Attachment A
City of Sunnyvale
Integrated Pest Management Plan / Policy and
IPM Implementation Plan
FINAL DRAFT 2.34
JuneMarch 2002
City of Sunnyvale Integrated Pest Management Policy
I. Introduction
This policyplan sets forth the guiding principles for the development and implementation of athe City of Sunnyvale Citywide Integrated Pest Management Plan as required underby provision C.9 of the City’s Stormwater National Pollution Discharge Elimination System (NPDES) discharge permit (Order No. 01-024). The City’s Pest Management Plan/PolicyPlan and Policy Advisory Committee developed thisthe Integrated Pest Management Policy and IPM Implementation Pplan with input from the representatives from the Department of Public Works, Department of Parks and Recreation, Department of Human Resources/ Risk and Insurance, Officeand Office of the City Manager, and consultation by Sierra Consulting & IPM.
(See Appendix I for definitions of terms and acronyms used in this IPM Plan/PolicyPolicy and Implementation Plan.)
II. Integrated Pest Management PolicyPlan / Policy and IPM Implementation Plan Goals
The goals of the City of Sunnyvale Integrated Pest Management Plan /Policy and IPM Implementation Plan are to:
2. Provide a means of educating all City departments to practice the most appropriate approach to managing pests in and around City buildings and facilities, parks and golf courses, urban landscape areas, and rights-of-way.
3. Reduce or minimize pesticide use in the City of Sunnyvale.
4. To eEliminate adverse impacts to water quality via pesticide usage.
5. Prevent adverse impacts of pesticide usage on the quality of composted green waste.
III. City of Sunnyvale Integrated Pest Management Policy
The City of Sunnyvale, including all departments and staff herein, and contractors providing pest management services and all leaseholders o onf Ccity properties shall follow the City’s Integrated Pest Management (IPM) Plan/Policy Policy for the control or management of pests in and around City buildings and facilities, parks and golf courses, urban landscape areas, and rights-of-way.
Pest Control Advisor (PCA):
Before performing any pesticide application on City property, a licensed Pest Control Advisor will consider the following options or alternatives:
1. No controls (e.g., tolerating the pest infestation, use of resistant plant varieties or allowing normal life cycle of weeds)
2. Physical or mechanical controls (e.g., hand labor, mowing, etc.)
3. Cultural controls (e.g., mulching, disking, alternative vegetation)
4. Biological controls (e.g., natural enemies or predators, goats)
5. Reduced-risk chemical controls (e.g., soaps or oils)
Pesticide Applicator (QAL, QAC or Structural Pest Control Operator):
Those performing pesticide applications (including pesticide management contractors engaged by the City) shall adhere to IPM practices that provide a reduced-risk approach forto dealing with pests. and Pesticide Applicators will followuse the most current technologies available to ensure the long-term prevention or suppression of pest problems in order to minimize. Thereby minimizing negative impacts on the environment, non-target organisms, and human health.
All City Staff and Departments:
The City departments and staff will recommend and promote non-toxic and reduced-risk alternatives for structural or landscape pest control, seeking to use the most recent IPM technologies and best management practices.
The City will promote education for all City staff regarding IPM practices. The City will also provide information to the residents and special districts within the City regarding the City’s Integrated Pest Management PlanPolicy and IPM PolicyImplementation Plan. Through these efforts, the City will establish a role model approach to encourage the use of less toxic techniques for structural or landscaping pest control practices.
The City of Sunnyvale is committed to the reduction, phase-out, and elimination of the usage of pesticides on City properties that are identified as causing impairment to the Santa Clara Basin waterways.
Pest Management Contractors for the City:
After the approval date of this policy, new contracts negotiated with pest management contractors employed by the City will include conditions requiring that they follow practices described in the City’s Integrated Pest Management Policy and IPM Implementation Plan. This includes employing the Best Management Practices and Standard Operating Procedures outlined in the IPM Implementation Plan for pest control actions occurring on City-owned property.
City Property Leaseholders:
The City of Sunnyvale shall use reasonable efforts to require the use of IPM practices as a part of new leases negotiated for City property after the approval date of this Policy. Current City property leaseholders will be informed of the City’s IPM Policy and the IPM Implementation Plan and encouraged to use the IPM practices discussed in these documents whenever practical.
City of Sunnyvale IPM Implementation Plan
I. What is IV. Integrated Pest Management (IPM)?
Integrated Pest Management is the strategic approach that focuses on the long-term prevention of pests and their damage from reaching unacceptable levels by selecting and applying the most appropriate combination of available pest control methods. These include cultural, mechanical, biological and chemical technologies that are implemented for a given site and pest situation in ways that minimize economic, health, and environmental risks.
