there have been no pests introduced. In the event pests are introduced, a very intense and rapid response is necessary to eliminate and prevent the spread of the infestation. An integrated approach includes multiple methods (e.g., monitoring, trapping and baiting).

a. Pests with Expanded Significant Health Related Concerns:

(1) Mosquitos. Mosquitos are flying parasites known for transmitting such diseases as Zika Virus, Chikungunya Virus, West Nile Virus, Dengue, Malaria, Yellow Fever and Eastern Equine Encephalitis Virus. There are about 150 species of mosquitos in the United States. Male mosquitoes have a lifespan of about 10 days while the female up to 56 days. Females require the blood meal from a host to develop and nourish the eggs. One female has the potential to create a population of well over a thousand mosquitoes in her lifespan. Mosquitoes can be active in almost any environment (except in cold weather) and are particularly fond of wet and moist areas. Because they must have water in order to thrive, typical areas for natural cisterns (ponds, marshes, swamps, tall grasses and weeds), human engineered cisterns (bird bath, open containers, gutters, fish ponds) and other areas where water can collect and be stagnate. The mosquito is the most dangerous carrier of disease in the world. An integrated approach includes multiple methods (e.g., monitoring, trapping and sanitation and chemical).

(2) Fleas. Fleas are non-flying parasites known for transmitting such diseases as murine typhus and bubonic plague. Common flea species are Cat Flea, Dog Flea and Bird Flea. In addition, fleas can be carried on other animals like rabbits, foxes, rats, mice and livestock. There are four distinct stages: eggs, larvae, pupae, and adult. Adult fleas feed on blood and the larvae eat dried blood. The lifespan of a single flea can be up to three months. A female flea can lay 200 to 400 eggs during her life time. Flea bites are extremely itchy and cause great discomfort. Fleas often target the legs and feet of human victims and may infest the entire bodies of animals (i.e., pets). An integrated approach includes multiple methods (e.g., exclusion, trapping, sanitation and chemical).

(3) Flies. There are more than 100,000 species of flies identified in the world. In North America alone, there are about 16,000 types of flies. Some of the more common flies in the United States (excluding the mosquito) are the Housefly, Gnat, Blow Fly, Fruit Fly, Phorid Fly, Cluster Fly and Drain Fly. The Housefly is associated with more than 100 pathogens, including but not limited to, Salmonella, Staphylococcus, E. coli and Shigella. Other diseases that flies are known to spread include typhoid fever, cholera, dysentery and rotavirus. Fly life expectancy is dependent on the fly species and can range from eight days to more than two months. A pair of flies can produce 500 to 200 eggs in their lifespan. The insects feed on garbage, animal feces, carcasses, carrion, food wastes, and various other decaying and putrefying organic materials. An integrated approach includes multiple methods (e.g., exclusion, trapping, sanitation and chemical).

(4) Rodents. Rodents (e.g., Mouse, Rat and Gopher) can quickly reproduce and the amount of foodstuffs they contaminate can be quite large. Rodents are a potential vector of multiple diseases (e.g., Hantavirus Pulmonary Syndrome expanded, Hemorrhagic Fever with Renal Syndrome collapsed, Lassa Fever collapsed, Leptospirosis collapsed and Lymphocytic Chorio-meningitis (LCM) collapsed), posing significant threat to individuals with a weakened immune system. Control of these pests involves multiple aggressive activities. Rodent traps are placed in critical areas where rodents can find food or access to the structures. Rodent traps and bait stations will be serviced and dated a minimum of every other week, with the exception of food storage areas which shall be serviced weekly. These areas include but are not limited to dumpster areas, receiving areas and basement areas where rodents may find access. It is critical to limit access to food and harborage. Caulking and sealing structures is the most critical aspect of rodent control. Monthly inspections and treatment of the buildings will include inspection for rodent activity and seal and repair of structure as needed to prevent pest entry. An integrated approach includes multiple methods (e.g., sanitation, monitoring, trapping, baiting, exclusion, chemical and other barrow reducing methods).

