IFB_8600_MAS1009_ATT_3_v1.docx

ATTACHMENT

Operations and Maintenance Integrated Pest Management

Division Effective Date: Reviewed: Revised:

Operations & Maintenance May 10, 2017 December 19, 2023 January 1, 2025

Authorization:

Digitally signed by Liana Kallivoka, Liana Kallivoka, PhD, PE PhD, PE Date: 2024.01.01 23:41:37 -06'00'

Assistant Director: Liana Kallivoka, PhD, PE, LEED Fellow

INTEGRATED PEST MANAGEMENT

PROGRAM

City of Austin Parks and Recreation Department Operations and Maintenance Division

ABSTRACT

It is imperative for the Austin Parks and Recreation Department to be environmentally conscious and provide safe and well-maintained parks and facilities for all visitors to enjoy, by utilizing a holistic approach to Integrated Pest Management (IPM).

IPM procedures will determine when and how to effectively control pests while preventing property damage with the least possible hazard to people, property and the environment.

TABLE OF CONTENTS

II. INTEGRATED PEST MANAGEMENT METHODOLOGY

PEST MANAGEMENT POLICIES

Outline of Strategies 15 Licensing and Training Strategy 1: Licensing, Certification, and Continuing Education of Pest Management Personnel 17 Pest Management Procedures

Pesticide Material Management

Safety Measures and Emergency Response

Special Situations

Integrated Pest Management Program

III. Appendices Appendix 1: Approved Pesticide Lists, Use Up and Do Not Restock List Appendix 2: Approved Lists for Park Use Appendix 3: Specialty Rose Garden Approved List Appendix 4: Athletic Field Services Approved List Appendix 5: City Urban Forestry Approved List Appendix 6: City Parks and Recreation-Horticultural Approved List Appendix 7: City Parks and Recreation-Natural Areas Approved List Appendix 8: Pesticide Applicator Record keeping Form Appendix 9: PARD Pesticide Record keeping Form Appendix 10: Form Letter for Written Notification of Use (Schools, etc.) Appendix 11: Form for Non-PARD Pesticide Application Approval Appendix 12: List of Common Pests and Their Control Method Appendix 13: Form for Turf Herbicide Application Approval Appendix 14: Texas Department of Agriculture’s Incidental Use Situation Fact Sheet Appendix 15: Incidental Use Record keeping Form Appendix 16: Emergency Phone List Appendix 17: Glossary Appendix 18: Acknowledgments Appendix 19: Resolution No. 20180625-071 Pesticides Appendix 20: Revisions

Assistant Director, Parks and Recreation Department

The Parks and Recreation Department’s Integrated Pest Management (IPM) Program was significantly revised in 2017 and further updated in 2021 to address the following:

· Update current practices;

· Create and refine a common understanding of goals and objectives;

· Establish Best Management Practices and outline when to use mechanical, physical, chemical, cultural or biological methods;

· Provide a training tool for employees;

· Establish policies, procedures and practices that are standardized, efficient and effective; and

· Meet our goal of maintaining accreditation through the National Recreation and Park Association.

The development of a comprehensive IPM Program was led by the Operations and Maintenance Division, included extensive interdepartmental collaboration, and has the Department’s commitment to follow through with its provisions. The program’s objective is to provide necessary pest control while minimizing pesticide use. The Department’s IPM Program relies on an ecosystems approach to control pests, and utilizes a variety of methods to prevent and resolve pest problems in an efficient and ecologically friendly manner without compromising the safety of our staff and visitors, and the integrity of our facilities. The IPM program is reviewed annually and is revised, as necessary, to meet current and future needs.

I ask for your continued involvement to ensure the IPM Program meets and exceeds the expectations of our citizens. I appreciate all the hard work and your commitment to the Department, the City of Austin and its residents. We will continue to work together to make the Austin Parks and Recreation Department the leader in innovation and sustainability, and set a high standard in the parks and recreation field, as the best Parks and Recreation Department in the country.

Again, my sincere appreciation for your steadfast commitment to our park system!

Liana Kallivoka, PhD, PE, LEED Fellow Assistant Director, Austin Parks and Recreation Department

GENERAL INFORMATION

The purpose of this document is to provide Austin Parks and Recreation Department (PARD) employees with an overview of integrated pest management principles and specific Strategy-based direction for implementing those principles.

Integrated Pest Management (IPM) Program is a decision-making process to determine pest levels and tolerance thresholds and combines biological, cultural, physical, and chemical tools to minimize health, environmental, and financial risks. This program uses extensive knowledge about pests, such as infestation thresholds, life histories, environmental requirements, and natural enemies to complement and facilitate biological and other natural control of pests. It coordinates the use of pest biology, environmental information, and available technology to prevent unacceptable levels of pest damage by the most economical means, while posing the least possible risk to people, property, resources, and the environment.

Mission Statement The mission of the Parks and Recreation Integrated Pest Management Program is to manage pests that are harmful to the health, function or aesthetic value of park landscapes and public health in a manner that is efficient, effective, environmentally-responsible, and with careful attention to the safety of the public and department employees.