In definition and in practice, IPM is a problem-solving approach to pest management, which seeks the best possible balance between environmental protection, costs and benefits, and the protection of human health and public safety.
Integrated Pest Management Guidelines and Practices
Integrated Pest Management requires the development of an IPM Program that includes following the pest management guidelines listed below for any particular pest and site.
a. The environment and any adverse impacts/effects that may occur from the proposed treatment.
b. The effectiveness of the proposed treatment in controlling the pest.
c. The efficiency of the proposed treatment as compared to alternative treatments.
d. The economics (costs and benefits) of the proposed treatment.
a. Habitat management or modifying the biological environment.
b. Changing maintenance practices (e.g. modifying watering, mulching, food storage and waste disposal).
c. Physical control methods that may include mechanical removal, traps and/or barriers).
d. Biological control measures or use of natural enemies.
e. Inclusion of Use pest-resistant landscaping and design features for new development projects and significant redevelopment projects on Citywithin-owned property the City of Sunnyvale.
a. Biology ofn each pest.
b. IPM technologies that provide for the most appropriate approach to pest management.
c. New pest management strategies as they become known.
d. Best Management Practices (BMPs) and Standard Operating Procedures (SOPs) associated with each technology.
e. Increasing awareness ofinto protecting the environment and Environmental Stewardship issues pertaining to pesticide applications.
f. Requirements of the City’s IPM Policy and IPM Implementation Plan.
(See Section VI. 3IX – 4 for additional training requirements.)
IIV. Adoption
of IPM and Reductions for Certain Pesticides
Integrated Pest Management offers continuing opportunities for new reduced-risk technologies to replace older methods in an ongoing effort to promote Environmental Stewardship.
Scientists worldwide are seeking more environmentally sound techniques that are more effective, yet safer for humans and animals. Technologies are rapidly changing, so it is imperative that the IPM practitioner be attentive to all the newest methods. All pest management methods throughout history have been challenged by new techniques and once these new methods are proven effective and cost effective, IPM practitioners quickly adopt the newer technology.
By California law, Licensed Pest Control Advisors (PCAs) are required to receive 40 hours of Continuing Education for license renewal. Through this continuing education, new IPM research and practices should be studied carefully by Licensed PCAs to educate oneselfensure they have knowledge of in the latestlatest IPM developments. in IPM.
Information regarding new IPM products, methods and technologies should be documented and made available to all City pest management personnel, pest management contractors for the City, and leaseholders, to promote outreach and education about IPM and the most current practices in pest management.
Certain pesticides of concern have been identified as contributing to water quality problems. In addition, some herbicides have been linked to problems with compost quality. Examples of these are:
Organo-phosphate Pesticides and Copper-based Pesticides
One particular group of older pesticides, mainly insecticides, contained Organo-phosphates (OP’s) as active ingredients. Two of these products are Diazinon and Chlorpyrifos. Each of these materials has a relatively long half-life in the environment. Many Uurban streams in the Santa Clara Basin have been listed as impaired for Diazinon under the Clean Water Act and are on the USEPA 303(d) list for impaired waterways.
Copper is currently listed by the US EPA as a contaminant in San Francisco Bay. Actions to limit the discharges of copper to the South Bay are included in the South San Francisco Bay Copper Action Plan included in the City’s NPDES Stormwater Permit requires that these actions be implemented. The City is required to implement actions to limit the discharges of copper into the South Bay. These actions are found in the South San Francisco Bay Copper Action Plan, which is included in the City’s NPDES Stormwater Discharge Permit.
For most pest control circumstances, less toxic chemicals or biological control techniques can replace organophosphate and copper-based pesticides. Organophosphate and copper-based pesticides will only be used by the City of Sunnyvale after careful review, and when justified by a Licensed Pest Control Advisor. If organophosphate-containing pesticides and copper-based pesticides are used, application techniques will be employed to prevent the contamination of stormwater and urban streams.
Clopyralid
The California Department of Pesticide Regulation has proposed a ban on a group of products containing the herbicide clopyralid found in some 17 formulations registered for use in California. Clopyralid is an active ingredient in a variety of formulations available for over-the-counter purchase by residents for weed control or weed and feed purposes.
Research has shown that composted green waste products can be contaminated with clopyralid. Levels of clopyralid present in compost at 1-3 parts per billion can have an adverse growth effect on plants such as beans, peas, peppers, potatoes, tomatoes and sunflowers. However, clopyralid is also a valuable herbicide for managing certain infestations such as the Yellow Star Thistle and the others in the noxious Thistle family of weeds that may infest native grass areas.
