Attachment_A_-_CAARNG_Integrated_Pest_Management_Plan.pdf

Attachment A: CMD Integrated Pest Management Plan

CAARNG Integrated Pest Management Plan

1 Signature Page

Technical Review:

Michael Moore Integrated Pest Management Coordinator

OBERG.JOHN.CLIFFORD.1078671200

Col (CA) John C. Oberg Environmental Program Manager

John T. Yunker ARNG Pest Management Consultant

Approval:

DAVID S. BALDWIN

Major General The Adjutant General i

February 2020

Date:

Digitally signed by OBERGJOHN.CLIFFORD.1078671200 Date: 2020.03.03 13:23:01 -08'00'

CAARNG Integrated Pest Management Plan February 2020 ii

Table of Contents

1 Signature Page ............................................................................................................................. i

2 Executive Summary:

3 Background:

3.1 Purpose:

3.2 Authority:

3.3 Plan Maintenance:

4 Responsibilities

4.1 The Adjutant General

4.2 Integrated Pest Management Coordinator (IPMC)

4.3 Pest Management Quality Assurance Evaluator (PMQAE) / Area Coordinators

4.4 Pest Management Provider (PMP)

4.5 Pest Management Contractors

4.6 Construction and Facility Management Office (CFMO)

4.7 Directorate of Operations, Training & Mobilization

4.8 Facility Managers and Maintenance Personnel

4.9 State Surgeon

4.10 Unit Commanders

4.11 Building Occupants

4.12 Self-Help Program Participants

5 Integrated Pest Management

5.1 Legal Mandate

5.2 Operations

6 Priority of Pest Management

6.1 Disease Vectors and Public Health Pests

6.2 Quarantine and Regulated Pests

6.3 Vertebrate Pests

6.4 Structural Pests

6.5 Pests Found In and Around Buildings

6.6 Noxious and Invasive Plants and Animals

iii

6.7 Undesired Vegetation

7 Health and Safety

7.1 Medical Surveillance of Pest Management Personnel

7.2 Hazard Communication

7.3 Personal Protective Equipment

7.4 Fire Protection

7.5 Pest Management Vehicle(s)

7.6 Protection of the Public

7.7 Pesticide Shop Health, Safety, and Hazards

8 Environmental Considerations

8.1 Sensitive Areas

8.2 Endangered or Protected Species and Critical Habitats

8.3 Cultural and Historical Sites

8.4 Environmental Documentation

8.5 Pesticide Spills and Remediation

8.6 Climate Change

9 Program Administration

9.1 Pest Management Operations

9.3 Outleases

9.4 Interservice Support Agreements

9.5 Reports and Records

9.6 Training and Certification

9.7 Pesticide Security

10 Sale and Distribution of Pesticides

11 IPM References and Links

11.1 Federal Laws

11.2 Directives and Instructions

11.3 DOD Regulations and Policy

11.4 Other References, Manuals, Books and Guides

LIST OF APPENDICES

Appendix A – Federally-owned CAARNG Sites ....................................................................... A-1 iv

Appendix B – Integrated Pest Management (IPM) Outlines ...................................................... B-1

Appendix C – CAARNG State Pesticide Use List (SPUL) ........................................................ C-1

Appendix D – CAARNG Pest Management Treatment Record ................................................ D-1

Appendix E – CAARNG Self-Help Program .............................................................................. E-1

Pesticides Approved for use by Self-Help Program Participants: ....................................... E-3

CAARNG Self-Help IPM Outlines: .................................................................................... E-7

Appendix F – IPM Points of Contact ........................................................................................... F-1

Appendix G – National Environmental Policy Act (NEPA) Documentation ............................. G-1

Appendix H – Program Update Form (PUF) .............................................................................. H-1

Appendix I – IPMC Appointment Memo ..................................................................................... I-1

Appendix J – Definitions and Glossary ....................................................................................... J-1

Appendix K – Pest Management Provider Certifications ........................................................... K-1

Appendix L –Threatened, Endangered, Special Status and invasive Species ............................. L-1

2 Executive Summary:

Pests can interfere with the military mission, damage real property and the environment, increase maintenance costs and expose personnel to diseases unless properly controlled. As per Army Regulation (AR) 200-1, the Army National Guard’s (ARNG) pest management program uses integrated pest management (IPM) to achieve effective pest control with minimal environmental impacts. IPM, as used by the CAARNG, is an approach that utilizes all available techniques in an organized program to suppress pest populations in an effective, economical and environmentally safe manner. The techniques of IPM include cultural, physical, mechanical, biological, and chemical controls. IPM strategies depend on surveillance to establish the need for pest control and to monitor the effectiveness of management efforts. Pest control is done by need rather than by schedule with limited use of preventative treatments (common exceptions are pre-emergent herbicides, mosquito larvicide and some fungicide treatments). Pests are controlled to acceptable levels and not always completely eliminated.

The contents of this Integrated Pest Management Plan (IPMP) apply to all activities and individuals working at CAARNG sites and will be implemented to the maximum extent possible.

At no time will pest management operations be done in a manner that will cause harm to personnel or violate the law. The application of pesticides is governed by the label. No pesticide will be applied contrary to its label.