(5) Common Nuisance Birds. Birds are usually useful and in many cases, enjoyable to observe. However, some can become a nuisance by destroying vegetation, contaminating and defacing buildings with droppings and vectoring health related diseases. (e.g., Equine Encephalitis, St. Louis encephalitis, West Nile Virus). Birds generally considered “nuisance birds” include but are limited to, Feral Pigeons, House Sparrows, Starlings, Canada Goose and Ring-Billed. An integrated approach includes multiple methods (e.g., sanitation, monitoring, trapping, baiting, exclusion and chemical).

b. Ornamental and Turf Pests.

(1) Ornamental Pests. Ornamental Pest control includes diagnosis and control of plant damage. Living pests, including disease agents, weed insects, mites and vertebrates, can cause some plant damage. Other causes of plant problems are imbalanced fertilization, pesticide injury, improper planting and pruning, root girdling, soil conditions, mechanical damage, pollution damage and natural aging of plants.

(2) Turf Pests. Pest control in this category is usually attained by good cultural practices and chemical control. Turf pest (e.g., Billbug, Chinch Bug, Moles, Shrews) problems often result from causes other than pests such as improper watering, improper mowing height, poor root systems, wrong soil pH and possible buildup of soluble salts in the soil. Proper controls will be used dependent on the cause and best solution for the problem.

Note: To void damage to the turf, it is important to have the knowledge and skills required for good ornamental and turf management and avoid damage from insects. Applying the appropriate fertilization, irrigation and mowing practices for the turf being managed are critical for ideal condition. Stressed turf has the potential to invite or be conducive for insect problems. However, sometimes it can be difficult to identify the source of the damage. Disease, fertilization, irrigation, insect damage and improper herbicide applications can imitate each other.

c. Miscellaneous Pests. This category includes but is not limited to squirrels, skunks, bats, cats and dogs. It is important to note that some of these pests may present health risks depending on local epidemiology of rabies. Local public health authorities may provide guidance on removal of these species.

d. Special Areas of Concern:

Food Service Areas. Monthly inspections of food service areas are conducted by the PMP; if infestations are identified; non-chemical methods are considered first for remediation, if appropriate.

7. ADMINISTRATION

a. Quality Assurance Program. The below requirements outline the processes which should ensure effectiveness of the IPM Plan.

(1) IPM Procedure Review. IPM procedures are reviewed to ensure that such procedures are consistent with the IPM principle.

(3) Quality Assurance Inspections.

Inspection System. The Contractor's quality control inspection system shall cover all the services stated in this contract. The purpose of the system is to detect and correct deficiencies in the quality of services before the level of performance becomes unacceptable and/or the COR identifies the deficiencies.

Checklist. A quality control checklist shall be used in evaluating contract performance during regularly scheduled and unscheduled inspections. The checklist shall include every building or site serviced by the Contractor, as well as every task required to be performed.

File. A quality control file shall contain a record of all inspections conducted by the Contractor and any corrective actions taken. The file shall be maintained throughout the term of the contract and made available to the COR upon request.

Inspector(s). The Contractor shall state the names responsible for performing the quality control inspections.

At least annually the PMO (or designee) reviews all IPM actions and documents to ensure proper completion of requirements and IPM practices as described below:

(a) Ensure all pest problems are addressed using a consistent process that includes, in order:

1. Inspection, Pest Identification, Sanitation, Exclusion and/or Pest Isolation.

2. Habitat and Harborage Modification

3. Physical Removal or Mechanical Controls

4. Chemical Application

(b) Ensure that all procedures regarding application of chemicals are followed including, but not limited to:

1. No applications will be made in any interior area without prior authorization from the PMO, or the appointed designee. PMP should have the latitude and flexibility to perform specific application or task. The PMO discusses and document all areas of unique significances with the PMP within first few days of the contract or the in-house PMP start date.

2. Exterior applications should be scheduled for a time when staff, patients, or visitors will not be present in the treatment area.

3. All staff working in the area(s) to be treated will be pre-notified of the application when in the interior, including the date, time, pest problem, and material to be applied.

4. No treatment will be made to any room when patients are present unless approved by the PMO.

5. Extra care should be made where pesticides are applied to special areas of concern and environmentally sensitive areas. IPM practices are particularly important in these areas and should be adhered to as much as possible.

