Att_3_-_EPA-RTP_IPM_Plan.pdf

Integrated Pest Management Plan

June 18, 2013

Office of Administration and Resource Management (OARM)

Safety, Health and Environmental Management Office

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

Attachment 3

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US EPA RTP June 2013

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Plan Updates & Reviews

Plan Review

Date

Reviewer Updates Made

1 6/2010 -- Original plan.

2 6/18/2013 K. Hartman, OARM

SHEM Contractor

Formatting and minor plan updates; removal of discussion of interagency agreement with the USFWS in regards to nuisance wildlife;

addition of Attachment 1.

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Integrated Pest Management Plan Table of Contents

1.0 Scope & Purpose

2.0 General Information

3.0 Definitions

4.0 Organizational Chart

5.0 Responsibilities

6.0 Pest Control Contractor Selection Process

7.0 Maintenance and Monitoring

8.0 Mechanical Control

9.0 Chemical Control

10.0 Indoor Plants

11.0 Action Levels

12.0 Indoor Pesticide Use

13.0 Outdoor Pesticide Use

14.0 Nuisance Wildlife Action Plan

15.0 Reporting and Communication

16.0 Training

17.0 Recordkeeping

18.0 Annual Review

Tables

Table 1 Action Level – Outdoor Pests

Table 2 Approved Indoor Pesticides

Table 3 Approved Outdoor Pesticides

Appendices

Appendix A Sample Pest Control Contractor Monitoring Report – Indoors/Outdoors

Attachments

Attachment 1 IPM Policy for First Environment Early Learning Center

Attachment 1.A Sample Annual Notification Letter

Attachment 1.B Sample 72-Hour Notice of Non-Routine Pesticide Application

Attachment 1.C Sample Visual Markers

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1.0 Scope & Purpose

This IPM plan is to be implemented and fulfilled on the EPA-RTP campus. For the purposes of this plan, the EPA-RTP campus is defined as the Main Campus at 109 T.W. Alexander Drive, Durham, NC 2771, including the National Computing Center (NCC) and the First Environments

Early Learning Center (FEELC). It also includes the Fluid Modeling Facility (FMF) and the

Human Studies Facility (HSF).

The purpose of this IPM plan is to manage pests and nuisance wildlife and the toxic chemicals used for their control in order to alleviate pest problems with the least possible hazard to people, property and the environment. This IPM plan provides the details on how the IPM policy will be implemented and fulfilled on the EPA-RTP campus. Attachment 1 of this plan, the IPM Policy for First Environment Early Learning Center, details additional IPM procedures to be implemented at the child care center.

2.0 General Information

Business Name: U. S. Environmental Protection Agency

(EPA-RTP)

Addresses: Main Campus

109 T.W. Alexander Drive

Durham, NC 27711

EPA Fluid Modeling Facility (FMF)

4930 Old Page Road

Durham, NC 27703

EPA Human Studies Facility (HSF)

104 Mason Farm Road

Chapel Hill, NC 27514

Outdoor IPM Coordinator: OARM Project Officer for Landscape Maintenance, Pete Schubert

Indoor IPM Coordinator OARM Project Officer for Custodial Services, Al Little

IPM Committee: OARM Health and Safety Officer (Chair)

Indoor IPM Coordinator

Outdoor IPM Coordinator

Nuisance Wildlife IPM Coordinator

FEELC IPM Coordinator

ORD Health and Safety Officer

NHEERL Health and Safety Officer

OAQPS Safety Officer

ORD Pesticide Research Scientist

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3.0 Definitions

Biological control: Biological control means the use of natural predators to control pest populations.

Chemical control: Chemical control means using baits or chemical applications to control pest populations.

Mechanical control: Mechanical control means the physical trapping and removal of pests.

Nuisance Wildlife: Nuisance wildlife includes the wild mammals and reptiles other than the pests listed below that become a nuisance on the RTP campus. Examples of wildlife that may become a nuisance include: beaver, deer, fox, feral cats/dogs, geese, pigeons, raccoons, skunks, snakes, and snapping turtles.

