0011 Pest Management SOP.pdf

Department of Veterans Affairs NCA DIRECTIVE 3410

National Cemetery Administration Transmittal Sheet

Washington, DC 20420 October 9, 2025

INTEGRATED PEST MANAGEMENT AT VA NATIONAL CEMETERIES

1. REASON FOR ISSUE: This issuance is a scheduled review and update of policy and responsibilities related to National Cemetery Administration (NCA) policy on the management of pests and use of pesticides.

2. SUMMARY OF CHANGES: NCA Handbook 3410 Integrated Pest Management

(April 30, 2012) is rescinded and replaced by standard operating procedures (SOP) 41-

SOP-028 Integrated Pest Management.

3. RESPONSIBLE OFFICE: NCA Cemetery Operations, 810 Vermont Avenue, NW, Washington, DC 20420, is responsible for the contents of this directive. For inquiries, contact ncacemopsanalysts@va.gov.

4. RELATED PUBLICATIONS:

a. NCA Directive 0057 Environmental Management Program.

b. NCA Directive 0320 Emergency Preparedness Planning.

c. NCA Directive 3000 Operational Standards for National Cemeteries.

5. RESCISSION:

a. NCA Handbook 3410 Integrated Pest Management (April 30, 2012).

b. NCA Directive 3410 Integrated Pest Management (April 30, 2012).

6. RECERTIFICATION: This document is scheduled for recertification not later than five

(5) years from the date of issuance

/s/ Samuel B. Brown Under Secretary for Memorial Affairs Date Signed: __________________

Distribution: Electronic

October 9, 2025 NCA DIRECTIVE 3410

INTEGRATED PEST MANAGEMENT AT VA NATIONAL CEMETERIES

1. PURPOSE/AUTHORITY:

a. This directive updates the National Cemetery Administration (NCA) policy on Integrated Pest Management (IPM), pesticide use, applicator certification, and related legal requirements.

b. The authority for this directive is 38 U.S.C. § 2404.

2. BACKGROUND:

a. Per National Institute of Health, a pesticide is any substance used to kill, repel, or control certain forms of plant or animal life that are considered to be pests. Pesticides include: herbicides for destroying weeds and other unwanted vegetation; insecticides for controlling a wide variety of insects; fungicides used to prevent the growth of molds and mildew; disinfectants for preventing the spread of bacteria; and compounds used to control mice and rats.

b. IPM is a decision-making process that uses knowledge of pest biology, the environment, and available technology to prevent unacceptable levels of damage by animal, insect or plant pests while posing the least possible hazard to people, resources, and the environment. IPM is an ecosystem-based strategy that uses biological controls, habitat manipulation, cultural controls, and, if necessary, targeted chemical controls.

c. IPM program objectives are to prevent, mitigate, and/or manage pest problems by:

(1) Maintaining and promoting safe, efficient, and environmentally sound strategies to prevent or control disease vectors and other pests that may adversely affect health, impede operations, damage property, and/or detract from cemetery appearance.

(2) Identifying and phasing out ineffective treatments.

(3) Incorporating IPM philosophy and strategies into all relevant aspects of National

Cemetery pest management planning, training, and operations.

(4) Complying with NCA integrated grounds maintenance plan, standards and associated standard operating procedures.

(5) Providing customized training in IPM techniques for cemetery staff involved in pest management operations as well as required training and certification for pesticide applicators.

3. POLICY:

a. All NCA-administered cemeteries will follow procedures set forth in (VA internal-only) 41-SOP-028 Integrated Pest Management (IPM) for VA National Cemeteries.

Each cemetery will maintain records that track pest problems and their probable causes, treatment, and treatment results both effective and ineffective.

b. Chemical controls will be used only if other IPM methods fail to achieve a satisfactory effect. The least toxic appropriate pesticide will be used. When application of chemical pesticides is required, the handling of pesticides and pesticide waste(s) must be conducted in accordance with all Federal, State and local (city, county, etc.) laws and regulations.

NOTE: For the purpose of this directive and accompanying Cemetery Operations

(41) IPM SOP, “handling” refers to all activities involved in the selection, purchase, storage, handling, mixing, application, and disposal associated with pesticides.

(1) All precautions will be taken to ensure the protection and safety of individuals and the environment during the conduct of these activities.