To accomplish this, the principles of Integrated Pest Management are endorsed. This approach uses multi-faceted strategies that minimizes economic, health, and environmental risks.

Asset The Parks and Recreation Department (PARD) is a subdivision of the City of Austin municipal government and is the steward of over 20,000+ acres of greenspace, containing 300 parks, 78 mixed-use fields, 5 disc golf courses, 212 miles of trails, 35 baseball fields, 12 dog parks, 23 soccer fields, 23 historic buildings, 49 volleyball courts, 26 recreation and senior centers, 12 preserves (sanctuaries for native plants, native animals and unique natural features), and 26 greenbelts1 (parkland on creeks and canyons). It also offers a wide array of recreation and enrichment opportunities for people of all ages.

PARD’s Operations and Maintenance Division is charged with maintaining these diverse park landscapes and assets in a safe, attractive, healthy, and useful condition. Park properties represent a major component of the city’s capital assets and PARD recognizes its responsibility to protect and preserve this economic investment to the best of its abilities. PARD also recognizes its responsibilities to its employees, park users, and the general public, and seeks to employ the highest professional standards in the performance of its duties. To manage pests in park lands, PARD personnel shall utilize the principles of Integrated Pest Management.

Integrated Pest Management Integrated Pest Management (IPM) is one of the major strategies used by PARD in the maintenance of park lands. There are many definitions of IPM, the following is from the U.S. Environmental Protection Agency for its publication, “EPA Integrated Pest Management for Turfgrass and Ornamentals2:”

1 https://issuu.com/atxparksmarketing/docs/pard_annual_report_2015_interactive (page 7) and http://www.austintexas.gov/sites/default/files/files/Parks/GIS/Inventory/Austin_PARD_Has.pdf 2 EPA Integrated Pest Management for Turfgrass and Ornamentals. Page 315 and http://nepis.epa.gov/Exe/ZyPDF.cgi/9101AIKB.PDF?Dockey=9101AIKB.PDF

“IPM is the coordinated use of pest and environmental information with available pest control methods to prevent unacceptable levels of pest damage by the most economical means with the least possible hazard to people, property, and the environment. The goal of IPM is to manage pests and the environment so as to balance costs, benefits, public health, and environmental quality. IPM systems use all available technical information on the pest and its interactions with the environment. Because IPM programs apply a holistic approach to pest management decision-making, they take advantage of all appropriate pest management options, including, but not limited to pesticides. Thus IPM is:

· A system using multiple methods;

· A decision-making process;

· A risk reduction system;

· Information intensive;

· Cost-effective; and

· Site specific.”

IPM makes use of cultural practices, environmental factors, pest growth patterns and life cycles, ecological interaction, human contact, mechanical removal and, finally, pesticides to control harmful organisms.

The Operations and Maintenance Division defines Integrated Pest Management as the coordinated use of pest and environmental information along with available pest control methods, including biological, cultural, physical, and chemical methods, to prevent unacceptable levels of pest damage by the most economical means and with the least possible hazard to people, property, and the environment".

· Integrated means that all feasible types of control strategies are considered and combined as appropriate to solve a pest problem.

· Pests are unwanted organisms that are a nuisance to man or domestic animals, and can cause injury to humans, animals, plants, and property, and have a significant economic impact. Pests reduce yield and/or quality in vegetation ranging from flower beds, to lawns, trees, and sports fields.

· Management is the process of making decisions in a systematic way to keep pests from reaching intolerable levels. Small populations of pests can often be tolerated; total eradication is often not necessary, or feasible.

Based on the above, PARD’s Operations and Maintenance Division’s IPM plan consists of the following steps:

1. Identification of the issue. This step will determine what kind of action is needed, if any.

2. Consensus. This involves defining the roles of the three types of people involved in the pest management equation (i.e., District staff, Certified Pesticide Applicator, and the decision-maker) to assure understanding and communication between them. If this step is omitted, failure is virtually guaranteed!

3. Management objectives. Staff must determine the management objectives for a given site in order to solve the pest problem(s). This can be done by reviewing policies and establishing priorities. A Strategy review includes determining if a species is native or exotic, locating the management zone, and evaluating the chances of successful management.

4. Set the action thresholds. These are points when pest populations or environmental conditions indicate that action must be taken in order to prevent the pest population from crossing a pre-determined injury threshold; no action is taken until the threshold is reached.

5. Monitor. This includes the site environment and the pest population. It should be done on a periodic, consistent basis to determine whether or not the action is effective.

6. No-pesticide action. In this step, action is taken to modify the pest habitat to reduce the carrying capacity of the site, exclude the pest, or otherwise make the site’s environment incompatible with the needs of the pest. This step, which involves applied ecology, is a critically important point.

7. Pesticide action. If no-pesticide actions are not available or insufficient, approval is obtained to take appropriate pesticide action. It should (a) use the least toxic, most effective, most efficient application technique that provides the longest dwell time in contact with the pest, (b) be applied when the pest is in its most vulnerable stage, and

(c) carry the least possible hazard to people, property, and the environment.