Occupants: All persons working within the EPA-RTP Campus are occupants of the building.

Pests: Pests are populations of living organisms (animals, plants, or microorganisms) that interfere with the use of campus facilities. A list of target pests found on the RTP campus is given below.

Bees, Wasps, Hornets, Yellow jackets

Cockroaches

Flies (mosquitoes, houseflies)

Fire Ants and other ant species

Millipedes, Centipedes

Mites

Poisonous plants (poison ivy, poison oak)

Rodents (rats, mice, squirrels)

Spiders

Termites

Weeds and Invasive Plants

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4.0 Organizational Chart

5.0 Responsibilities

IPM Committee: The IPM Committee will be composed of the EPA-RTP Safety Committee, the IPM coordinators, the FEELC Director and an onsite staff scientist conducting research on pesticide exposure. The IPM Committee will:

Meet annually to review IPM implementation.

Review and revise the IPM plan on an annual basis. This review will be documented.

IPM Committee Chair: The OARM Safety Officer will serve as the IPM Committee Chair.

The chair will:

Ensure implementation of plan.

Lead the meetings of the IPM Committee.

Maintain the minutes of the IPM Committee meetings.

Approve the temporary use of pesticides not listed in the IPM plan (case by case basis).

Pest Control

Contractors

Occupants

IPM Coordinators

IPM Committee

Chair

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IPM Coordinators:

Indoor, Nuisance Wildlife, and Outdoor: The IPM Coordinators will be selected by the OARM Director of the Facility Management and Support Division (FMSD). The

IPM Coordinators will:

Establish and enforce pest contractor’s performance requirements.

Maintain records of pest problems, pest prevention and pest control activities.

FEELC: The Director of the First Environments Early Learning Center will serve as

IPM Coordinator for the FEELC.

Pest Control Contractor: The pest control contractors are subcontractors selected by the EPA-

RTP custodial contract and the landscaping contract. The IPM Coordinators are able to establish and enforce the pest contractor’s performance requirements. There will be one pest control contractor for outdoor pests, one pest control contractor for indoor pests, one pest control contractor for nuisance wildlife, and the indoor plant contractor. Each pest control contractor is responsible for:

Complying with the requirements of this IPM plan.

Providing an action plan for the EPA-RTP campus at the beginning of each contract period.

Reporting to the IPM Coordinators the results of pest control activities. A sample report is provided in Appendix A. Reports shall include:

o A monthly activity report of activities along with recommendations for controlling pests. These recommendations may include suggestions for implementation by the campus.

o A monthly monitoring report on bait stations, traps and evidence of pest infestations.

Providing professional recommendations to the IPM Coordinators for methods of preventing and controlling pest problems.

Reporting any spills to the IPM Coordinators immediately.

Occupants: Occupants are not allowed to bring in pesticides/herbicides for personal use.

Occupants are responsible for:

Understanding and abiding by the EPA-RTP IPM policies herein.

Storing food and drinks in airtight containers.

Reporting pest problems to the IPM Coordinators as soon as possible.

Maintaining the health of personal plants in their office space.

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6.0 Pest Control Contractor Selection Process

The pest control contractor shall provide the following documentation:

Evidence of applicator license for structural and outdoor pesticides.

Copy of general liability insurance certifications.

At least 3 references from other office building clients served by the company.

Pest control contractors shall be given a copy of this IPM and shall conduct a walk-through of the building prior to proposal submission. Contractors shall provide a recommended pest control plan as part of their proposal.

7.0 Maintenance and Monitoring

Preventing the establishment of pest populations in the indoor environment and around structures is the first step in pest management. This is accomplished by eliminating the conditions that attract pests. Food and water sources will be minimized. Food should be kept in airtight containers, and water leaks will be controlled. Campus Occupants will be trained in the importance of maintaining their workspace to discourage pest infestations.