(2) Local restrictions on pesticide applications associated with land uses on cemetery property and adjacent lands and all other agreements with local (city, county, etc.), State, and Federal agencies must be adhered to and enforced.

c. NCA staff who handle pesticides will have a state license, receive appropriate training and guidance to ensure compliance with all applicable Federal, State and local laws and regulations.

d. Cemetery employees that apply restricted use pesticides in a National

Cemetery must be certified or licensed in that State, or under the supervision of a State-certified applicator. Volunteers may not apply pesticides.

e. If pesticide application is to be done by contractors, the Statement of Work

(SOW) must include:

(1) Requirement that the contractor (and all individually-identified applicator(s)) are

State-certified and/or licensed, are aware of and agree to abide by NCA IPM procedures and requirements as stated in this directive and current Cemetery Operations 41-SOP-

28 IPM.

(2) Requirement to submit a plan to the Cemetery IPM Coordinator documenting:

i. All chemical and non-chemical controls that will be used to include product names and types and estimated rates of application.

ii. Monitoring and record-keeping practices.

iii. All required licensing documentation in accordance with State pesticide application laws and regulations.

f. Any individual applying pesticides must first read the appropriate

Manufacturer’s Safety Data Sheet (SDS) and take necessary precautions to limit negative effects to human health and safety and/or the environment. SDSs must be available to all employees, contract employees, and any other individuals who may be exposed potentially in areas where pesticide mixing or application is performed as required by the Occupational Safety and Health Administration.

g. All NCA cemeteries will have site-specific Cemetery Emergency Plans available to staff in accordance with current NCA Directive 0320 – NCA Emergency Preparedness

Program. First aid, cleanup, and other appropriate equipment and supplies must be available at all times.

h. NCA National Cemeteries will landscape with pest resistant plant varieties and use cultivation, pruning, fertilizing, and irrigation practices that discourage pest development. Cemetery staff will remove potential sources of food, shelter, and water in structures and the landscape that may attract pests.

i. All National Cemeteries will follow reporting and recordkeeping procedures as specified in the accompanying Cemetery Operations 41-SOP-28 IPM.

4. RESPONSIBILITIES:

a. Executive Director, Cemetery Operations, is responsible for establishing policies and procedures for the Integrated Pest Management program to ensure VA national cemeteries implement pest management activities in a safe, healthy manner while controlling environmental impacts.

b. NCA General Engineer and/or Environmental Protection Specialist, Design and Construction Service, is responsible for developing and publishing an NCA

Directive 0057, Environmental Management Program and providing environmental expertise in regard to IPM activities on an as-needed basis.

c. Director, NCA Training and Safety, is responsible for developing and implementing training programs regarding IPM in coordination with NCA Safety and

Environmental Protection Specialist.

d. Deputy Director, NCA Safety, is responsible for:

(1) Developing and implementing, in coordination with NCA Training and NCA’s

Environmental Protection Specialist, safety training programs for IPM staff, including proper pesticide handling, application techniques, personal protective equipment (PPE) use, and emergency response procedures.

(2) Creating safety protocols, including standard operating procedures (SOPs) for pesticide storage, transportation, application, and disposal, as well as non-chemical control methods.

(3) Developing and maintaining emergency response plans for accidents, spills, or exposures related to pest management activities, ensuring staff are trained to respond effectively; and

(4) Working with IPM coordinators, applicators, and other stakeholders to integrate safety considerations into pest management plans, promoting the use of least-toxic methods and sustainable practices.

e. District Executive Directors are responsible for:

(1) Ensuring that all national cemeteries within their district adhere to established policies and procedures for implementing the IPM program.

(2) Making available District Agronomists (or designee) to provide expert consultation and advice to cemetery directors and other designated IPM Coordinators, perform audits, and carry out all other responsibilities identified in this directive.

(3) Providing cemetery staff with resources and training to comply with State certification requirements and maintain applicator licenses.

f. District Agronomists are responsible for:

(1) Serving as NCA subject matter experts for all IPM operations.

(2) Conducting audits of district cemetery’s IPM program records, including purchase inventories, Pesticide Application Logs, storage and disposal records, and associated IPM program audit materials, and working with NCA Cemetery Operations and Cemetery IPM Coordinator to resolve any identified issues.

(3) Providing technical support and advice regarding spills and ensuring timely notification of the District Executive Director or other personnel.

(4) Developing SOW or performance work statement (PWS) for contracted IPM activities, to include reviewing the requirements package to ensure it complies with applicable laws, regulations, VA, and NCA requirements (as Stated in paragraph 3.d.

above) and consulting with NCA Cemetery Operations and NCA Safety as necessary.

(5) Maintaining a list of all State-certified cemetery personnel within the district:

(6) Reviewing site designs for new construction projects to address IPM concerns in advance.