8. Evaluate. This means checking the post-treatment results of the habitat modification or pesticide treatment actions by periodically monitoring the site and pest populations.

9. Records. For each site, written records should be kept of pest management objectives, monitoring methods and data collected, actions taken, results obtained, and pesticides used.

All components of this system must be addressed and implemented in some form for it to be most effective.

According to the Imagine Austin Comprehensive Plan, “NATURAL Austin is Natural and Sustainable3 Austin is a green city. We are environmentally aware and ensure the long-term health and quality of our community through responsible resource use as citizens at the local, regional, and global level. Growth and infrastructure systems are well-managed to respect the limitations of our natural resources.”

IPM is a decision-making process to determine if, where, when, and how pest control practices should be applied. And, in the short term, modification of direct pest control practices (such as reducing pesticide use through spot spraying strategies and replacing undesirable chemicals with more environmentally friendly materials) can provide valuable benefits in reducing the use of pesticides.

The IPM process first determines if a pest needs to be managed, and if so, how best to do it. Key elements are information gathering, well-informed decision making and monitoring of results. The IPM process promotes effective, low-risk management strategies to manage pests. The controls used in this program include biological, cultural, physical, and chemical methods and materials; often a combination of methods is used. Methods selected to manage specific pest populations are evaluated by licensed and trained PARD professionals on a case-by-case basis. The methods employed conform to recognized

3 http://www.austintexas.gov/sites/default/files/files/Planning/ImagineAustin/webiacpreduced.pdf page 85 standards established and endorsed by state and federal regulatory agencies, state educational institutions and organizations.

A few examples of IPM activities within the PARD program:

· Utilizing plants with natural resistance to pests.

· Mulching of planting beds to reduce establishment of weeds.

· Proper mowing and irrigation of park turf to increase vigor and reduce weed populations.

· Application of selected herbicides to control invasive weeds before seed formation to prevent future weed infestations.

· Release of natural biological control insects to control certain infestations. This is not a practice currently conducted by PARD.

Key elements of an IPM program are information gathering and informed decision-making. Horticulturists, botanical specialists, park technicians, foresters, and arborists are skilled in identifying and evaluating pest problems. When pest problems occur that are unusual or beyond the scope of in- house experts, advice is obtained from other qualified sources such as state universities, Texas Department of Agriculture, and Texas A&M University Extension Service experts. Texas Pesticide Applicators License continuing education courses reinforce employee skills and provide current information concerning laws, safety, pests, and current IPM methods.

PARD employees monitor levels of pests in order to arrive at the best solution for managing a pest problem. When pest management methods are implemented by trained IPM personnel, the results are solutions that are economically and environmentally responsible. This provides the public with safe, healthy, and aesthetically pleasing park areas.

Pesticide Use Pesticide is a general term for any substance intended for preventing, destroying, repelling, or mitigating any pest. Park pests consist primarily of unwanted vegetation and invasive weeds, but can also include insects, disease organisms, rodents, and other organisms. To manage these pests, PARD personnel select the best methods available. When it is necessary to use pesticides as part of an IPM approach, PARD minimizes risk by careful product selection and application. When developing and updating PARD’s IPM program the best expert scientific opinion is relied upon on to inform staff about potential materials and methods. Assessments from regulatory agencies, state university departments in Texas, university extension scientists and other experts in the field provide much useful specific information. PARD turns to these recognized experts for credible science-based information. PARD also stays current with the latest pertinent studies as part of our process. By basing decisions on these authoritative sources best solutions can be obtained within the IPM framework. PARD has found that as part of a complete IPM approach, judicious use of carefully selected pesticides can sometimes be an important tool in ensuring quality landscapes and healthy and diverse natural areas. The demonstrated benefits of these balanced management practices have made PARD a model of responsible park management throughout the region.

Before an applicator uses a pesticide of any type, the treatment must be approved by the supervisor and documented in the work order system. PARD pesticide applicators are required to comply with all pesticide label directions, federal, state, and local pesticide regulations, applicable safety laws, and PARD policies. Misuse of pesticides will not be tolerated. Pesticides not labeled or listed (refer to Appendices 1-7) will not be covered in detail within this document, but PARD requires pesticide applicators to use additional precaution and label directions, if present, for all applications. If the pesticide chosen for application poses any health risks to the environment, users, and their pets, it must be approved before application. DOCUMENTED NONCOMPLIANCE WITH STATE AND FEDERAL LAWS OR RULES SET OUT IN THESE POLICIES IS CAUSE FOR DISCIPLINARY ACTION, UP TO AND INCLUDING TERMINATION.

Safety The Austin Parks and Recreation Department has an excellent safety record with respect to the use of pesticides. This record is made possible through appropriate training, careful processes for approving pesticides, and adherence to label directives and safety procedures when employees work with or apply pesticides. When pesticides are being applied in park areas by PARD personnel, notification signs are posted at points of entry to the treated areas. These signs include information about the pesticides being applied, the date, as well as a phone number where additional information can be obtained.