This plan describes CAARNG’s pest management requirements, outlines the resources necessary for surveillance and control, and describes the administrative, safety and environmental requirements of the CAARNG IPM program. The first step in pest management begins with the individuals who occupy or maintain buildings, open spaces, or forests through a cost-effective Self-Help Program. For pests that cannot be controlled through Self-Help, the program uses pest management providers, who have the necessary state and/or Department of Defense (DOD) certifications, to control pests using the procedures found in the IPM Outlines (Appendix B). If needed, contracted pest control services are administered and funded by the Construction and Facilities Management Office (CFMO), with IPM technical guidance provided by the Integrated Pest Management Coordinator (IPMC) and quality assurance by the IPMC and/or Pest Management Quality Assurance Evaluator (PMQAE). Additional responsibilities of pest management personnel are detailed in Section 4 of this plan.

This plan is a working document and will be continually updated to reflect actual pest management and the IPM program practices.

3 Background:

3.1 Purpose:

This IPMP is a framework that defines how pest management is accomplished by the CAARNG.

The plan identifies elements of the program to include health and environmental safety, pest identification, and pest management, as well as pesticide storage, transportation, use and disposal. This plan is used as a tool to reduce reliance on pesticides, to enhance environmental protection, and to maximize the use of IPM techniques.

3.2 Authority:

3.2.1 Federal Insecticide, Fungicide, and Rodenticide Act, (FIFRA)

3.2.2 Integrated Pest Management Memorandum from the President. August 2, 1979

3.2.3 Department of Defense Instruction (DODI) 4150.07, DOD Pest Management Program, 29 May 2008

3.2.4 Army Regulation (AR) 200-1, Environmental Protection and Enhancement, 13 December

3.2.5 Memorandum, ARNG-ILE, 04 February 2016, subject: Integrated Pest Management Program Policy

3.2.6 State of California, Department of Pesticide Regulation, Structural Pest Control Act, November 2010

3.2.7 Title 3 California Code of Regulations (CCR) Food and Agriculture Division 6, Pesticides and Pest Control Operations discusses the California Division of Occupational Safety and Health (Cal/OSHA) requirements for workers safety more information is available at the following: http://www.dir.ca.gov/dosh/dosh1.html

3.2.8 3 CCR Division 4, Plant Industry. Chapters 3, 5, and 6 covers plant and rodent pest control

3.3 Plan Maintenance:

3.3.1 The IPMC maintains this plan.

3.3.2 Updates to the plan are made when necessary by the IPMC. Updates to the plan can be in the form of an attached memorandum that is referenced in the affected section of the plan.

Minor changes can also be notated directly in the plan and initialed by the IPMC.

3.3.3 Plan review and approval are conducted in accordance with DOD, Department of the Army (DA) and ARNG policies and directives. This IPMP will be reviewed annually by the http://www.dir.ca.gov/dosh/dosh1.html

IPMC during the preparation of the annual Plan Update Form (PUF) (an example PUF is in Appendix H). A completed PUF will be the documentation of the annual plan review. Annual updates of this plan are sent, via the PUF, to the ARNG Pest Management Consultant (PMC) no later than 15 October.

3.3.4 This plan will be revised every five years. Revisions will formally incorporate the annual updates and any other changes to the program that have occurred since the last revision.

Complete rewriting of the IPMP during the revision process is not required unless substantial program changes have occurred. Revised IPMPs are reviewed by the ARNG PMC for technical accuracy and sufficiency and are signed by The Adjutant General (TAG). Additional signees of the IPMP are specified in DODI 4150.07.

4 Responsibilities

4.1 The Adjutant General (TAG) TAG is considered the “Installation Commander” of the virtual installation in regard to the requirements in DODI 4150.07, AR 200-1 and the ARNG Integrated Pest Management Program Policy Memorandum, and has ultimate responsibility for pest management actions at both State and Federally-owned (Appendix A) CAARNG sites.

4.1.1 Approve and support the IPMP.

4.1.2 Designate an Integrated Pest Management Coordinator (IPMC) to oversee all pest management activities. Approval of this plan constitutes the written appointment of the listed IPMC, or the IPMC can be appointed with a signed memo (Appendix I).

4.1.3 Ensure that CAARNG personnel performing pest control as a part of their assigned duties receive adequate training (in accordance with Section 9.6 of this plan), and, when required, obtain appropriate pest management certification(s).

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

4.2 Integrated Pest Management Coordinator (IPMC)

4.2.1 Prepare and maintain the IPMP with 5-year revisions.

4.2.2 Annually review and update the IPMP as needed.

4.2.3 Ensure all pesticides are approved by the ARNG PMC prior to their use at CAARNG Federally-owned (Appendix A) sites and all pesticide used at CAARNG sites are listed on the CAARNG State Pesticide Use List (SPUL) (Appendix C).

4.2.4 Coordinate with personnel conducting pest surveillance and/or control to ensure all applicable information is recorded and reported as required by the directives cited in Section 3.2 and this plan.

4.2.5 Function as a point of contact between those individuals who store and apply pesticides (e.g., facility management, pest control contractors) and activities or individuals who document, regulate, manage or are impacted by pesticide usage at CAARNG sites (e.g., Environmental Office, Safety Office, Fire Department, and Industrial Hygienist).

4.2.6 Coordinate with the CAARNG Natural Resources Manager (NRM) about pest control actions in semi-improved or unimproved grounds where there may be endangered, threatened or sensitive animals (including insects) or plants.

4.2.7 Coordinate with the CAARNG Cultural Resources Manager (CRM) when pest control actions may impact native plants of interest to the Tribes, cultural sites, or affect a building eligible for the National Register of Historic Places.