(c) Ensure that all pest management activities are properly documented that include:

1. Specific locations of reported activity.

2. Inspection reports.

3. Identification of pest, if applicable.

4. Analysis of pest activity and potential causes, when applicable.

5. Actions taken without the use of chemicals, when applicable.

6. Listing of chemicals used by name, EPA registration number, percentage of active ingredient applied, and amount of chemical applied, when applicable.

7. Method of application, when applicable.

8. (Where required) Square footage of applications larger in size than spot application (defined as a surface treatment to an area of no more than two square feet).

9. Wind direction and speed and temperature, if outside (when applicable).

Note: Each chemical application requires documentation. Contractors should be providing this documentation, if chemicals were used. This documentation should be on file. Appendix E provides a sample Report for facility in-house PMPs to record pest management activities.

Contractor should provide their own after every service.

(d) Maintain an approved pesticide list for the facility. Approved pesticides should be placed on an approved pesticides list. Such pesticides should be the only chemicals that may be used for applications without supplemental authorization when needs arise.

(e) Pest management records for indoor and outdoor services should be kept in the IPM log book. This log book should be managed by the PMO or designated representative and should contain at a minimum:

1. Each PMP’s license (in-house and contractor).

2. Proof of PMP’s continuing education (in-house PMP Only).

3. Proof of insurance for any contractor conducting Pest Control Services at the McGuire

Hunter Holmes VAMC.

4. Pest Sightings log sheets.

5. Pest management inspection and application reports.

6. SDS (and antidotes) for approved materials.

7. Contractor and in-house PMP reports regarding identification of structural or procedural improvements, with recommendations on how improvements can be devised and/or implemented.

8. Inspection Schedule.

9. Site diagram(s) to include placement of all rodent control and flying insect devices, both interior and exterior.

10. Copy of pest management contracts.

b. Complaints and Sightings. Complaints and sightings should be reported to the PMO or the appointed designee and be logged on the Pest Sighting Log Sheet. Pest activity or evidence in clinical environments should be reported immediately.

Note: Appendix F provides a sample Pest Sightings Log Sheet that can be used to record pest sightings.

c. Resources.

(1) Funding. Funding for the pest management operation is budgeted annually through the facility budget process, and includes but is not limited to the following options:

(a) A contract pest control company licensed by the State of Virginia to provide specific services when applicable.

(b) In-house PMP(s) staffing including training, supplies and work area.

(c) In-house PMP(s) licensing required by the State of Virginia.

(d) Facility repairs and modifications for addressing pest management issues.

(2) Staffing. Integrated pest management activities will be performed by a licensed in-house PMP or an in-house trainee being closely supervised by a licensed medical facility PMP and under a facility approved facility pest management training program. All personnel will be licensed in the appropriate categories. The contractor PMPs should supply all pesticides, personnel and equipment required to perform integrated pest management services as indicated in the specific contract.

(3) Materials, pesticides and equipment. The inventory of the pesticides will vary week to week and also by the season. A complete inventory of all assets and supplies is conducted annually, if applicable.

(4) Facilities. The following specific locations are covered by this pest management plan.

There should be a systematic approach or established schedule for routine inspections of all areas covered by the plan.

LOCATIONS:

Hunter Holmes McGuire Richmond VAMC 1201 Broad Rock Blvd.

Richmond, VA 23249 Point of Contact:

Calvin Greene 804-675-5000, ext. 1823 or 5137 Five days per week - Monday - Friday

Emporia CBOC 1746E. Atlantic St.

Emporia, VA 23847

Once a month either Monday, Tuesday, Wednesday, Thursday or Friday

South Fredericksburg CBOC 10401 Spotsylvania Ave.

S. Fredericksburg, VA 22408

North Fredericksburg CBOC 130 Executive Center PKWY N. Fredericksburg, VA 22401

Charlottesville CBOC 590 Peter Jefferson PKWY #250 Charlottesville, VA 22911

(5) Contracts (if applicable). Contractors should supply a list of pesticides for use at the Richmond VAMC. Labels and SDSs are submitted for approval prior to service.

(a) Storage and Mixing. No storage of pesticides or mixing of pesticides is permitted on property without approval from the PMO.