When pest management equipment is being used and materials are being applied by PARD employees, all appropriate worker personal protective equipment is provided for use. Use of such equipment is an important part of safely applying pesticides as well as using mechanical equipment. PARD employees work with the Watershed Protection Department to protect the city’s water supply from all types of contamination. Park employees do not apply pesticides within waterways areas unless proper procedures have been followed and the direct supervisor approves. When pesticides are contemplated to be used near waterways and drainage areas, the Watershed Protection Department will be consulted, and written permission (e-mail will be sufficient) will be granted for any pesticide application.

Laws and Regulations Several Federal and State agencies regulate the use of pesticides. PARD Operations and Maintenance Division conforms to all pesticide laws and regulations. PARD allows only Texas State licensed Pesticide Applicators to apply pesticides of any kind on park land. In this way PARD exceeds the standards established within Texas state law. To obtain a Noncommercial Pesticide Applicator's License, applicators must pass a series of tests given by the Texas Department of Agriculture. The Texas Department of Agriculture does allow non-licensed staff to apply pesticides when it is incidental to their primary duties. (See Appendix 14)

Subjects tested include: Laws and Regulations; Safety and Storage; Use and Disposal of Pesticides; Reading and Understanding Pesticide Labels; Pest Management Methods and Materials, Integrated Pest Management and others. Licensed applicators are legally liable if they apply pesticides contrary to state and federal laws and label directions. Texas State Department of Agriculture certified continuing education can be found online at the TDA’s continuing education unit course search, http://www.agr.state.tx.us/internet/ceucourse/search.jsp.

Once licensed, applicators must renew their license, annually for noncommercial applicators, and take the required amount of continuing education units needed for the type of Pesticide Applicator’s License held, 5 CEUs for noncommercial applicators annually. Applicators are required by law to record specific information when applying pesticides and keep records for a minimum of 2 years. The Texas Department of Agriculture has designated forms for these purposes, which are included in Appendix 8. In addition, the City of Austin has its own form to document pesticide applications (See Appendix 9).

Also, applicators are required to submit a work order with a complete description of treatment, equivalent to the standards required by TDA, and post a copy on G drive. This helps keep track of previous treatments if adjacent damage becomes visible in the future.

Agricultural Worker Protection Standard The Worker Protection Standard (WPS) is a federal regulation designed to protect agricultural workers (people involved in the production of agricultural crops) and agricultural pesticide handlers (agricultural workers mixing, loading, or applying pesticides or tasks involving direct contact with pesticides). These rules apply only to agricultural settings, not park use. However, elements of Austin Parks and Recreation nursery and greenhouse operations may fall under the scope of these rules. Applications of pesticides in these two areas are governed by both the PARD Strategy and the additional rules of the WPS.

These rules require worker training regarding pesticide exposure, protection, and mitigation. They also require specific notification and worker re-entry intervals for pesticide applications in plant production areas.

Duties of Employers4 The Worker Protection Standard for Agricultural Pesticides (WPS) is a regulation issued by the U.S. Environmental Protection Agency (EPA) to protect persons who use pesticides in the production of agricultural plants on farms, and in forests, nurseries, and greenhouses. The WPS requires employers to take steps to reduce the risk of pesticide-related illness and injury for themselves and the people they employ.

The WPS covers:

· Agricultural workers - perform tasks related to the cultivation and harvesting of plants on farms or in greenhouses, nurseries, or forests;

· Pesticide handlers - mix, load or apply agricultural pesticides; clean or repair equipment; act as flaggers, or perform any task involving direct contact with pesticides.

Employers are responsible for making sure workers and handlers receive the protections required by the pesticide label and the WPS. There are two types of employers:

· Agricultural employers - employ or contract for the services of workers or own or operate an establishment that employs workers.

· Handler employers - hire pesticide handlers or are self-employed as handlers. This definition includes commercial applicators and companies that supply crop advisory services on agricultural establishments.

It is important to note, whether or not you employ workers and handlers, at a minimum, YOU will be required to comply with new personal protective equipment and restricted entry statements on the pesticide labels.

Some WPS protections that employers must provide to their employees are nearly the same whether the employees are workers or handlers.

Information at a Central Location For the benefit of all employees, information must be posted at an easily seen, central location on each agricultural establishment. That information includes:

· Facts about each pesticide application, the product name, EPA registration number, and active ingredient(s); location and description of treated area(s); the time and date of the application and the restricted-entry interval (REI);

4 https://texasagriculture.gov/Portals/0/Publications/PEST/pes_wpsbro.pdf

· The name, address, and telephone number of the nearest emergency medical facility, and;

· An EPA WPS safety poster.

Employers must tell workers and handlers where the information is posted and allow them access to the information. Be sure that the information remains legible and notify your employees of any changes to the emergency medical facility information.