4.2.8 Coordinate with the CAARNG Directorate of Plans, Training, Mobilization and Security (DPTMS) for all pest management performed on training or maneuver land.

4.2.9 Coordinate with local health officials to determine the prevalence of disease vectors and other public health pests in the area surrounding CAARNG sites. Oversee surveillance at CAARNG sites for known vectors for diseases such as West Nile, Dengue, Chikungunya and Zika viruses.

4.2.10 Coordinate with the State Surgeon on any necessary measures for control of disease vectors and other public health pests at CAARNG sites.

4.2.11 Oversee, manage, monitor and document the technical aspects of the Self-Help Program (Appendix E) with respect to pest control products and training of program participants.

4.2.12 Monitor certification and continuing pest management training for pesticide applicators at CAARNG sites. Maintain copies of current certifications in Appendix K of this plan.

4.2.13 Coordinate with the CFMO to ensure that contracts including pest management activities at CAARNG Federally-owned (Appendix A) sites are forwarded to the ARNG PMC for technical accuracy and sufficiency review prior to solicitation of the contract. For contracted pre-construction treatment of soil to control termites at Federally-owned CAARNG sites (Appendix A), ARNG PMC review and approval of the termite management section of contracts is not required if the contract language is in accordance with the current Unified Facilities Guide Specification for chemical termite control.

4.2.14 Ensure that pest management contracts at CAARNG Federally-owned (Appendix A) sites with efforts that exceed 0.25 work-years are monitored by a certified PMQAE.

4.2.15 Coordinate with local, state and federal agencies, as necessary, to conduct the CAARNG IPM program in accordance with federal, state, and local laws and regulations that apply to pest management, pesticide use, applicator certification, record-keeping, and reporting.

4.2.16 Provide answers to questions concerning pest management from Commanders, ARNG Directorate, Headquarter Department of Army (HQDA), and interested state agencies.

4.2.17 Perform design review of new construction and landscaping projects to ensure that pest entry points and potential harborage sites have been eliminated and that proper preconstruction termite treatment is included in project specifications.

4.2.18 Prepare, with assistance from a PMC certified in DOD Category 11: Aerial Application Pest Control, an Aerial Spray Statement of Need (ASSON) for any potential aerial application of pesticides to Federally-owned (Appendix A) CAARNG sites.

4.2.19 Obtain IPMC certification within two years of being appointed to the position and maintain certification with refresher training every three years.

4.3 Pest Management Quality Assurance Evaluator (PMQAE) / Area Coordinators

4.3.1 Monitor pest management contracts at CAARNG sites when total efforts exceed 0.25 work-years.

4.3.2 Obtain PMQAE certification and maintain certification with refresher training every three years.

4.3.3 If an installation’s pest management contract efforts are less than 0.25 work-years, the presence of a trained PMQAE at the installation is not mandatory.

4.4 Pest Management Provider (PMP)

4.4.1 Use IPM techniques to the maximum extent possible.

4.4.2 Maintain current DOD or California Depart of Pesticide Regulation certification to apply pesticides in the category of pest control for work being done at CAARNG sites and comply with all state and federal regulations. Send a copy of the certification to the IPMC annually for inclusion in Appendix K of this plan.

4.4.3 Control pests according to the provisions of this plan, in accordance with California state and local laws and regulations, and DOD, Army and ARNG instructions, regulations and policies (DODI 4150.07, AR 200-1, ARNG Integrated Pest Management Program Policy Memorandum).

4.4.4 Conduct surveillance for mosquitoes, ticks, cockroaches, or other pests that could adversely affect the health and welfare of installation personnel.

4.4.5 Operate in a manner that minimizes risk to personnel and the environment.

4.4.6 When using pesticides, always read and follow the label. The label is the law.

4.4.7 Keep records of all pest surveillance and control efforts and provide reports to the IPMC using the format(s) and at the frequency as specified in this plan.

4.4.8 Maintain effective liaison with county, state, and federal health and environmental officials, as necessary.

4.5 Pest Management Contractors

4.5.1 Use IPM and conduct pest management in accordance with this plan, including ARNG PMC pre-approval of pesticides applied at CAARNG sites.

4.5.2 Comply with all federal, state, and local laws and regulations.

4.5.3 When using pesticides, always read and follow the label. The label is the law.

4.5.4 Submit written records of all pest management activities to the IPMC or PMQAE using the format(s) and at the frequency as specified by the directives cited in Section 3.2 of this plan and the contract.

4.6 Construction and Facility Management Office (CFMO)

4.6.1 Determine the pest management requirements for the CAARNG sites and request appropriate funding to support contracted pest control operations.

4.6.2 Ensure that CAARNG personnel performing pest control as a part of their assigned duties receive adequate training (in accordance with Section 9.6 of this plan), and achieve pest management certification, as required.

4.6.3 Ensure all pest management activities, including those that are part of the Self-Help Program, are recorded in accordance with this plan and reports are provided to the IPMC at intervals as specified in this plan. Maintain records of pest management operations as required by the directives cited in Section 3.2 and this plan.

4.6.4 Request and monitor contracted pest control operations.

4.6.5 Coordinate with the IPMC to ensure that contracts including pest management activities at CAARNG Federally-owned (Appendix A) sites are forwarded to the ARNG PMC for review for technical sufficiency prior to solicitation of the contract. For contracted pre-construction treatment of soil to control termites at CAARNG Federally-owned (Appendix A) sites, ARNG PMC review and approval of the termite management section of contracts is not required if the contract language is in accordance with the current Unified Facilities Guide Specification for chemical termite control.