(b) Disposal. Contractors are responsible for disposing of any pesticide or container off-site in compliance with applicable federal, state and local laws and regulations.

(c) Application by Need. Pesticide application should be according to need, not by schedule. As a general rule, application of pesticides in any interior and exterior areas should not occur unless visual inspections or monitoring devices indicate the presence of pests in that specific area. Preventive pesticide applications of areas where surveillance indicates a potential insect or rodent infestation are acceptable, on a case-by-case basis

(d) Minimization of Risk. When pesticide use is necessary the in-house PMP and contractor should employ the least hazardous material, most precise application technique, and minimum quantity of pesticide necessary to achieve control.

(e) Structural Modifications and Recommendations. The contractor should recommended structural, sanitary, or procedural modifications that would reduce pest food sources, water sources, harborage, or access to the COR, when required.

e. Training.

(1) The in-house PMP should complete the required training for maintaining certification and attend annual refresher training events to stay abreast of latest pest management risks, processes, abatement measures, pesticides and applicable laws.

(2) Unlicensed PMP helper training should consist of at a minimum:

(a) Recognizing common pests and associated risks.

(b) Reading and understanding label information to include:

1. The common name of pesticides applied;

2. Pest(s) to be controlled;

3. Timing and methods of application;

4. Poisoning control;

5. Safety precautions; and

6. Any specific disposal procedures.

(c) Applying pesticides in accordance with label instructions and warnings. This includes the preparation of the proper concentration of pesticide to be used under particular circumstances, and taking into account such factors as the area to be covered and the quantity dispersed in a given period of application.

(d) Recognizing local environmental situations that must be considered during application to avoid contamination of special facilities, especially those particular areas in sensitive environmental areas or special areas of concern.

(3) The PMO should attend training, at a minimum, annually to receive updates on laws and pesticide regulations, new and emerging pest risks that have the potential to impact the facility and general activities within the industry. The PMO training should provide continual knowledge and skills for managing an effective facility pest management program.

8. HEALTH AND SAFETY

a. Requirements.

(1) Safety equipment required for personal protection of those engaged in the application storage or transportation of pesticides is listed on all labels and or SDS sheets. All required safety equipment should be available as needed before the use of any material in accordance with VHA policy governing pest management operations.

(2) Outdoor pesticide applications (liquids, dusts, granular) should be conducted when wind speed is safe to apply to prevent drift.

(3) All PMPs that apply pesticides should include each application in their report (including non-restricted use pesticides).

(4) Cleaning, maintenance and storage of pest control equipment should be done by authorized, trained personnel, in accordance with the manufacturer’s instructions.

(5) Facility equipment used in pest control activities should be marked with appropriate warnings to ensure public safety and to avoid environmental contaminations.

(6) Personal Protective Equipment (PPE) is worn as required in the SDS. Any staff member that wears a respirator to complete pest management duties should be included in the Respiratory Protection Program.

(7) Liquid pesticide mixing should be done on a nonporous surface that is capable of retaining any spillage that might occur. Nonporous surfaces should not contain any drainage devices or appurtenances.

(8) Pesticides used by in-house PMPs should not to be transported in the cab or passenger compartment of any vehicle.

(9) When applicable, pesticides should only be stored in designated storage area that meets the label and SDS storage requirements (humidity, temperature). The storage area should be locked when not in use and accessible to authorized personnel only. Pesticides should be stored in the original container, with original visible/legible labels and all containers tightly closed. The pesticide storage area is marked with required warning signage. A spill kit compatible with pesticides should be kept in all pesticide storage areas. The Safety Department provides additional safety guidance when it comes to storage and mixing chemical.

(10) The toxicity information, including antidotes, for all types of pesticide poisoning should be kept readily available. The responsible program official and employee health physician(s) should maintain a listing of all pesticides available for use at the facility and their antidotes. Note: The “Recognition and Management of Pesticide Poisonings”, published by the Environmental Protection Agency gives healthcare providers a quick reference resource for the best toxicology and treatment information for patients with pesticide exposures.