Pests will be denied access to building interiors by maintaining the integrity of doors and walls.

Cracks will be promptly sealed. Foliage will not be allowed to grow up the walls of any structure, and it will be kept trimmed next to buildings.

Regular inspections will facilitate early detection of pests before large populations can be established. Building perimeters, entrances, kitchens, service areas and dumpsters will be inspected on a monthly basis by the pest control contractor. Inspections should include bait stations and rodent traps. Rodent traps shall be inspected more frequently when there is evidence of rodent activity.

The pest control contractor shall submit a written report to the IPM Coordinators after each inspection is completed. The report shall include information on the evidence of pest infestations and the condition of bait stations and traps. The report will also include an action plan detailing expected activities from the pest control contractor and any recommendations for improved maintenance.

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8.0 Mechanical Control

The pest control contractor will initially use mechanical control methods for removing established pest populations where appropriate.

9.0 Chemical Control

The pest control contractor will use chemical control methods as a last resort for controlling pest infestations. Chemical control may be the only solution in some circumstances. Chemicals shall be used in the order listed on this IPM.

If the pest control contractor needs to use a chemical not listed in this IPM plan, he must first apply to the IPM Coordinators for approval of the chemical. The IPM Coordinators will submit the request to the IPM Committee Chair. The alternate chemical may be used only after the IPM

Committee Chair has granted approval.

10.0 Indoor Plants

The indoor plant contractor will keep indoor plants free of pests using mechanical methods and/or a solution of soap and water where possible. Should this not control pest infestations, plants will be removed from the campus prior to the use of chemical pesticides; or an alternative indoor application method will be reviewed and approved by the Indoor IPM Coordinator, based on the approved indoor pesticides, detailed in Table 2 below or approval by the IPM committee.

Replacement plants will be installed that are free of pests. The interior plant maintenance contractor shall employ methods (sanitization of tools, use of disposable gloves, removal of diseased soil and plant material, etc.) to prevent the spread of pests from plant to plant.

11.0 Action Levels

Insects and rodents are an important part of the ecosystem. However, they are also vectors for causing disease and injuries from bites and stings. It is impossible to eliminate all pests.

Therefore, this IPM establishes the following action levels for pests in and around the RTP campus. Pests are not acceptable in the indoor environment.

Table 1: Action Level – Outdoor Pests

Pest Action Level

Bees, Wasps, Yellow jackets, Hornets

Bee, wasp, yellow jacket and hornet will controlled within 10 feet of walkways, evacuation assembly points, and outdoor storage units.

Fire Ants Fire ant colonies within 3 feet of walkways, evacuation assembly points, or outdoor storage buildings will be

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Pest Action Level controlled.

Other ants Ant colonies within 1 foot of building foundations will be controlled.

Poison Ivy

Poison Oak

Poison ivy and poison oak will be controlled within 3 feet of walkways and evacuation assembly points.

Rodents (rats, mice, squirrels)

Rodent nests within 3 feet of main campus buildings or outdoor storage units shall be controlled.

Snakes Nuisance snakes will be handled on a case by case basis.

Spiders:

Black Widow

Black widow spiders will be controlled within 3 feet of walkways, evacuation assembly points, and outdoor storage buildings.

All Other Pests All other pests will be controlled at the discretion of the

IPM Coordinators.

12.0 Indoor Pesticide Use

EPA has established a policy of using the least toxic pesticide. A list of approved pesticides that may be applied indoors by the pest control contractor is provided in Table 2.

Additions to the approved list may be approved by the IPM Committee Chair after consulting with the IPM Committee. The Chair may grant temporary approval in situations where a decision needs to be made quickly. Pest control contractors are encouraged to present alternatives based on their professional experience.

Table 2: Approved Indoor Pesticides

(NOTE: this list is not intended to be comprehensive.)