4.6.6 Provide a copy of each finalized pest control contract to the IPMC within 90 days.

4.6.7 Initiate requests for aerial application of pesticides, when necessary.

4.6.8 Stray animal control is coordinated and performed by the CFMO using in-house personnel, contracted personnel and/or through an agreement with the local municipal animal control authorities.

4.7 Directorate of Operations, Training & Mobilization

4.7.1 Determine the pest management requirements for the CAARNG training and maneuver lands and request appropriate ITAM funding when pests are impeding training/maneuvers.

4.7.2 For management of pests that are not impeding training/maneuvers (e.g., hornet nests in bivouac areas, noxious/invasive weeds in maneuver areas, etc.), ensure the use of all non-chemical pest control techniques as recommended in the IPM outlines (Appendix B) before requesting further assistance from the CFMO for in-house or contracted pest control.

4.7.3 Coordinate with the IPMC any pest management activities occurring on CAARNG training and maneuver lands.

4.7.4 Ensure all pest management activities on training and maneuver lands, including those that are part of the Self-Help Program, are performed in accordance with this plan, including the recording and reporting of pesticide usage.

4.7.5 Request and assist with the monitoring of contracted pest control operations.

4.7.6 Coordinate with the IPMC to ensure that contracts including pest management activities at CAARNG Federally-owned (Appendix A) training and maneuver lands are forwarded to the ARNG PMC for review for technical sufficiency prior to solicitation of the contract.

4.7.7 Initiate requests for aerial application of pesticides, when necessary.

4.8 Facility Managers and Maintenance Personnel

4.8.1 Ensure the application of good sanitary practices, landscape maintenance, and materials management to prevent pest infestations.

4.8.2 Use all non-chemical pest control techniques as recommended in the IPM outlines (Appendix B) before requesting further assistance from the CFMO or Area Coordinator for in-house or contracted pest control.

4.8.3 Ensure all pest management activities, including those that are part of the Self-Help Program, are recorded in accordance with this plan and reports are provided to the IPMC at intervals specified in this plan.

4.8.4 Cooperate fully with pest management personnel in scheduling pest management operations, to include preparing the areas to be treated.

4.8.5 Have available on-site Safety Data Sheets (SDSs) for any pesticide stored or used on the premises.

4.9 State Surgeon

4.9.1 Evaluate the human health aspects of the IPM program.

4.9.2 Coordinate with the IPMC on any necessary human health-related measures for control of disease vectors and other public health pests at CAARNG sites.

4.10 Unit Commanders

4.10.1 Ensure the proper use of the DOD Arthropod Repellent System and other personal protective measures when troops are exposed to potential disease vectors such as mosquitoes and ticks.

4.10.2 Brief troops on potential biological threats (such as poison oak) before training exercises.

4.10.3 Appoint a field sanitation team for each company, troop, or battery-size unit. Ensure that field sanitation teams are trained and supplied and mission capable prior to deployment.

4.11 Building Occupants

4.11.1 Utilize good sanitary practices to prevent pest infestations. Keep all areas free of open food containers. Don’t accumulate pest harborage materials such as empty boxes or dunnage.

4.11.2 Cooperate fully with contractors and CFMO personnel in scheduling pest management operations, to include preparing the areas to be treated.

4.11.3 Report all pest management issues to the CFMO, Area Coordinator, or IPMC.

4.12 Self-Help Program Participants

4.12.1 Self-Help Program Participants are generally maintenance workers, but Self-Help is available to all CAARNG members and employees.

4.12.2 Keep all areas clean, dry, and sanitary. Keep all areas free of open food containers.

Don’t accumulate pest harborage materials such as empty boxes or dunnage.

4.12.3 Use the IPM outlines in Appendix B to determine if Self-Help is allowed for the pest problem.

4.12.4 If Self-Help is appropriate, follow the requirements found in Appendix E covering the Self-Help Program. Only pesticides that are pre-approved for Self-Help Program use and listed as such on the CAARNG SPUL (Appendix C) are allowed. All training, recording, reporting, handling and storage of pesticides must be done as specified under the Self-Help Program and in accordance with the pesticide label.

4.12.5 If Self-Help is not appropriate for the pest or level of the pest problem, fill out a work-order requesting assistance with your pest problem and submit it to the Facility Manager.

4.12.5 When using pesticides as part of the Self-Help Program, always read and follow the label.

The label is the law.

5 Integrated Pest Management

5.1 Legal Mandate

5.1.1 “Integrated Pest Management Memorandum from the President. August 2, 1979” that emphasizes the utilization of IPM techniques and encourages the use of IPM for economic and environmental benefits.

5.2 Operations

5.2.1 The four basic principles of IPM work together to provide long term control of pest populations at acceptable levels with the least detrimental impact on the environment. Although the use of the least‐toxic pesticide is an integral part of IPM, non‐chemical control is emphasized. Use of pesticides is almost always a temporary measure and often more expensive if used regularly. Non‐chemical control may initially be more expensive, but will usually be more cost effective long-term with ongoing pest management. Non‐chemical controls have the added advantage of being less toxic which reduces the potential risk to human health and the environment. Surveillance and monitoring of pests are stressed in an IPM program since it is important to determine the cause of the pest infestation and the most effective management of the problem. Insect and vertebrate pests require food, water, and harborage (a place to rest or breed). Long term control is dependent upon eliminating or restricting pests’ access to these requirements.