(11) Compounded Pesticide Products. The PMO ensures the proper utilization of all products which are compounded with pesticides. This applies to pesticides formulated and labeled for use as paint additives resulting in a paint-insecticide mixture, which must be applied by certified applicators when used on VA property as required. This does not apply to the use of paints containing fungicides as mildew inhibitors, or the use of anti-microbial pesticides where application procedures on the label require no special measures.

b. Hazards.

(1) Pest Control Personnel. The PMPs should use all safety equipment required by the pesticide label and SDS sheets for the product being applied.

(2) Medical Surveillance. Any time symptoms of toxicity are exhibited; an immediate medical examination should be performed.

(3) The following is minimal list of protective equipment for the in-house PMPs on hand or available through the safety department;

1. Apron, neoprene

2. Boots, neoprene http://www2.epa.gov/pesticide-worker-safety/pesticide-poisoning-handbook-table-contentshttp:/www2.epa.gov/pesticide-worker-safety/pesticide-poisoning-handbook-table-contents

3. Coveralls, safety, industrial

4. Gloves, neoprene

5. Gloves, heavy leather

6. Goggles, safety

7. Respirator, full mask

8. Respirator cartridges

9. Emergency eye wash

10. Spill kit

11. Bee suit, if applicable

(4) General Public. The public is protected from potential contamination through careful analysis of the pest problem and the use of the minimum amount of material needed to resolve the problem. In addition, a strong emphasis is placed on prevention and control by identifying the source of the problem.

(5) Maintenance Shops. This plan follows the safety requirements as outlined in the VHA policy governing pest management operations.

(6) Vehicles. To minimize the chance of accidental contamination, vehicles used in the transportation of pesticides and equipment should have a separate compartment from the passengers for the pesticides. When transporting pesticides all necessary protective clothing and equipment should be available.

9. PUBLIC LAWS AND REGULATIONS

a. Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Subchapter E-Pesticide

Programs.

(a) Virginia Pesticide Control Act Chapter 670

(b) Virginia Pesticide Control Act Chapter 675

(c) Virginia Pesticide Control Act Chapter 680

(d) Virginia Pesticide Control Act Chapter 6850

(e) Virginia Pesticide Control Act Chapter 690

(f) Pesticide Discharges General Permit (VAG87)

10. COORDINATION

This plan is coordinated with the following staff officials at the facility: (1) Facility Management, (2) Personnel Physician, (3) Safety and GEMS (4) Environmental Management Service (EMS), and others as required.

11. ENVIRONMENTAL CONSIDERATIONS

Sensitive areas listed on pesticide labels are considered before pest management operations are conducted. No pesticides are applied directly to wetlands or bodies of water unless use in such sites is specifically approved on the label.

a. Environmentally Sensitive Areas. All patient care and food service areas are considered sensitive areas. This plan reflects necessary precautions and restraints.

b. Protected Species.

i) Mammals

a. Gray bat (Myotis grisescens)

b. Indiana bat (Myotis sodalis)

c. Virginia big-eared bat

d. West Indian manatee (Trichechus manatus)

e. Dismal Swamp southeastern shrew (Sorex longirostris fisheri)

f. Fin whale (Balaenoptera physalus)

g. Humpback whale (Megaptera novaeangliae)

h. Right whale (Balaena glacialis)

ii) Birds

a. Piping plover (Charadrius melodus)

b. Roseate tern (Sterna dougallii dougallii)

c. Red-cockaded woodpecker (Picoides borealis)

d. Kirtland’s warbler (Dendroica kirtlandii)

iii) Reptiles

a. Green sea turtle (Chelonia mydas)

b. Hawksbill turtle (Eretmochelys imbricata)

c. Kemp's ridley (Lepidochelys kempii)

d. Leatherback sea turtle (Dermochelys coriacea)

e. Loggerhead sea turtle (Caretta caretta)

f. Bog turtle (Clemmys muhlenbergii)

iv) Fish

a. Slender chub (Erimystax cahni)

b. Spotfin chub (Cyprinella monacha)

c. Duskytail darter (Etheostoma percnurum)

d. Roanoke logperch (Percina rex)

e. Shortnose sturgeon (Acipenser brevirostrum)

f. Blackside dace (Phoxinus cumberlandensis)