Pests Approved Indoor Pesticides

Insects and Spiders Hydroprene

Fenoxycarb

Cyfluthrin

Cypermethrin

Permethrin

Fipronil

Imiprothrin

Imidcloprid

Avermectin

Hydramethylnon

Boric Acid

Silica Aerogel

Pyrethins synergized with PBO

Rodents (rats, mice, squirrels) Traps, glue boards and bait stations should be used to control rodent populations.

Baits must be submitted to the IPM Committee Chair for approval.

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13.0 Outdoor Pesticide Use

EPA-RTP has established a policy of using the least toxic pesticide. A list of approved pesticides that may be applied outdoors by the pest control contractor is provided in Table 3.

The pest control contractor is encouraged to offer alternate approaches and compounds based on their knowledge and availability of chemicals and technology.

Additions to the approved list may be approved by the IPM Committee Chair after consulting with the IPM Committee. The Chair may grant temporary approval in situations where a decision needs to be made quickly.

Table 3: Approved Outdoor Pesticides

Pest Pesticide

Insects and spiders Cyfluthrin

Cypermethrin

Permethrin

Acephate

Soap

Hydramethylnon

Fipronil

Imidacloprid

Spinosad

Carbaryl

Diatomaceous Earth

Rodents Traps, glue boards and bait stations should be used to control rodent populations.

Baits must be submitted to the IPM Committee Chair for approval.

Plants (weeds) Glyphosate

14.0 Nuisance Wildlife Action Plan

Increasing numbers of resident geese, deer, rabies vectors such as raccoons, foxes, cats, coyotes, and venomous snakes pose a human health and safety threat. On occasion it is expected that employees will occasionally encounter this wildlife. Employees should avoid interfering with wild animals encountered on the campus. In addition, employees should physically avoid any animal exhibiting unusual or defensive behavior and report the behavior immediately to the safety office.

Wildlife control on the campus is treated on a situational basis. The Nuisance Wildlife IPM

Coordinator will take appropriate action when animals encountered on the campus may pose a threat to employees. The Nuisance Wildlife IPM Coordinator will consult with the United States

Fish and Wildlife Service (USFWS) or other appropriate agency for managing wildlife on an as needed basis.

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15.0 Reporting and Communication

Occupants should call the IPM Coordinators if they observe a pest or nuisance wildlife problem.

The IPM Coordinators will:

Follow up with the reporting tenant concerning actions resulting from the tenant’s report

Notify occupants if they need to improve housekeeping efforts to minimize pest problems.

Inform occupants that are observed violating the IPM of the requirements of the IPM.

Contact the IPM Committee Chair if the pesticide control contractor requests the use of non-approved chemicals.

The pest control contractor will:

Seek permission to use chemicals other than those listed on the IPM when necessary.

Make recommendations to the IPM Coordinators and the IPM Committee on practices and procedures for minimizing pest problems.

Report to the IPM Coordinators the results of all monitoring and the actions taken to minimize pests. The contractor will specifically outline which pesticides were used, where and when they were used, how they were used and how much was used.

The IPM Committee will develop a communication calendar and provide reminders of the IPM plan to all occupants. These reminders will take the form of posters and café table cards.

Reminders will occur periodically throughout the year.

An email will be sent to all occupants when this IPM plan is adopted. A copy of this IPM plan and summary training will be maintained on the OARM Safety, Health and Environmental

Management intranet website, http://intranet.epa.gov/rtp/orgs/hssd/info.htm. Posters and café table cards will be used to notify the campus community of the adoption of the IPM plan.

16.0 Training

Occupants will receive training on the IPM plan through new-hire safety orientation and the

OARM Safety Health and Environmental Management (SHEM) website. Training PowerPoint slides will be posted on the website for occupant review.

It will be instrumental for the employees of the Facility Management and Support Department

(FMSD) to fully understand the program. They will receive training detailing the IPM plan when the plan is initially implemented. Annual updates to the plan will be covered once each year in IPM committee meetings and through the established communication calendar.

http://intranet.epa.gov/rtp/orgs/hssd/info.htm http://intranet.epa.gov/rtp/orgs/hssd/info.htm

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17.0 Recordkeeping

The OARM SHEM office will maintain the minutes from the annual IPM Committee meeting, copies of each draft of the IPM plan, and copies of annual training slides and rosters.