The City will not collect green wastes for composting from City properties where clopyralid has been applied. This will prevent the potential contamination of composted products being produced at the SMaRT station or other City facilities.
Sites where clopyralid is currently in use include restoration projects and/or native grass landscapes at Baylands Park as well as the City Golf Course. Green wastes (i.e., grass clippings) from these locations will be left in place to help promote a healthy thatch layer in the turf.
Information regarding new IPM products, methods and technologies should be documented and to all City pest management personnel, contractors for the City, leaseholders, to promote outreach and education into IPM and the most current practices in pest management.
IIIVI. Water Quality and Pest Management Practices in the City of Sunnyvale
One of the main goals of this IPM Plan/Policy Policy and IPM Implementation Plan is to eliminate adverse impacts to water quality byvia any pesticide usage. A key element of Integrated Pest Management is that of Environmental Stewardship. When recommending pesticides for use or applying pesticides, the environment must always be taken into consideration. The City of Sunnyvale IPM practionerspractitioners shall select and apply integrated pest management methods that will have the least impact or effect on water quality and the environment.
The City of Sunnyvale will always avoid applications of pesticides that directly contact water unless the pesticide is registered under Federal and California law for aquatic use. Pesticides that are not approved for aquatic use will not be applied to areas immediately adjacent to aquatic sites where, through drift, drainage or erosion, there is the possibility of a pesticide to be transported into surface water.
As of March 12, 2001, the Ninth Circuit Court of Appeals determined thatD discharges of pollutants from the use of aquatic pesticides to waters of the United States require coverage under athe National Pollution Discharge Elimination Systems (NPDES) permit, (Headwaters, Inc. vs. Talent Irrigation District).. The regulating department for this in California is the State Water Resources Control Board, who issues the NPDES permit. Those that apply pesticides directly to waters of the United States will secure a NPDES permit prior to making applications.
While the NPDES permit is required for aquatic pesticide applications, and in some cases warranted for certain pest issues, tThe general goals of the City of Sunnyvale’sof Sunnyvale’s pest management procedures will be to avoid any unnecessary adverse impacts on surface or ground water quality.
IVVII. Education and Outreach for IPM City Wide Participation
The City, in participation with the Santa Clara Valley Urban Runoff Pollution Prevention Program, has a public outreach program to encourage people who live, work, and/or attend school in Sunnyvale in the use of IPM techniques, least toxic pesticides, and proper disposal of unused pesticides and their containers.
1. The City will expand its current public outreach program to include:
a. City employees not authorized to apply pesticides as part of their normal job duties.
b. Selected business owners, ((i.e.,including landscape gardeners,gardeners and commercial pesticide applicators).
c. Any special districts that occur within the Sunnyvale city limits
d. School District staff that may be involved with pest management (i.e., landscape and facilities), administration and teachers).
The California Healthy Schools Act of 2000 (AB 2260) imposed requirements on California school districts regarding pesticide use in schools. Posting of notification prior to the application of pesticides is now required, and IPM is stated as the preferred approach to pest management in schools. The City of Sunnyvale staff is trained to follow requirements of the California Healthy Schools Act of 2000.
2. The City will develop and implement an outreach campaign to reach these various audiences. The message will include the following information about the City’s IPM Plan/PolicyPolicy, IPM Implementation Plan, and:
a. Reasons to select the least toxic pest control method and minimize the use e of pesticidesdes.
b. How to obtain more information about IPM methods to control pests.
c. c. Proper disposal of unused pesticides and pesticide containers.
VIII. Best Management Practices (BMP’s) for the IPM Implementation Plan for implementing the Pest Management Plan
Below are the contact numbers for each agency. Do not hesitate to contact these agencies, as they are here to help with issues regarding laws and regulations pertaining to pesticides.
Federal: U.S. EPA Air and Toxics Division, Pesticides
415-744-1087
State: Cal-EPA Department of Pesticide Regulation
916-445-4700
County: Santa Clara County Agricultural Commissioner
408-299-2172
For all City staff or r contractors involved with pest management, it is requiredis required that all individuals recommending pesticides be licensed by the State of California Department of Pesticide Regulations as Pest Control Advisor or Licensed Qualified Applicator. All other employees involved with applying pesticides pesticide applications will be trained as required by DPR rules and work directly under the supervision of a licensed applicator.
a. Avoid application if rain is expected. (This does not apply to the use of pre-emergent herbicide applications when required by the label for optimum results).
b. Avoid applications to saturated soils, puddles or any water, steep slopes prone to erosion, or dry soils that may blow in the wind.