Decontamination Sites Employers must provide sites so that workers and handlers can wash pesticides and residues from their hands and body. Decontamination supplies must include:

· Enough water for routine and emergency whole-body washing and for eye flushing;

· Soap;

· Single-use towels; and,

· A clean coverall, for use by handlers.

Decontamination materials must be within ¼ mile of the employees’ work site. If the work place is more than 1/4 mile from the nearest point of vehicular access, the decontamination materials may be located at the nearest access point. Handler employers must also provide decontamination materials:

· Where handlers remove their personal protective equipment (PPE) at the end of a task, and;

· At each mixing/loading site. Emergency eye flush water must be immediately available if the pesticide label calls for protective eyewear.

The decontamination materials may not be located in an area under restricted entry unless they serve handlers working in that area. In this case, all materials must be protected from contamination.

Emergency Assistance If there is reason to believe that a handler or worker may have been poisoned or injured by pesticides, an employer must promptly make transportation to an appropriate medical facility available to that person. Be prepared to provide the victim and medical personnel with:

· The product name, EPA registration number, and active ingredient(s);

· All first aid and medical information from the label;

· A description of how the pesticide was used; and

· Information about the victim’s exposure.

Personal Protective Equipment (PPE) Employers must provide handlers with the PPE as listed on the pesticide label. The employer must:

· Maintain PPE in a clean and operational condition;

· Make sure it fits correctly;

· Make sure handler wears and uses the PPE correctly;

· Provide a clean place to put on and remove PPE, and store personal clothing;

· Not allow worker to wear or take home PPE;

· Take action to prevent heat-related illness while PPE is worn.

Cleaning and Maintaining PPE Employers must make sure:

· PPE is cleaned according to manufacturer’s instructions, inspected, and repaired before each use;

· PPE that is non-reusable or cannot be cleaned, must be disposed of properly;

· Clothing drenched with pesticide labeled DANGER or WARNING are discarded;

· PPE must be washed and dried properly, and stored separately from personal clothing;

· Respirator filters, cartridges and canisters are replaced as often as required. The handler employer must make sure anyone cleaning PPE is informed of possible pesticide residues on PPE, of the potentially harmful effects of pesticides, and of the correct ways to handle and clean PPE.

Equipment Safety Handler employers must make sure that equipment used for mixing, loading, transferring, or applying pesticides is inspected and repaired or replaced as needed. Only appropriately trained and equipped handlers may repair, clean, or adjust pesticide handling equipment that contains pesticides or pesticide residues.

Pesticide labels reflect the Worker Protection Standard requirements under the Agricultural Use Directions section. When you use a pesticide product with labeling that refers to the Worker Protection Standard, you must comply with the WPS. For more information about the Worker Protection Standard, contact: Texas Department of Agriculture (512) 463-7622 or 1-800-TELL-TDA Relay Texas: 1-800-735-2988 (voice); 1-800-735-2989 (TDD) Web address: http://www.TexasAgriculture.gov

Environmental Protection The City of Austin operates under the Pesticides General Permit (PGP, TXG870000) administered by TCEQ. The purpose of this permit is to regulate the discharge of pesticides to the waters of the United States. Within the City, reporting for PGP compliance is coordinated through the Watershed Protection Department (WPD). Any potential adverse incidents involving pesticides should be immediately reported to the WPD IPM Coordinator. Pesticide use within the City is also tracked to maintain compliance with the PGP.

INTEGRATED PEST MANAGEMENT METHODOLOGY

Approved Pest Management Strategies This is a short list of examples of possible management strategies among the many methods available. Prevention of pest problems through:

· Good Strategy and planning;

· Cultural practices, avoidance measures, and physical means to manage pest problems; and

· Mechanical practices, trapping, biological controls, and use of natural and synthetic pesticides.

All of these IPM measures are evaluated and considered together so that the best overall pest problem solutions are chosen and implemented.

Strategy Management of pests through adoption of Strategy can be highly effective and low in cost. Such policies can often eliminate problems before they begin. Some examples are:

· Prioritization of parks for control measures may be considered. Different park areas may have varying standards of acceptable care and appearance. Determining whether a particular park area requires control of pests and the level of that control must take these differences into account. Careful attention to public desires and public needs must be part of this prioritization process.

· Establishment of thresholds for action and the tolerance level for different pests are part of the IPM process. These thresholds vary according to plant, pest, and site. Determinations of action thresholds are made on a case-by-case basis.

Design Proper park design is a major way that pest problems can be avoided. While no landscape can be designed to be free of pest management needs, such considerations need to be part of the planning process. Examples are:

· Elimination or modification of problematical areas;

· Avoiding the use of potentially invasive species;

· Proper and adequate spacing of plant material to reduce the incidence of pest problems;

· Maintenance of species diversity and elimination of monocultures in plantings where possible;

· Elimination of alternate hosts for diseases; and

· Establishment of overstory, thick groundcovers and other design techniques benefiting both the establishment of plants and the reduction of weed problems.

