A06_Herbicide_SOP.pdf

Standard Operating Procedures for Applying Herbicides identified in Vegetation Treatments Using Herbicides on BLM in 17 Western States Programmatic EIS and incorporated by reference into the Programmatic EIS for Fuels Reduction and Rangeland Restoration in the Great Basin applicable to this project:

General

• Prepare spill contingency plan in advance of treatment.

• Conduct a pretreatment survey before applying herbicides.

• Select herbicide that is least damaging to environment while providing the desired results.

• Select herbicide products carefully to minimize additional impacts from degradates, adjuvants, inert ingredients, and tank mixtures.

• Apply the least amount of herbicide needed to achieve the desired result.

• Follow product label for use and storage.

• Have licensed applicators apply herbicides.

• Use only USEPA-approved herbicides and follow product label directions and “advisory” statements.

• Review, understand, and conform to the “Environmental Hazards” section on the herbicide label. This section warns of known pesticide risks to the environment and provides practical ways to avoid harm to organisms or to the environment.

• Consider surrounding land use before assigning aerial spraying as a treatment method and avoid aerial spraying near agricultural or densely populated areas.

• Minimize the size of application areas, when feasible.

• Comply with herbicide-free buffer zones to ensure that drift will not affect crops or nearby residents/landowners.

• Post treated areas and specify reentry or rest times, if appropriate.

• Notify adjacent landowners prior to treatment.

• Keep copy of Material Safety Data Sheets (MSDSs) at work sites. MSDSs available for review at http://www.cdms.net/.

• Keep records of each application, including the active ingredient, formulation, application rate, date, time, and location.

• Avoid accidental direct spray and spill conditions to minimize risks to resources.

• Consider surrounding land uses before aerial spraying.

• Avoid aerial spraying during periods of adverse weather conditions (snow or rain imminent, fog, or air turbulence).

• Make helicopter applications at a target airspeed of 40 to 50 miles per hour (mph), and at about 30 to 45 feet above ground.

• Take precautions to minimize drift by not applying herbicides when winds exceed >10 mph

(>6 mph for aerial applications) or a serious rainfall event is imminent.

• Use drift control agents and low volatile formulations.

• Conduct pre-treatment surveys for sensitive habitat and special status species within or adjacent to proposed treatment areas.

• Consider site characteristics, environmental conditions, and application equipment in order to minimize damage to non-target vegetation.

• Use drift reduction agents, as appropriate, to reduce the drift hazard to non-target species.

• Turn off applied treatments at the completion of spray runs and during turns to start another spray run.

• Refer to the herbicide label when planning revegetation to ensure that subsequent vegetation would not be injured following application of the herbicide.

http://www.cdms.net/

• Clean OHVs to remove seeds.

Air Quality: See Manual 7000 (Soil, Water, and Air Management)

• Consider the effects of wind, humidity, temperature inversions, and heavy rainfall on herbicide effectiveness and risks.

• Apply herbicides in favorable weather conditions to minimize drift. For example, do not treat when winds exceed 10 mph (6 mph for aerial applications), or rainfall is imminent.

• Use drift reduction agents, as appropriate, to reduce the drift hazard.

• Select proper application equipment (e.g., spray equipment that produces 200- to 800-micron diameter droplets [spray droplets of 100 microns and less are most prone to drift]).

• Select proper application methods (e.g., set maximum spray heights, use appropriate buffer distances between spray sites and non-target resources).

Soil: See Manual 7000 (Soil, Water, and Air Management)

• Minimize treatments in areas where herbicide runoff is likely, such as steep slopes when heavy rainfall is expected.

• Minimize use of herbicides that have high soil mobility, particularly in areas where soil properties increase the potential for mobility.

• Do not apply granular herbicides on slopes of more than 15% where there is the possibility of runoff carrying the granules into non-target areas. Water Resources See Manual 7000 (Soil, Water, and Air Management)

• Consider climate, soil type, slope, and vegetation type when developing herbicide treatment programs.

• Select herbicide products to minimize impacts to water. This is especially important for application scenarios that involve risk from active ingredients in a particular herbicide, as predicted by risk assessments.

• Use local historical weather data to choose the month of treatment. Considering the phenology of the target species, schedule treatments based on the condition of the water body and existing water quality conditions.

• Plan to treat between weather fronts (calms) and at appropriate time of day to avoid high winds that increase water movements, and to avoid potential stormwater runoff and water turbidity.

• Review hydrogeologic maps of proposed treatment areas. Note depths to groundwater and areas of shallow groundwater and areas of surface water and groundwater interaction.