The IPM Coordinators will maintain copies of the monthly activity reports provided by the pest control contractor.

18.0 Annual Review

The IPM Committee will meet once each calendar year. They will evaluate the following questions.

Is the IPM plan working?

What pest problems did the campus have for the previous year?

Should the plan be modified?

Are there changes to the organization chart?

Should there be amendments to pesticide control contractor’s contract?

Should there be any additions or deletions to the approved pesticide lists?

The IPM Committee will revise the IPM plan as necessary.

Integrated Pest Management Plan Appendix A

Appendix A - Sample Pest Control Contractor Monitoring Report – Indoors/Outdoors

Date: __________________________________ Time: ________________________

Facility: ________________________________________________________________

Entrances, building perimeters, walkways, dumpsters and rodent bait stations, traps and glue boards must be inspected on a monthly basis. Evaluate the entrances and building perimeters for cracks, pest access points. Evaluate all locations for evidence of pests and potential pest harborage.

No evidence of outdoor pests or problems was noted during the inspection.

Location Pest or

Problem

Description

(include quantity)

Solution/

Recommended Actions

Actions Taken Pesticide Applied &

Quantity Used

Signature Printed Name

Appendix A

Integrated Pest Management Plan Attachment 1 – IPM Policy for the FEELC A Appendix A

Attachment 1 – IPM Policy for the First Environments Early Learning Center

Purpose

This policy supports the use of an Integrated Pest Management (IPM) approach at the First

Environments Early Learning Center (FEELC) which follows widely accepted IPM best practices for early childcare providers. The IPM policy is aimed at actively working to reduce the presence of harmful pests in the center, while minimizing potential exposure of children, staff and visitors to pesticides. This policy works together with the EPA-RTP’s IPM Plan and defines additional measures pertaining to the FEELC. Regularly scheduled applications of pesticides are not permitted under this IPM policy.

Definitions

Exempt applications include pesticide products which are self-contained baits or traps, gels or pastes being used in a crack or crevice treatment, a pesticide exempted under the Federal

Insecticide Fungicide and Rodenticide Act (FIFRA), or antimicrobial pesticides, including sanitizers and disinfectants.

Routine applications are those pesticide applications which, generally, are necessary throughout the year (such as the localized treatment of fire ants). Routine applications are not regularly scheduled applications and are applied only on an as needed basis.

Non-Routine applications include all pesticide applications at the FEELC which do not meet the two definitions listed above.

Emergency applications are those applications wherein the FEELC and the EPA-RTP, together, deem the immediate use of a pesticide as being necessary to protect the health and safety of the children, staff and visitors.

Policy

FEELC will implement and practice IPM to manage pests in the buildings and grounds to minimize the exposure of children, staff and visitors to pesticides. In accordance with IPM best practices for early childcare providers, the FEELC will:

Work with EPA-RTP to notify parents and staff in writing, annually, of what pesticides are expected to be applied at the FEELC.

Inform all parents and staff prior to every non-routine application not deemed an emergency.

o Notification of non-routine pesticide applications at the FEELC will occur at least 72 hours prior to the application. The notification will include the name of the pesticide, the active ingredient(s) in the product and the date and anticipated time the pesticide is to be applied.

Pesticide applications will occur after normal business hours, unless an emergency application is necessary. Children, staff and visitors will be asked to vacate the immediate area in an emergency application situation and notification will occur within

24-hours of an emergency application.