Plant selection Plant selection is critical in minimizing pest management needs both short- and long-term. Criteria for plant selection include:

· Use of disease or pest resistant or tolerant plant species or varieties; and

· Removal of invasive or pest-susceptible plants, or replacement with native or adapted pest resistant plants or varieties.

Useful resources for choosing native and adapted grasses, groundcover, vines, perennials, shrubs, and trees are the City of Austin’s Grow Green website and the Arbor Day Foundation website: https://www.austintexas.gov/sites/default/files/files/Watershed/growgreen/plantguide.pdf http://www.austintexas.gov/department/grow-green

Cultural practices Proper cultural practices are essential in establishing healthy landscapes and can often help to maintain their resistance to pest problems. Examples are:

· Knowledge of the cultural requirements of plants to best provide proper conditions for optimum plant health and resistance to pests.

· Adequate site preparation before landscape installation. This can include soil improvements, pruning of surrounding vegetation, grade adjustments, drainage improvements, and installation of irrigation systems.

· Use of disease resistant grafting rootstock or scion wood.

· Proper timing and use of water to reduce over or under watering.

· Proper timing and use of fertilization to eliminate over and under-fertilization.

· Use of cover crops to improve soil structure and reduce soil erosion.

· Rotation of plant species in nursery areas to reduce the buildup of pests.

· Aeration, over-seeding, and top-dressing to improve turf health and suppress weeds.

· Raking and debris removal to remove pest sources.

· Pruning and plant removal to promote air circulation and light penetration for plant health.

· Removal of diseased, infested, damaged, or dead wood.

· Mulching for weed reduction, water retention, winter protection and root zone improvement.

· Fan placement for improved greenhouse air circulation.

Mechanical and physical controls Mechanical and physical methods are often employed to manage pests. Examples are:

· Mechanical edging of turf.

· Mechanical clearing of weeds in rough areas.

· Hand weeding in shrub beds.

· Weed wrenching or loping, or chain sawing invasive trees.

· Mowing of rough turf areas for vegetation control.

· Traps such as yellow sticky boards for greenhouse insects and traps for mammalian pests.

· String trimming to control unwanted vegetation.

· Disinfecting materials or equipment to prevent spread of pests.

Biological controls Where applicable, biological control is useful to manage pests. Typically most important is minimizing disruption of natural pest controls that may be present. Examples are:

· Introducing insect or disease parasitoids, predators, and microbial products to control pests.

· Minimizing the use of disruptive techniques and materials in landscapes that may destroy natural pest control organisms.

Naturally derived and synthetically derived pesticides Pesticides are derived from many sources. They vary widely in their characteristics and must be examined individually to determine their suitability within the IPM approach. Examples are:

· Placement of pheromone traps.

· Disinfecting materials or equipment to prevent spread of pests.

· Application of naturally and synthetically derived pesticides.

Criteria for Choosing a Pest Management Method When choosing a pest management method or pesticide material from the approved lists located in

Appendix 1-7, all personnel should consider the following factors and any additional factors relevant to the selection.

Nature of the site

· Erosion susceptibility and potential movement of soil through runoff;

· The intended use and function of the landscape;

· The feasibility of the method given the area and scope of the problem;

· The relative importance and public expectation of a site or plantings; and

· Site conditions such as soil type, grade, drainage patterns, and presence of surface water.

Possible health and safety effects

· Consider both short- and long-term toxicological properties and any other related potential health effects of the materials or methods, both to the applicator and the public;

· Equipment operation safety issues for both the operator and the public; and

· Worker safety and worker injury issues involved with carrying out the method.

Possible environmental effects

· Consider both acute and chronic toxicity and any other related potential effects of the material or method to non target organisms including mammals, birds, amphibians, fish, invertebrates and other organisms;

· Environmental effects from potential bioaccumulation;

· Potential impacts to non-target plants and other organisms from materials or methods;

· Potential impacts to federally listed, threatened or endangered species; and

· Possible introduction or establishment of invasive plants.

Costs

· Costs of the material or method;

· Application and labor costs;

· Length and quality of pest control; and

· Feasibility of using a particular method or product.

Characteristics of the product

· Target pests and target sites of the product being used;

· Possible residual effect, decomposition pathways, rates, and breakdown products;

· Volatility and flammability;

· Product formulation and package size;

· Leachability, solubility, and surface and soil bonding characteristics of the product;

· Ease of cleaning equipment after use; and

· Positive and negative synergistic effects of pesticide combinations.

Special considerations

· Application equipment availability;

· Method of delivery;

· Current and anticipated weather conditions;

· Previous pesticide applications to the site and the interval between treatments; and

· Possible development of pest resistance to a particular management method or material.

OUTLINE OF STRATEGIES

Licensing and Training Strategy 1. LICENSING, CERTIFICATION AND CONTINUING EDUCATION OF PEST MANAGEMENT PERSONNEL- Defines the required State of Texas licensing requirements and recertification obligations and training for PARD applicator personnel.

Pest Management Procedures Strategy 2. MANAGEMENT METHODS FOR PEST PROBLEMS- Establishes the IPM methodology and approved strategies.