Minimize treating areas with high risk for groundwater contamination.

• Conduct mixing and loading operations in an area where an accidental spill would not contaminate an aquatic body.

• Do not rinse spray tanks in or near water bodies. Do not broadcast pellets where there is danger of contaminating water supplies.

• Maintain buffers between treatment areas and water bodies. Buffer widths should be developed based on herbicide- and site-specific criteria to minimize impacts to water bodies.

• Minimize the potential effects to surface water quality and quantity by stabilizing terrestrial areas as quickly as possible following treatment.

Wetlands and Riparian Areas

• Use a selective herbicide and a wick or backpack sprayer.

• Use appropriate herbicide-free buffer zones for herbicides not labeled for aquatic use based on risk assessment guidance, with minimum widths of 100 feet for aerial, 25 feet for vehicle, and 10 feet for hand spray applications.

Vegetation: See Handbook H-4410-1 (National Range Handbook), and manuals 5000 (Forest Management) and 9015 (Integrated Weed Management)

• Refer to the herbicide label when planning revegetation to ensure that subsequent vegetation would not be injured following application of the herbicide.

• Use native or sterile species for revegetation and restoration projects to compete with invasive species until desired vegetation establishes.

• Use weed-free feed for horses and pack animals. Use weed-free straw and mulch for revegetation and other activities.

• Identify and implement any temporary domestic livestock grazing and/or supplemental feeding restrictions needed to enhance desirable vegetation recovery following treatment.

Consider adjustments in the existing grazing permit, needed to maintain desirable vegetation on the treatment site.

Pollinators

• Complete vegetation treatments seasonally before pollinator foraging plants bloom.

• Time vegetation treatments to take place when foraging pollinators are least active both seasonally and daily.

• Design vegetation treatment projects so that nectar and pollen sources for important pollinators and resources are treated in patches rather than in one single treatment.

• Minimize herbicide application rates. Use typical rather than maximum rates where there are important pollinator resources.

• Maintain herbicide free buffer zones around patches of important pollinator nectar and pollen sources. • Maintain herbicide free buffer zones around patches of important pollinator nesting habitat and hibernacula.

• Make special note of pollinators that have single host plant species and minimize herbicide spraying on those plants (if invasive species) and in their habitats.

Fish and Other Aquatic Organisms: See manuals 6500 (Wildlife and Fisheries Management) and 6780 (Habitat Management Plans)

• Use appropriate buffer zones based on label and risk assessment guidance.

• Minimize treatments near fish-bearing water bodies during periods when fish are in life stages most sensitive to the herbicide(s) used and use spot rather than broadcast or aerial treatments.

• Use appropriate application equipment/method near water bodies if the potential for off-site drift exists.

• For treatment of aquatic vegetation, 1) treat only that portion of the aquatic system necessary to achieve acceptable vegetation management; 2) use the appropriate application method to minimize the potential for injury to desirable vegetation and aquatic organisms; and 3) follow water use restrictions presented on the herbicide label.

Wildlife: See manuals 6500 (Wildlife and Fisheries Management) and 6780 (Habitat Management Plans)

• Use herbicides of low toxicity to wildlife, where feasible.

• Use spot applications or low-boom broadcast operations where possible to limit the probability of contaminating non-target food and water sources, especially non-target vegetation over areas larger than the treatment area.

• Use timing restrictions (e.g., do not treat during critical wildlife breeding or staging periods) to minimize impacts to wildlife.

• Avoid using glyphosate formulations that include R-11 in the future, and either avoid using any formulations with POEA, or seek to use the formulation with the lowest amount of POEA available, to reduce risks to amphibians. Threatened, Endangered, and Sensitive Species See Manual 6840 (Special Status Species)

• Survey for special status species before treating an area. Consider effects to special status species when designing herbicide treatment programs.

• Use a selective herbicide and a wick or backpack sprayer to minimize risks to special status plants.

• Avoid treating vegetation during time-sensitive periods (e.g., nesting and migration, sensitive life stages) for special status species in area to be treated.

Livestock: See Handbook H-4120-1 (Grazing Management)

• Whenever possible and whenever needed, schedule treatments when livestock are not present in the treatment area. Design treatments to take advantage of normal livestock grazing rest periods, when possible.

• As directed by the herbicide label, remove livestock from treatment sites prior to herbicide application, where applicable.

• Use herbicides of low toxicity to livestock, where feasible.

• Take into account the different types of application equipment and methods, where possible, to reduce the probability of contamination of non-target food and water sources.