5.2.2 Mechanical and Physical Control: This type of control alters the environment where pests live, excludes pests, or traps and removes pests where they are not wanted. Examples of mechanical and physical control include: harborage elimination in structures through caulking or filling voids, screening, mechanical traps or glue boards, and nets and other barriers to prevent entry into buildings.

5.2.3 Cultural Control: Strategies in this method involve manipulating environmental conditions to suppress or eliminate pests. For example, judicious sanitation at dining facilities reduces the attractiveness of the area to flocks of birds that may cause increased air strike hazard.

Replacing ornamental trees and shrubbery with native plants that are less attractive to defoliating pests is another cultural measure.

5.2.4 Biological Control: In this control strategy, predators, parasites or disease organisms are used to control pest populations. For example, the introduction of ragwort flea beetle, and the cinnabar moth have dramatically reduced the prevalence of tansy ragwort. Release of these biological controls in infested areas can eliminate tansy ragwort at that location. Introduction of new biological controls is the responsibility of the United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), Plant Protection and Quarantine, Biological Control Program.

5.2.5 Chemical Control: Pesticides kill living organisms, whether they are plants, insects or other animals. At one time, pesticides were considered to be the most effective control available, but pesticide resistance has rendered many ineffective. In recent years, the trend has been to use pesticides that have limited residual action. While reducing human exposure and lessening environmental impact, the cost of chemical control has risen due to requirements for more frequent application. Since personal protection and special handling and storage requirements are necessary with the use of pesticides, the overall cost of chemical control can be quite high when compared with non‐chemical control methods. However, the use of chemicals may be warranted to control some pests and invasive species when other control methods are not sufficiently effective.

6 Priority of Pest Management

Priorities of pest control operations are in the order shown below. Pests that affect the health of CAARNG personnel are of greatest importance. Other important pests included in this section are pests that damage real property, food and other commodities and those that are a threat to natural resources.

6.1 Disease Vectors and Public Health Pests

6.1.1 Mosquito species have the potential to transmit Western equine encephalitis, St. Louis encephalitis, West Nile virus, Zika virus, Dengue, Chikungunya and other diseases. Mosquito-borne virus transmission is usually most prevalent from June through October when mosquitoes are most abundant.

6.1.2 Ticks may transmit disease organisms (such as Lyme disease). Personnel conducting outdoor activities can minimize tick exposure by wearing appropriate clothing (see DOD Arthropod Repellent System), applying tick repellent, and performing personal hygiene inspections (with bathing) daily.

6.1.3 Some spiders (such as Brown Recluse) and stinging insects may produce painful bites as well as toxic reactions. Bees and wasps may produce allergic reactions in some individuals.

6.1.4 Scorpions and black widow spiders are usually encountered in undisturbed areas. They are venomous and the stings are painful, but typically cause few problems to personnel who are not allergic.

6.1.5 Venomous snakes are capable of causing serious illness or death. Snakes, even when non-venomous, may have painful bites. Snakes found in areas where they are not wanted are captured alive and relocated to other areas away from ongoing activities.

6.1.6 Skunks, foxes, raccoons and bats may be infected with rabies. Since these animals may be found in or under buildings, the disease potential should be considered when doing control work with these animals. Bat feces may contain several fungi which, when aerosolized and inhaled, can cause potentially fatal illnesses. Utilize appropriate Personal Protective Equipment (PPE) when cleaning bat-contaminated areas.

6.1.7 Deer flies may transmit tularemia through their bites, but contracting the disease in this manner rarely occurs.

6.1.8 Mice occasionally invade buildings and cause damage to food and other products. In addition, mice present a potential human health threat of Hantavirus pulmonary syndrome (HPS).

This disease results from the inhalation of the aerosolized virus found in the feces and urine of rodents, particularly deer mice (Peromyscus maniculatus). Although this disease is relatively rare, the high fatality rate (50 percent) makes it significant in the range where it occurs. Utilize appropriate PPE when either handling or removing mice and/or cleaning mouse-contaminated areas.

6.1.9 Fleas found on rodents can transmit plague. Human plague cases have occurred in the past, but are extremely rare occurrences.

6.2 Quarantine and Regulated Pests

The IPMC will coordinate with the local USDA inspectors to determine requirements regarding inspection of cargo for the presence of eggs, larvae, or adult insects that the USDA has prohibited from entering certain geographic areas. Any retrograde cargo that is received is inspected inside the common carrier (e.g., truck, aircraft) used for transport. If any signs of live pests or plant/soil material are present, the shipping container is to be immediately sealed and impounded to prevent discharge of the contents. Notify the local USDA inspector and determine further disposition of the materiel after a joint inspection. If any quarantine pest is suspected, the Facility Manager notifies the IPMC.

6.3 Vertebrate Pests

6.3.1 Mice and rats occasionally invade buildings. The primary management techniques for controlling these rodents are exclusion and sanitation. Snap traps are the main method used for controlling rodent infestations indoors.

6.3.2 Gophers, moles, prairie dogs, and ground squirrels damage lawns and other turf areas through their burrowing. Some of these rodents may be protected under the Endangered Species Act (ESA) and/or state wildlife regulations it is vital to coordinate with the CAARNG NRM before performing any exterior rodent pest management.

6.3.3 Stray animal control at CAARNG sites is coordinated and performed by the CFMO using in-house personnel, contracted personnel and/or through an agreement with the local municipal animal control authorities.