g. Yellowfin madtom (Noturus flavipinnis) https://en.wikipedia.org/wiki/Gray_bat https://en.wikipedia.org/wiki/Indiana_bat https://en.wikipedia.org/wiki/Corynorhinus https://en.wikipedia.org/wiki/West_Indian_manatee https://en.wikipedia.org/w/index.php?title=Dismal_Swamp_southeastern_shrew&action=edit&redlink=1 https://en.wikipedia.org/wiki/Sorex https://en.wikipedia.org/wiki/Fin_whale https://en.wikipedia.org/wiki/Humpback_whale https://en.wikipedia.org/wiki/Right_whale https://en.wikipedia.org/wiki/Piping_plover https://en.wikipedia.org/wiki/Roseate_tern https://en.wikipedia.org/wiki/Red-cockaded_woodpecker https://en.wikipedia.org/wiki/Kirtland%E2%80%99s_warbler https://en.wikipedia.org/wiki/Green_sea_turtle https://en.wikipedia.org/wiki/Hawksbill_turtle https://en.wikipedia.org/wiki/Kemp%27s_ridley https://en.wikipedia.org/wiki/Leatherback_sea_turtle https://en.wikipedia.org/wiki/Loggerhead_sea_turtle https://en.wikipedia.org/wiki/Bog_turtle https://en.wikipedia.org/wiki/Slender_chub https://en.wikipedia.org/wiki/Spotfin_chub https://en.wikipedia.org/wiki/Duskytail_darter https://en.wikipedia.org/wiki/Roanoke_logperch https://en.wikipedia.org/wiki/Shortnose_sturgeon https://en.wikipedia.org/wiki/Blackside_dace https://en.wikipedia.org/wiki/Yellowfin_madtom

v) Insects

a. Northeastern beach tiger beetle (Cicindela dorsalis dorsalis)

b. Mitchell’s satyr (Neonympha mitchellii)

vi) Crustaceans

a. Lee County cave isopod (Lirceus usdagalun)

b. Madison cave isopod (Antrolana lira)

vii) Gastropods

a. Virginia fringed mountain snail (Polygyriscus virginianus)

b. Vii) Bivalves

c. Purple bean (Villosa perpurpurea)

d. Cumberlandian combshell (Epioblasma brevidens)

e. Fanshell (Cyprogenia stegaria)

f. Appalachian monkeyface (Quadrula sparsa)

g. Cumberland monkeyface (Quadrula intermedia)

h. Pink mucket (Lampsilis abrupta)

i. Oyster mussel (Epioblasma capsaeformis)

j. Birdwing pearlymussel (Lemiox rimosus)

k. Cracking pearly mussel (Hemistena lata)

l. Dromedary pearly mussel (Dromus dromas)

m. Green blossom pearlymussel (Epioblasma torulosa gubernaculum)

n. Littlewing pearlymussel (Pegias fabula)

o. Fine-rayed pigtoe (Fusconaia cuneolus)

p. Rough pigtoe (Pleurobema plenum)

q. Shiny pigtoe (Fusconaia cor)

r. Rough rabbitsfoot (Quadrula cylindrica strigillata)

s. Tan riffleshell (Epioblasma florentina walkeri)

t. James River spinymussel (Pleurobema collina)

u. Dwarf wedgemussel (Alasmidonta heterodon)

viii) Plants

a. Sensitive joint-vetch (Aeschynomene virginica)

b. Shale barren rock-cress (Arabis serotina)

c. Virginia round-leaf birch (Betula uber)

d. Small-anthered bittercress (Cardamine micranthera)

e. Smooth purple coneflower (Echinacea laevigata)

f. Virginia sneezeweed (Helenium virginicum)

g. Swamp pink (Helonias bullata)

h. Peter's mountain mallow (Iliamna corei)

i. Small whorled pogonia (Isotria medeoloides)

j. Eastern prairie fringed orchid (Platanthera leucophaea)

k. Michaux's sumac (Rhus michauxii)

l. American chaffseed (Schwalbea americana)

m. Northeastern bulrush (Scirpus ancistrochaetus)