• Avoid use of diquat in riparian pasture while pasture is being used by livestock.

• Notify permittees of the project to improve coordination and avoid potential conflicts and safety concerns during implementation of the treatment.

• Notify permittees of livestock grazing, feeding, or slaughter restrictions, if necessary.

• Provide alternative forage sites for livestock, if possible.

Wild Horses and Burros

• Minimize using herbicides in areas grazed by wild horses and burros.

• Use herbicides of low toxicity to wild horses and burros, where feasible.

• Remove wild horses and burros from identified treatment areas prior to herbicide application, in accordance with label directions for livestock.

• Take into account the different types of application equipment and methods, where possible, to reduce the probability of contaminating non-target food and water sources.

Cultural Resources and Paleontological Resources:

• See handbooks H-8120-1 (Guidelines for Conducting Tribal Consultation) and H8270-1 (General Procedural Guidance for Paleontological Resource Management), and manuals 8100 (The Foundations for Managing Cultural Resources), 8120 (Tribal Consultation Under Cultural Resource Authorities), and 8270 (Paleontological Resource Management), See also: Programmatic Agreement among the Bureau of Land Management, the Advisory Council on Historic Preservation, and the National Conference of State Historic Preservation Officers Regarding the Manner in Which BLM Will Meet Its Responsibilities Under the National Historic Preservation Act.

• Follow standard procedures for compliance with Section 106 of the National Historic Preservation Act as implemented through the Programmatic Agreement among the Bureau of Land Management, the Advisory Council on Historic Preservation, and the National Conference of State Historic Preservation Officers Regarding the Manner in Which BLM Will Meet Its Responsibilities Under the National Historic Preservation Act and state protocols or 36 CFR Part 800, including necessary consultations with State Historic Preservation Officers and interested tribes.

• Follow BLM Handbook H-8270-1 (General Procedural Guidance for Paleontological Resource Management) to determine known Condition I and Condition 2 paleontological areas or collect information through inventory to establish Condition 1 and Condition 2 areas, determine resource types at risk from the proposed treatment, and develop appropriate measures to minimize or mitigate adverse impacts.

• Consult with tribes to locate any areas of vegetation that are of significance to the tribe and that might be affected by herbicide treatments.

• Work with tribes to minimize impacts to these resources.

• Follow guidance under Human Health and Safety in areas that may be visited by Native peoples after treatments.

Visual Resources: See handbooks H-8410-1 (Visual Resource Inventory) and H-8431-1 (Visual Resource Contrast Rating), and manual 8400 (Visual Resource Management)

• Minimize the use of broadcast foliar applications in sensitive watersheds to avoid creating large areas of browned vegetation.

• Consider the surrounding land use before assigning aerial spraying as an application method.

• Minimize off-site drift and mobility of herbicides (e.g., do not treat when winds exceed 10 mph; minimize treatment in areas where herbicide runoff is likely; establish appropriate buffer widths between treatment areas and residences) to contain visual changes to the intended treatment area.

• If the area is a Class I or II visual resource, ensure that the change to the characteristic landscape is low and does not attract attention (Class I), or if seen, does not attract the attention of the casual viewer (Class II).

• Lessen visual impacts by: 1) designing projects to blend in with topographic forms; 2) leaving some low-growing trees or planting some low-growing tree seedlings adjacent to the treatment area to screen short-term effects; and 3) revegetating the site following treatment.

• When restoring treated areas, design activities to repeat the form, line, color, and texture of the natural landscape character conditions to meet established Visual Resource Management (VRM) objectives.

Rights-of-way

• Coordinate vegetation management activities where joint or multiple use of a ROW exists.

• Notify other public land users within or adjacent to the ROW proposed for treatment.

• Use only herbicides that are approved for use in ROW areas.

Human Health and Safety

• Establish a buffer between treatment areas and human residences based on guidance given in the HHRA, with a minimum buffer of ¼ mile for aerial applications and 100 feet for ground applications, unless a written waiver is granted.

• Use protective equipment as directed by the herbicide label.

• Post treated areas with appropriate signs at common public access areas.

• Observe restricted entry intervals specified by the herbicide label.

• Provide public notification in newspapers or other media where the potential exists for public exposure.

• Have a copy of MSDSs at work site.

• Notify local emergency personnel of proposed treatments.

• Contain and clean up spills and request help as needed.

• Secure containers during transport.

• Follow label directions for use and storage.

• Dispose of unwanted herbicides promptly and correctly.