6.3.4 Wildlife, such as bats, may be protected under the ESA. It is vital to coordinate with the CAARNG NRM before doing any wildlife pest management.

6.3.5 Control efforts for regulated wildlife species, such as coyotes, are coordinated with the USDA APHIS Wildlife Services and California Department of Fish and Wildlife.

6.4 Structural Pests

6.4.1 Birds roost in warehouses, aircraft hangars, maintenance and other buildings and damage equipment and supplies with their droppings. Most birds are protected under the Migratory Bird Treaty Act, so coordination with the CAARNG NRM is necessary before taking any management action.

6.4.2 Due to the high cost of repairing termite damage, infestible structures are periodically inspected for termites or termite damage. Carpenter ants may also damage wooden structures.

6.5 Pests Found In and Around Buildings

6.5.1 Food items located in dining facilities, in armory kitchens or in food storage facilities may become infested by stored food product pests.

6.5.2 Crawling insects (e.g., ants, cockroaches and bedbugs) and spiders may require control in offices, billeting, food service facilities, warehouses and administrative buildings. Proper sanitation and housekeeping is very effective in discouraging these pests.

6.6 Noxious and Invasive Plants and Animals

Invasive plants are species that have few, if any, natural controls in their location and spread out of control. The CAARNG supports the three goals of the National Strategy for Invasive Plant Management: prevention, control, and restoration. Detailed control strategies may also be found in the INRMP if there is one for that site.

6.7 Undesired Vegetation

Weeds along fence lines, on road shoulders, paved surfaces (including runways), other developed areas and training areas may require control using IPM techniques, including the appropriate use of herbicides. Noxious vegetation such as poison oak should be controlled when it grows where it can frequently contact personnel. Often, control of unwanted plants can be done mechanically using mowers and trimmers.

7 Health and Safety

7.1 Medical Surveillance of Pest Management Personnel

Pesticide applicators must read and follow all health and safety information on the label. If applying pesticides requires formal medical surveillance or respirators, CAARNG personnel must work with the CAARNG Safety Office to initiate medical surveillance physical exams, as appropriate. Contractors performing pest management services are responsible for their own medical surveillance program.

7.2 Hazard Communication

Safety Data Sheets (SDSs) for pesticides used are to be made available to all individuals who have contact with these chemicals. Hazard Communication (HAZCOM) training is mandatory for individuals working with hazardous materials, including pesticides.

7.3 Personal Protective Equipment

7.3.1 Personal Protective Equipment (PPE) as specified on the pesticide’s label is provided to pest management personnel by the CFMO, Area Coordinator, or the unit. Submit purchase order requests, when supplies of PPE become low.

7.3.2 Appropriate respiratory protection (High-Efficiency Particulate Air (HEPA) filter cartridges) should be used when working in enclosed areas infested with rodents and rodent waste, as well as additional measures like disposable gloves and the use of disinfectants. Rodent waste is associated with Hantavirus and Hantavirus pulmonary syndrome.

7.4 Fire Protection

The usual hazards presented by a fire are compounded in the case of a pesticide fire by the danger of pesticide poisoning and contamination. Fire protection of pesticides will be governed by the label and the CAARNG Hazardous Material, Waste and/or Spill Management Plans.

7.5 Pest Management Vehicle(s)

Whenever possible, designate a single vehicle to transport and apply pesticides. Pesticides are never transported in the cabs of vehicles, in personally-owned vehicles, or in vehicles generally used for non-pesticide related activities unless the pesticides are being used in the Self-Help program. Whenever possible, pesticides are transported in a lockable storage compartment of an assigned vehicle(s). In addition, care is taken to secure pesticides to prevent damage to the containers and spillage of the chemicals. At no time are pesticides to be left unsecured in an unattended vehicle at an unsecure location.

7.6 Protection of the Public

Take precautions during pesticide application to protect the public, on and off CAARNG sites.

Follow all precautions listed on the label. Pesticides are not applied outdoors when the wind speed exceeds label-specified levels. Whenever pesticides are applied outdoors, ensure that any drift is kept away from individuals, including the applicator. At no time are personnel permitted in a treatment area during pesticide application unless they are appropriately trained, have met the medical monitoring standards, and are protected in accordance with the pesticide label requirements.

7.7 Pesticide Shop Health, Safety, and Hazards

7.7.1 Personnel will follow all label precautions that deal with the storage of pesticides.

Pesticides should be kept secure at all times. Pesticides should be under the applier’s direct control or located in a secure locked facility or cabinet that is marked “Pesticide Storage” and posted with applicable “Danger”, “Poison” and/or “Flammable” signs. Pesticides are a hazardous material and should be stored according to the SDS.

More information on pesticide storage can be found in the Armed Forces Pest Management Board (AFPMB) Technical Guide No. 17, “Design of Pest Management Facilities”. This technical guide can be found on the AFPMB website (go to: http://www.acq.osd.mil/eie/afpmb/ search for “AFPMB”) or obtained from the ARNG PMC.

7.7.2 Used pesticide aerosol cans must be turned-in to the Hazardous Waste Program Manager as hazardous waste. Other pesticide containers must be disposed of according to the label directions or turned-in as hazardous waste.