n. Virginia spiraea (Spiraea virginiana) https://en.wikipedia.org/w/index.php?title=Northeastern_beach_tiger_beetle&action=edit&redlink=1 https://en.wikipedia.org/wiki/Cicindela https://en.wikipedia.org/wiki/Mitchell%E2%80%99s_satyr https://en.wikipedia.org/w/index.php?title=Lee_County_cave_isopod&action=edit&redlink=1 https://en.wikipedia.org/w/index.php?title=Madison_cave_isopod&action=edit&redlink=1 https://en.wikipedia.org/wiki/Virginia_fringed_mountain_snail https://en.wikipedia.org/wiki/Purple_bean https://en.wikipedia.org/wiki/Cumberlandian_combshell https://en.wikipedia.org/wiki/Fanshell https://en.wikipedia.org/wiki/Appalachian_monkeyface https://en.wikipedia.org/wiki/Cumberland_monkeyface https://en.wikipedia.org/wiki/Pink_mucket https://en.wikipedia.org/wiki/Oyster_mussel https://en.wikipedia.org/wiki/Birdwing_pearlymussel https://en.wikipedia.org/wiki/Cracking_pearly_mussel https://en.wikipedia.org/wiki/Dromedary_pearly_mussel https://en.wikipedia.org/w/index.php?title=Green_blossom_pearlymussel&action=edit&redlink=1 https://en.wikipedia.org/wiki/Littlewing_pearlymussel https://en.wikipedia.org/wiki/Fine-rayed_pigtoe https://en.wikipedia.org/wiki/Rough_pigtoe https://en.wikipedia.org/wiki/Shiny_pigtoe https://en.wikipedia.org/wiki/Rough_rabbitsfoot https://en.wikipedia.org/wiki/Tan_riffleshell https://en.wikipedia.org/wiki/James_River_spinymussel https://en.wikipedia.org/wiki/Dwarf_wedgemussel https://en.wikipedia.org/w/index.php?title=Sensitive_joint-vetch&action=edit&redlink=1 https://en.wikipedia.org/wiki/Shale_barren_rock-cress https://en.wikipedia.org/wiki/Virginia_round-leaf_birch https://en.wikipedia.org/wiki/Betula https://en.wikipedia.org/w/index.php?title=Small-anthered_bittercress&action=edit&redlink=1 https://en.wikipedia.org/wiki/Cardamine https://en.wikipedia.org/wiki/Echinacea_laevigata https://en.wikipedia.org/wiki/Virginia_sneezeweed https://en.wikipedia.org/wiki/Helenium https://en.wikipedia.org/wiki/Helonias_bullata https://en.wikipedia.org/wiki/Peter%27s_mountain_mallow https://en.wikipedia.org/wiki/Small_whorled_pogonia https://en.wikipedia.org/wiki/Platanthera_leucophaea https://en.wikipedia.org/wiki/Michaux%27s_sumac https://en.wikipedia.org/wiki/Rhus https://en.wikipedia.org/wiki/American_chaffseed https://en.wikipedia.org/wiki/Northeastern_bulrush https://en.wikipedia.org/wiki/Scirpus https://en.wikipedia.org/wiki/Virginia_spiraea https://en.wikipedia.org/wiki/Spiraea

c. Pollution Abatement Procedures. Abatement procedures consist of the increased use of alternative control measures and chemical applications are utilized only when other measures are ineffective in controlling the pest. Recordkeeping is reviewed to ensure that minimum rates of chemical applications are used to affect control at all times. Planned reductions of chemical usage are goals of the program at all times.

12. REFERENCES

a. Federal Insecticide Fungicide and Rodenticide Act (FIFRA).

b. Toxic Substances Control Act (TSCA) and implementing instructions in 40 CFR Parts 700-799, Subchapter R- Toxic Substances.

c. Occupational Safety and Health Act (OSHA) and implementing instructions in 29 CFR Parts 1900-1999, Subchapter XVII.

d. VHA Directive 1850.02 Pest Management Operations

e. Environmental Protection Agency. “Pesticide Registration (PR Notice) Notice 2002-1” Pesticide Registration (PR) Notices. 2002. http://www.epa.gov/PR_Notices/pr2002-1.pdf (November 30, 2010).