Strategy 3. PESTICIDES APPROVED FOR USE BY AUSTIN PARKS AND RECREATION PERSONNEL- Describes the approval process for pesticides and details certain pesticides and their control methods. Approved product lists for each unit are located in the appendices.

Strategy 4. NOTIFICATION OF PESTICIDE USE AT A SITE- Outlines the on-site notification procedures to be used before, during and after applications.

Strategy 5. PESTICIDE APPLICATION ON PARK PROPERTY AND STREET RIGHTS OF WAY- Establishes procedures on how to apply pesticides on all park lands.

Strategy 6. PESTICIDE APPLICATION RECORDKEEPING- Outlines recordkeeping standards for parks applications. Recording form samples are located in appendices.

Pesticide Material Management Strategy 7. USE OF REMAINING PESTICIDE SOLUTIONS AND RINSES- Outlines how residual pesticides and rinsates are handled.

Strategy 8. STORAGE AND TRANSPORTATION OF PESTICIDES- Defines methods and procedures for storage of pesticides.

Strategy 9. DISPOSAL OF EMPTY PESTICIDE CONTAINERS AND UNUSABLE PESTICIDES- Establishes the fate of surplus or contaminated pesticides and empty containers.

Safety Measures and Emergency Response Strategy 10.USE OF PROTECTIVE CLOTHING AND EQUIPMENT- Describes appropriate personal protective clothing and equipment for use by PARD personnel when handling or applying pesticides.

Strategy 11.EMERGENCY INFORMATION CONCERNING ACCIDENTAL PESTICIDE EXPOSURE- Defines the procedures followed in responding to inquiries from PARD employees and the public regarding pesticide exposure.

Strategy 12.PESTICIDE SPILL RESPONSE- A Strategy dealing with any unintended release of pesticides on or off PARD properties. Outlines responsibilities, training, reporting, methods, and materials involved.

Strategy 13.WORKER PROTECTION STANDARD- Outlines the background of the WPS and how it relates to the nursery and greenhouse operations of Parks and Recreation. Establishes training duties and defines those required to receive training.

Special Situations Strategy 14.PESTICIDE APPLICATION BY NON-PARD EMPLOYEES- Establishes the framework for review of all pesticide applications to PARD property proposed by outside contractors.

Strategy 15.RODENT AND OTHER VERTEBRATE PEST MANAGEMENT- Describes approved methods of rodent management by PARD personnel.

Strategy 16.TURF BROADLEAF WEED MANAGEMENT- Describes procedures, rationale, and approval process for management of broadleaf weeds in maintained park turf areas.

Strategy 17.PESTICIDE USE AROUND WATERSHED PROTECTION PROPERTY AND WATERWAYS- Explains the joint Strategy between PARD and the Watershed Protection to protect water quality in streams and reservoirs Strategy 18.PESTICIDE APPLICATIONS AROUND COMMUNITY GARDENS- Outlines procedures and limitations of pesticide applications adjacent to PARD Community Garden sites.

Strategy 19.WATERWAYS PEST MANAGEMENT- This Strategy defines specific practices, methods and materials approved for use alongside, and within aquatic sites.

Strategy 20.VEGETATION MANAGEMENT IN ENGINEERED WOOD FIBER PLAYGROUND AREAS - Defines special pest management practices in wood chip-surfaced playground areas. Strategy 21.VENOMOUS INSECT MANAGEMENT- Describes how venomous insects such as wasps, bees and hornets on parkland are addressed.

Strategy 22.DOG AREA PEST MANAGEMENT- Specifies how pest management in designated dog areas is carried out.

Strategy 23.INSECTICIDE USE AND POLLINATOR PROTECTION- This Strategy defines specific practices and methods when dealing with pollinators, including bees and other insects.

STRATEGY 1: Licensing, Certification, and Continuing Education of Pest Management Personnel

PURPOSE

This Strategy defines the education, training, licensing, and certification requirements for applicators who are applying pesticides, or supervising others applying pesticides.

BACKGROUND

State pesticide applicator licensing assures a level of expertise and familiarity with pest management practices and pesticide materials. While Texas state law does not require this level of licensing for the majority of the kinds of applications carried out on park lands, PARD is committed to maintaining a high level of expertise in our workforce and chooses to exceed the minimum standards. The continuing education requirements of state licensing also help to keep personnel up-to-date on pest management theory and practice. Therefore, PARD requires that all personnel applying pesticides as their primary duty on parkland maintain a Texas Department of Agriculture applicators license. The Texas Department of Agriculture does allow non-licensed staff to apply pesticides when it is incidental to their primary duties. (See Appendix 14)

STRATEGY

All PARD personnel applying pesticides or herbicides as their primary duty on park lands shall be certified as state pesticide applicators by passing the Texas Department of Agriculture examinations. Applicators are required to recertify every year by obtaining five continuing education credits; with one credit each from two of the following categories: laws and regulations, integrated pest management or drift minimization. To maximize the value and relevance of the recertification training, PARD will actively seek out educational opportunities for staff.