8 Environmental Considerations

8.1 Sensitive Areas

8.1.1 Special consideration is given prior to conducting pest control operations in sensitive areas that are identified on pesticide labels. No pesticides are applied directly to wetlands or water areas (lakes, rivers, etc.) unless their use is specifically approved on the label and in compliance with National Pollutant Discharge Elimination System (NPDES) regulations for application over or into waters of the United States. Separate NPDES permitting may be required in some instances and will require coordination with the CAARNG Environmental personnel.

8.1.2 In addition to aquatic and marine habitats, sensitive areas also include critical habitat of endangered, threatened, or rare flora or fauna species, and unique geological and other natural features.

8.1.3 All aerial application of pesticides to Federally-owned (Appendix A) CAARNG sites requires an Aerial Spray Statement of Need (ASSON) that has been approved by the ARNG PMC. The ASSON is prepared by CAARNG personnel with assistance from a PMC certified in DOD Category 11: Aerial Application Pest Control. Aerial application of pesticides to Federally-owned (Appendix A) CAARNG sites also requires additional environmental documentation (see Section 8.4.2 of this plan).

8.2 Endangered or Protected Species and Critical Habitats

8.2.1 Protected migratory birds that occur on CAARNG property cannot be controlled without a permit. Migratory birds and their nests are protected. Neither migratory birds nor their eggs may be harmed. Birds may be scared or herded to encourage them to move (unless the birds are otherwise protected under separate authority such as the ESA). Nuisance nests may be destroyed http://www.acq.osd.mil/eie/afpmb/

(not collected) before eggs are laid or after chicks have fledged unless protected under the ESA or the Bald and Golden Eagle Protection Act (BGEPA).

8.2.2 The IPMC periodically reviews, with assistance from the CAARNG NRM, ongoing pest control operations and also evaluates all new pest management operations to ensure compliance with the ESA, Migratory Bird Treaty Act, the Bald and Golden Eagle Protection Act and state wildlife regulations. No pest management operations are conducted that are likely to have a negative impact on endangered or protected species or their habitats without prior approval from the ARNG PMC. Special consideration must be given when using pest management tactics in areas where endangered species and/or nesting/roosting eagles are found. Refer to the site-specific Integrated Natural Resources Management Plan (INRMP) for special environmental concerns pertaining to endangered species and coordinate with the CAARNG NRM before performing any pest management operations that might affect endangered or protected species or their habitats. Installations and facilities that have T&E species, such as Camp Roberts, Camp San Luis Obispo, Santa Cruz Armory, and Bakersfield Armory, must contact NGCA-ARN-EN prior to conducting any pesticide activities. A list and applicable information on T&E species, and species of concern identified at Camp Roberts, Camp San Luis Obispo, Santa Cruz Armory, and Bakersfield Armory is available in Appendix L.

8.2.3 Coordinate with the CAARNG NRM regarding pest control operations that could affect pollinators (such as insecticides and herbicides that kill flowering plants). All efforts should be made to reduce the use of pesticides that may affect pollinators. If pesticides must be used, apply the lowest toxicity pesticide available and apply pesticides at times of day and/or season when pesticide use will have the least impact on pollinators, but achieve pest contract objectives.

8.3 Cultural and Historical Sites

All IPM activities must be in accordance with the CAARNG Integrated Cultural Resources Management Plan (ICRMP). Follow the procedures and notifications specified in the ICRMP immediately after discovering cultural resources. In any native plants of interest to the Tribes are identified during the tribal consultation process, report their locations to the CAARNG Cultural Resources Manager. The CAARNG Cultural Resources Manager will review any necessary ground disturbance or work requiring alteration of a building eligible for the National Register of Historic Places.

8.4 Environmental Documentation

8.4.1 An ARNG Programmatic Environmental Assessment (PEA) was completed to identify, document, and evaluate the ARNG IPM Program. In the PEA, the ARNG Directorate addresses potential environmental effects of implementing IPMPs on a broad, programmatic scale.

Assessing environmental impacts of the CAARNG IPM Program has been conducted and documented via an ARNG Checklist and Record of Environmental Consideration (REC). The REC was completed in accordance with 40CFR § 1502.20 and was treated as a tiering action.

Environmental documentation can be found in Appendix G.

8.4.2 Aerial application of pesticides to Federally-owned CAARNG sites (Appendix A) may require an Environmental Assessment (EA).

8.5 Pesticide Spills and Remediation

An adequate pesticide spill cleanup kit is maintained wherever bulk pesticides are stored or used.

All pesticide spills are reported to the CAARNG Hazardous Waste Program Manager. Spills are governed by the label and the CAARNG Hazardous Material, Waste and/or Spill Management Plans.

8.6 Climate Change

There is a potential for climate change to impact the control of pests on state and local levels.

Shifts in precipitation regimes and temperature ranges can result in changes to vegetation that could impact training areas, promote noxious weed infestations, or compromise wildlife habitat.

CAARNG supports the development of a vulnerability assessment to better understand the potential impacts related to a changing climate. However, the abundance and distribution of species and habitats at CAARNG sites are too small in scale to address comprehensive climate change vulnerabilities and CAARNG will instead utilize existing state and regional plans, partnerships, or reports that other agencies, universities, or non-profits are conducting to assess, develop and implement climate change adaptation strategies. In general, CAARNG will identify and implement sound IPM strategies, regardless of whether climate changes occur.

9 Program Administration

9.1 Pest Management Operations

9.1.1 Pest management operations are conducted in accordance with Appendix B, “Integrated Pest Management (IPM) Outlines”.

9.1.2 If the pest problem cannot be solved using the Self-Help Program (see Appendix E), then a request for pest control is sent to the CFMO or the Area Coordinator.