f. Potter, Michael F. “Bed Bugs” University of Kentucky College of Agriculture. August 2008. http://www.ca.uky.edu/entomology/entfacts/ef636.asp (November 30, 2010).

g. Environmental Protection Agency. “Bed Bugs: Get Them Out and Keep Them Out” https://www.epa.gov/bedbugs (November 30, 2010).

h. EPS Bed Bug Management Guide. http://vaww.vhaco.va.gov/EPS/Directives/Bed%20Bug%20Guide2.pdf

i. VA National Center for Patient Safety (NCPS) Topics in Patient Safety (TIPS) Newsletter, May/June2004 Link available at:

http://www.patientsafety.va.gov/docs/TIPS/TIPS_MayJun04.pdf (Accessed 9/30/16)

j. VHA Center for Engineering & Occupational Safety and Health (CEOSH) Employee Occupational Health Guidebook: 2014, Updated February 2016; Chapter 6.2.18 “Pesticides, Herbicides, Fungicides, Insecticides” Link available at:

http://vaww.ceosh.med.va.gov/01HP/02HP_Guidebooks/03_Collections/04HP_Occupational Health/NetHelp/EOHGB.htm#!WordDocuments/pesticidesherbicidesfungicidesandinsecticid es.htm http://www.epa.gov/PR_Notices/pr2002-1.pdf http://www.ca.uky.edu/entomology/entfacts/ef636.asp https://www.epa.gov/bedbugs http://vaww.vhaco.va.gov/EPS/Directives/Bed%20Bug%20Guide2.pdf http://www.patientsafety.va.gov/docs/TIPS/TIPS_MayJun04.pdf http://vaww.ceosh.med.va.gov/01HP/02HP_Guidebooks/03_Collections/04HP_OccupationalHealth/NetHelp/EOHGB.htm#!WordDocuments/pesticidesherbicidesfungicidesandinsecticides.htm http://vaww.ceosh.med.va.gov/01HP/02HP_Guidebooks/03_Collections/04HP_OccupationalHealth/NetHelp/EOHGB.htm#!WordDocuments/pesticidesherbicidesfungicidesandinsecticides.htm http://vaww.ceosh.med.va.gov/01HP/02HP_Guidebooks/03_Collections/04HP_OccupationalHealth/NetHelp/EOHGB.htm#!WordDocuments/pesticidesherbicidesfungicidesandinsecticides.htm

13. FOLLOW-UP RESPONSIBILITY: ENVIRONMENTAL MANAGEMENT SERVICE (EMS)

14. REVIEW DATE: AUGUST 3, 2018

Deborah Bannister-Sandiford, Acting Chief, EMS

John A. Brandecker, Director

Appendix A: Bed Bugs MCM, Bed Bug Plan for Home Health Care and Social Workers and Bed Bugs Action Plan Appendix B: The Richmond VAMC does not store or formulate pesticide products on Department of Veterans Affairs property Appendix C: Building Plans/Campus Site Plans Appendix D: Sample Quality Assurance Inspection Checklist Appendix E: Sample Pesticide Usage Report / Service Ticket Report?

Appendix F: Sample Pest Sighting Log

FACILITY PEST MANAGEMENT PLAN

Appendix A

BED BUG MCM

Revised MCM Pending Director’s signature file://V06.med.va.gov/ric/Users/VHARICBanniD/Bed%20Bug%20Control%20-%20Richmond%20VAMC.pdf

Bed Bug Action Plan for Home Health Care and Social Workers

Dini M. Miller, Ph.D., Department of Entomology, Virginia Tech

Stephen Kells Ph. D. Department of Entomology, University of Minnesota

Introduction

Bed bugs are spreading rapidly within the United States. Bed bug researchers have observed that bed bug reservoirs are developing among the lower socioeconomic classes due to the cost of control. People who require home visits usually have a long list of economic problems. Bed bugs infestations are just another problem that they cannot afford to deal with.

Consequently, if a few bed bugs become established in a low-income situation it is very likely that an infestation will develop.

Healthcare and social workers that routinely visit clients’ homes as a part of their job are at risk for contacting bed bugs.