The ultimate responsibility for maintaining a valid applicator license is with the applicator. PARD will keep pesticide applicators informed of approved supplemental education to meet continuing certification and licensing requirements. Unless special arrangements and approvals have been made, all PARD applicators must be full-time employees. Regardless of licensing status, no seasonally employed staff members shall apply pesticides on park land, unless approved by the PARD IPM Coordinator, and specific approval from the Division Manager, following a request from the supervisor of the seasonal employee.

PARD Operations and Maintenance Division has incorporated Texas Department of Agriculture’s Incidental Use Situation Fact Sheet5 into its strategy. It reads:

“This fact sheet must be distributed to all city, county, and state employees who apply general use pesticides and do not have a Texas Department of Agriculture ornamental plant and turf license or a Structural Pest Control Service noncommercial applicator's or technician license. The fact sheet and instruction must be provided upon initial employment and thereafter must be available as needed. These general use pesticides include insecticides, herbicides, fungicides and rodenticides and involve applications made both inside and outside of structures. Incidental Use is not intended for long terms or extensive pest control measures. Where long-term pest control is required, a trained, licensed person is to make the applications.

5 https://texasagriculture.gov/Portals/0/forms/PEST/Structural/Incidental%20Use%20Fact%20Sheet.pdf

Incidental Use is defined as “A pesticide application on an occasional, isolated, site- specific basis that is incidental to the primary duties of an employee and involves the use of general use pesticides after instruction as provided by rules adopted by the Structural Pest Control Service.”

Examples of Incidental Use Situations are treating fire ants in a transformer box, or treating of ants by a janitor or clerical employee in a break area. Incidental is defined as site-specific and incidental to the employee's primary duties. If it is a part of the employee's primary duty to make applications of pesticides, that employee is required, by law, to obtain either a Structural Pest Control Service license or Texas Department of Agriculture ornamental plant and turf license, depending on the location and type of application.

In all cases of incidental use, the employee should use the least hazardous, effective method of controlling pests. If chemicals are to be utilized, they must be applied in strict accordance with manufacturer labels of "General Use" products being used. Applications made inconsistent with the label requirements of the general use product may result in penalties being assessed against the individual and/or the certified noncommercial applicator or technician responsible.

“Incidental Use Situation” applications of pesticides are regulated by the Texas Department of Agriculture, Structural Pest Control Service. If you have any questions or comments, contact SPCS at 866-918-4481; written inquiries may be addressed to the Structural Pest Control Service, P.O. Box 12847, Austin, Texas 78711-2847.”

Any personnel who does not apply pesticides as their primary duty, and are not licensed applicators, are allowed to apply pesticides as per Texas Department of Agriculture for incidental use. This means that if during the course of their normal duties, i.e. mowing, daily service or maintenance, and they find an infestation of fire ants or wasps, they are allowed by law to apply pesticides to protect park visitors or employees. The application of the chemicals must be in accordance with the manufacturer’s label, and must be documented on an “Incidental Form.” (Appendix 15)

LICENSING AND TESTING PROCEDURES

The Texas Department of Agriculture (TDA) has contracted with PSI Services (PSI) to administer exams for pesticide applicator licensing. This is the same vendor that administers exams for structural pest control licensing. PSI provides opportunities and a convenient schedule for pesticide applicators to test in 22 locations across the state.

Complete step-by-step procedures to obtain a commercial, noncommercial or noncommercial political subdivision pesticide applicator license.

Step 1: Contact Texas A&M AgriLife Extension Service at http://agrilife.org/aes/ or (979) 845-1099, to obtain pesticide examination study manuals.

Step 2: Complete an application for either a Commercial Applicator (PA-401) or a Noncommercial Pesticide Applicator (PA-400N) and submit the license fee to TDA. These forms are available at http://www.TexasAgriculture.gov or by calling TDA at 1-800-835-5832 or 512-463-7622.

· Commercial Pesticide Applicator License Fee = $200/year

· Noncommercial Pesticide Applicator License Fee = $140/year

· Noncommercial Political Subdivision Pesticide Applicator License Fee = $75/year

Step 3: Submit the completed applicator license application form and license fee to TDA.

Step 4: When the license application is processed, TDA will send the applicant a letter in the mail with their Account Number. This Account Number will be the number the applicator will use to register and schedule exam(s) with PSI.

Step 5: Applicants can go to PSIexams.com or call 1-800-733-9267 to schedule an exam at one of 22 locations around the state.

· A Pesticide Licensing Examination Candidate Information Bulletin is provided at the PSI website to assist the applicant with the exam scheduling process.

· An applicant must pass the General Standards exam and at least one category exam to be issued a license. Typically, this will be the Lawn and Ornamental Pest Control category, but others may be required, depending on job duties.

· The commercial/noncommercial applicant will pay $64 per exam.

· There is a 24 hour waiting period to take a repeat exam.

Step 6: Upon completion of the exam, the testing center will provide test results immediately. A passing grade is 70% or higher.

Step 7: PSI will send exam scores…