9.1.3 All pesticides used at CAARNG sites will be approved prior to use by the ARNG PMC and all pesticides used at CAARNG sites will be listed on the CAARNG SPUL (Appendix C).

9.2 Pest Management Contracts and Contract Quality Assurance

9.2.1 CAARNG site personnel may use contracts when essential pest management services are not provided in-house. Contracts are administered in accordance with DODI 4150.07 for CAARNG Federally-owned (Appendix A) sites. The CFMO will contact the IPMC for guidance for any contracts that include pest management.

9.2.2 Pest management contracts for CAARNG Federally-owned (Appendix A) sites are forwarded to the ARNG PMC for technical sufficiency review prior to advertisement of the contract. For contracted pre-construction treatment of soil to control termites, PMC review and approval of the termite management section of contracts is not required for CAARNG Federally-owned (Appendix A) sites if the contract language is in accordance with the current Unified Facilities Guide Specification for chemical termite control.

9.2.3 State contracting procedures and regulations are utilized to contract pest control on CAARNG State-owned sites.

9.2.4 Pest management contracts are initiated on an "as needed" basis. Regularly scheduled, monthly or periodic treatments will be eliminated unless deemed necessary after surveying and monitoring pest population levels. Regularly scheduled monthly or periodic treatments at CAARNG Federally-owned (Appendix A) sites must be approved by the ARNG PMC. Use of IPM techniques is encouraged in all contracts to decrease DOD’s use of toxic chemicals and pollutants. Pest problems threatening the health, safety, or welfare of installation personnel receive priority.

9.2.5 Contractors will conduct pest management in accordance with this plan and may only apply pesticides listed on the CAARNG SPUL at CAARNG sites. Contractors may request addition of pesticides to the CAARNG SPUL via the IPMC.

9.2.6 Once a contract is awarded, it is the responsibility of the CFMO to establish a date and time for work to commence. A copy of each finalized contract dealing with pest control must be forwarded to the IPMC within 90 days.

9.2.7 The IPMC is responsible for ensuring the requirements of this plan are implemented for contracted pest management and for assuring the quality of all pest management activities via the Facility Managers. Pest management contracts with efforts that exceed 0.25 work-years must be monitored by a certified PMQAE at CAARNG sites]. Work performed by contracted pest management personnel is evaluated based on the adherence to the contract statement of work negotiated through the CFMO, the requirements outlined in this plan, and the Facility Manager or PMQAE reviews contracted pest control work to determine the effectiveness of control efforts. Failure of a contractor to adequately control pests is reported to the CFMO. Ongoing contracts are evaluated annually or as necessary. An evaluation to confirm the satisfactory completion of all work is performed prior to payment being made.

9.3 Outleases

If the CAARNG initiates outleases, the lessee will be governed by this plan as a contractor. IPM techniques will continue to be used to the maximum extent possible and the lessee may only apply pesticides listed on the CAARNG SPUL at CAARNG sites. Lessees may request addition of pesticides to the CAARNG SPUL via the IPMC.

9.4 Interservice Support Agreements

Tenants of CAARNG sites will be governed by this plan. If the CAARNG has activities or units that are tenants on another installation, they will follow that installation’s IPMP unless the interservice support agreement states otherwise. In no instance will a pesticide be applied contradictorily to its label.

9.5 Reports and Records

9.5.1 The CAARNG IPMC is responsible for the maintenance of records for all in-house and contracted pest management operations (e.g., pesticide use, surveillance).

9.5.2 Records of pesticide applicator certification must be retained by the applicator and available for review. Current pesticide applicator records are provided to the IPMC for inclusion in Appendix K of this plan.

9.5.3 All pest surveillance and control operations are recorded by the pesticide applicator or pest management provider. This includes pest management actions done in-house, by contractors, Self-Help Program participants, and as part of outleases, land management, and forestry programs. These records must contain at a minimum:

a. Date and time of pesticide application

b. Target pest(s)

c. Specific pesticide application location(s)

d. Name of the person (and company, if contractor) applying the pesticide and their certification number (if applicable)

e. Name and manufacturer of pesticide

f. EPA registration number of the pesticide

g. Sufficient information to determine the amount (in pounds) of pesticide active ingredient applied (such as amount of undiluted pesticide used, total amount of concentrate used, or amount of diluted pesticide applied, and the dilution rate)

9.5.4 Pest surveillance and control operations are recorded using the Pest Management Maintenance Record (DD Form 1532-1), the CAARNG Pest Management Treatment Record (Appendix D) or an equivalent hard-copy or electronic form. Self-Help program participants are to record pest control using the CAARNG Self-Help Pest Management Treatment Record (Appendix E, page E-6). These records are maintained indefinitely at the CAARNG Environmental Office and are a permanent record of pest management activities.

9.5.5 Reports of pesticides used at CAARNG sites are compiled at the end of each fiscal year by the PMP and provided to the IPMC. For contracted pesticide applications, the Contractor provides records to the Facility Manager, PMQAE or IPMC at the interval required per the contract. If contracted pesticide usage is reported to the Facility Manager or PMQAE, they will forward the information to the IPMC at the end of the fiscal year. For Self-Help program applications, Self-Help program participants report usage to the Facility Manager and they will forward the information to the IPMC at the end of the fiscal year year.

9.5.6 The IPMC calculates and provides the data required for the annual PUF (an example PUF is in Appendix H).