(7) Ensuring Federal, State and local pesticide requirements are followed at all

District cemeteries and working with appropriate Federal and State regional staff on specific local (city, county, etc.) requirements and concerns.

(8) Identifying training resources that target specific regions and/or pests on an as-needed basis.

g. Cemetery Directors, whether serving as the Cemetery IPM Coordinator or directly overseeing the activities of an individual designated to act in that capacity, are responsible for:

(1) Adhering to IPM policies and procedures and implementing IPM plans and activities, to include maintenance of all required records, at the cemetery.

(2) Ensuring staff involved in IPM activities follow established policies, procedures and plans for the safe and proper handling of pesticides from selection through disposal.

(3) Ensuring training requirements are met by all cemetery personnel involved in

IPM activities and resources are available for certification and licensing compliance.

(4) Designating a cemetery employee to serve as the Cemetery IPM Coordinator, if not serving in that capacity, and providing the name and title of the designated individual to the District Agronomist or their designee.

h. Cemetery IPM Coordinator (Cemetery Director or designated individual) is responsible for:

(1) Ensuring cemetery-specific IPM program is developed and implemented in accordance with this policy and the procedures and guidelines specified in Cemetery

Operations 41-SOP-028 Integrated Pest Management Procedures for VA National

Cemeteries and the Safety SOP B33 Pesticide Safety (April 2023).

(2) Continually monitoring and evaluating the cemetery IPM program, including annual evaluation of cemetery use of pesticides to determine if less toxic products may be substituted.

(3) Ensuring that the chemicals used in pest control are registered with the State and applied in accordance with label instructions, pesticide applicators’ laws, and all other local (city, county, etc.), State, and Federal regulations.

(4) Enforcing any additional cemetery-specific restrictions on pesticide use, including those associated with the cemetery property and/or adjacent land uses, natural resource management areas, and/or endangered/protected species, and all other agreements with local (city, county, etc.), State, and Federal agencies.

(5) Selecting employee(s) to attend training to acquire Public Agency Applicator

Certificate(s) and any required State licenses for pesticide application.

(6) Requesting the services of a certified Public Agency Applicator from a VA medical center or, if appropriate, contracting for commercial pest management services.

(7) Ensuring that cemetery employees and/or contractor employees who apply pesticides or otherwise handle pesticides are adequately trained, licensed, or certified in all aspects of Federal, State, and local (city, county, etc.) laws and regulations that apply to the use and handling of pesticides.

(8) Ensuring that employees and contractors use appropriate Personal Protective

Equipment (PPE) when handling or applying pesticides.

(9) Posting appropriate signage in areas visible to the public and staff when pesticide application is planned, and at specific pesticide application location(s) as required by the State and locality.

(10) Ensuring that pesticides are applied only when there are no non-participating individuals within the area to be treated, and that signs are posted to identify treated areas.

(11) Ensuring that the Cemetery Emergency Plan includes procedures to follow if a pesticide is spilled or otherwise unintentionally released into the environment as required by the U.S. Environmental Protection Agency (EPA) and U.S. Occupational Safety and Health Agency regulations and NCA Directive 0320 NCA Emergency Preparedness Program.

(12) Preparing all necessary reports in accordance with applicable laws, regulations, and VA/NCA policy.

(13) Maintaining records of all IPM activities, including Spray Logs, as specified in the Cemetery Operations IPM SOP.

(14) Ensuring the following materials are available to all employees, contractors, and other individuals that may be potentially exposed to pesticides:

i. Material Safety Data Sheets (see IPM SOP paragraph 3.b.)

ii. EPA Handbook, Recognition and Management of Pesticide Poisoning.

i. Cemetery employees involved in IPM are responsible for:

(1) Complying with all training and safety requirements.

(2) Adhering to NCA policy, procedures and guidance regarding IPM activities.

(3) Coordinating cleanup of spills according to the cemetery emergency plan and

District Agronomist instructions.

(4) Reporting spills and corrective actions to the Cemetery IPM Coordinator, Cemetery Director, District Agronomist, and District Director, as appropriate.

5. REFERENCES:

(1) VA Safety Standard Operating Procedure (SOP) B33 Pesticide Safety.

(2) VA Safety SOP B19 Hazard Communication Program.

(3) VA Safety SOP B37 Respiratory Protection Program.

(4) VA Safety SOP B30 Medical Surveillance and Records.

(5) VA Safety SOP B20 Hazardous Materials.

(7) 41-SOP-28 Integrated Pest Management.