Integrated Pest Management Plan Attachment 1 – IPM Policy for the FEELC A Appendix A

Visual markers will be posted in the vicinity of a pest problem as soon as a pest is identified in order to alert children, staff and visitors to stay clear of the area. The marker will remain in place throughout all pesticide applications and will stay in place for at least 72 hours after pesticide application. FEELC will visually demarcate pesticide application areas by doing the following:

o Green flags (see Attachment 1.C) will be placed outdoors in areas where age appropriate.

o A barrier (see Attachment 1.C) will be placed outdoors for infant and toddler play areas.

o A warning sign(s) will be posted indoors near the area of treatment, and if within a classroom, on the classroom entry door(s) (see Attachment 1.C).

EPA-RTP will maintain records of all pesticide applications at the FEELC for a period of four years and will make these records available to those parents and staff who request them.

IPM Program

The FEELC program will include the following:

Semi-annual inspections, conducted by the pesticide contractor, during major seasonal transitions to identify pest problems and/or potential pest problems.

Preventative actions to reduce future pest problems, to include annual training of

FEELC staff.

Preference for the use of non-chemical management practices to address pest problems.

Use of least-toxic pesticides after non-chemical management practices have failed or are deemed inappropriate treatment options.

FEELC designation of a FEELC IPM Coordinator to oversee implementation of IPM practices.

Integrated Pest Management Plan Attachment 1.A

Attachment 1.A – Sample Annual Notification Letter

[DATE]

Dear Parents and Staff, The First Environments Early Learning Center (FEELC) is providing to all parents, guardians and staff a listing of all pesticides expected to be used at the Center in the coming year.

FEELC uses an integrated pest management (IPM) approach to managing ants, rodents and other pests. Our goal is to protect the health of our children and staff and the environment by reducing pesticide use. Prevention is critical to this approach, and we work hard to keep pests out of our building, and remove their access to food, water and shelter. A copy of the IPM plan is available at the Center for your review.

When pests enter the Center, we try to use nonchemical and least-harmful methods to deal with them. Occasionally, we do have to use pesticides to manage these pest problems. Pesticides are only used as a last resort and are only applied after hours, except in emergency situations.

As many of you are already aware, fire ants have been an ongoing concern at FEELC, requiring a significant amount of effort in order to address their safety concerns to children playing outdoors. Fire ants are the number one pest problem at the FEELC, and comprise the majority of our routine pesticide applications throughout the year. Fire ants, upon discovery, are visually marked for staff and children awareness and are then baited outdoors or treated with a soapy-water or bleach-water solution indoors.

Parents, guardians and staff will be notified regarding non-routine pesticide applications throughout the year. Non-routine applications are all those applications not included on the list below. Beginning [date], parents and guardians will be notified at least 3 days prior to a non-routine pesticide application (as long as it is not an emergency application, in which case notification will be made within 24-hours after the application).

The following pesticides will be used, as necessary, on center this coming year:

Name of Pesticide Product Active Ingredient(s) Targeted Pest

Integrated Pest Management Plan Attachment 1.A

If you have any questions, please contact Trudi Tuinstra at [number].

Sincerely, Integrated Pest Management Plan Attachment 1.B

Attachment 1.B – Sample 72-Hour Notice of Non-Routine Pesticide Application

Dear Parent, Guardian or Staff, We are writing to notify you about a specific pesticide application(s) at the First

Environments Early Learning Center. Please see below for detailed information. If you would like to see the Material Safety Data Sheet for this chemical, it is available at

[location]. If you have any questions, please contact [name] at [phone].

Sincerely, NOTICE OF PESTICIDE APPLICATION

Date:

Name of Child Care Center: FEELC

Pest of Concern:

Location of Planned Pesticide Application:

Building Room Number:

Playground or Grounds Area:

Name of Pesticide to be Applied:

Active Ingredient(s):

Planned Date/Time of Pesticide Application:

Integrated Pest Management Plan Attachment 1.C

Attachment 1.C – Sample Visual Markers

Example of a ‘green flag’ visual marker.

Example of a ‘barrier’ visual marker for the infant and toddler play areas.

Integrated Pest Management Plan Attachment 1.C

Example warning sign used as an indoor visual marker.

Example posted warning sign used as an indoor visual marker.