10. Calibrate application equipment prior to and during use to ensure application rate is accurate and precise.
11. When applying pesticides always employ techniques to minimize off site movement or drift of spray materials.
a. Apply only when wind speed is low and not blowing toward sensitive areas such as schools, hospitals, shopping malls, residential areas, or sensitive natural/wild habitats.
b. Use low-pressure settings and large droplets while spraying pesticides and use drift retardant additives where applicable.
c. Apply only to target pest and avoid non-target areas.
12. Clean equipment after use and dispose of wastes in accordance with State, Federal, and County requirements. Store equipment in a secure, dry area.
13. If irrigation is required after a pesticide application to landscape areas, irrigate appropriately to prevent runoff.
14. When making crack and crevice applications in and around structures or buildings, avoid over-application to adjacent hard (concrete, brick or tile) surfaces. Ensure that applications are precise and accurate to avoid off- target movement of pesticides.
15. To prevent potential compost product contamination, do not collect green waste for composting from city properties where clopyralid has been applied.
VIIX. Standard Operating Procedures (SOP’s) for the for implementing the Pest Management Plan.
IPM Implementation Plan
The goals of this IPM Implementation Plan are to minimize overall pesticide use on City of Sunnyvale properties and prevent pesticides from reaching any waterway, by storm water discharges and landscape runoff to the maximum extent practicable. Sunnyvale is also committed to the reduction, phase-out, and elimination of use of pesticides that have been identified as causing impairment to Santa Clara Basin waterways. The following list of SOPs will help the City to meet the goals of this IPM Implementation Plan.
a. The use of IPM in all pest management decisions, recommendations, and situations.
b. The Mminimization of all pesticide use.
c. c. Limiting the use of Oorgano-phosphate pesticides identified as causing water quality problems and/or copper based pesticides to situations only when their use is justified, all other approaches and techniques have been considered, and adverse water quality impacts are eliminated.
(See Section VIII for Best Management Practices.)
a. City Departments responsible for pest management on City property must provide Pesticide Safety Training on an annual basis for all employees conducting pest management activities. Pesticide Safety Training must be conducted as as required byper requirements of the California Department of Pesticide Regulations and the Federal EPA.
All City departments, contractors and leaseholders will ensure that any contractor employed to conduct pest control and pesticide applications on city property engages in pest control methods consistent with the City’s IPM Plan and Policy, BMPs and SOPs. The contractor shall supply evidence of IPM training. The contractor will annually provide documentation of pesticide use (e.g., pesticide used, target pest, quantity used, location applied) on city property.
b. Ensure that all those individuals who apply pesticides to City properties, including pest management contractors and their employees, will obtain the appropriate training as required by the County Agricultural Commissioner, State Department of Pesticide Regulation and the Structural Pest Control Board.
c. Employees responsible for pesticide recommendations and applications will receive annual training on the appropriate portions of the City’s IPM Plan/PolicyPolicy, IPM Implementation Plan, Best Management Practices (BMPs) and Standard Operating Practices (SOPs) as well as the latest in IPM technology and application methods.
d. Training must also include information regarding the safe use and handling for each particular pesticide that the employee may work with, and appropriate training on personal protection and protective coverings to be worn while applying the pesticide. It must also cover, chronic or long term exposure issues and any special information required by the product label for mixing or applying pesticides safely and having noso as to adverse minimize adverse effects on the environment, human health or public safety.
e. Training for employees that that apply pesticides must include the Pesticide Safety Training Series N-1 to N10, available through the California Department of Pesticide Regulation.
f. Employees who are not authorized and trained to recommend or apply pesticides will be informed of the City’s IPM Policy, IPM Implementation Plan, and that they cannot use over-the-counter pesticides in or around the workplace.
g. Pest management contractors shall supply evidence of IPM training for Pest Control Advisors and staff that apply pesticides on City property upon request by City staff.
a. Pesticides discovered during the annual inventory that are no longer legal or appropriate for application will be disposed of in accordance with appropriate State and Federal regulations.
b. Copies of the annual inventory and information regarding the disposal of any pesticides removed as a result of the inventory will be submitted to the Environmental Division Manager of the Public Works Department at the end of each calendar
year
8. Pesticide sStorage and dDisposal requirements are:
a. Each department with pest management responsibilities will implement storage requirements for the pesticide products usingwith guidance from City of Sunnyvale Administrative Policy Manual, Chapter VI, Article VI, Section 1-4 and the Santa Clara County Agricultural Commissioner.
b. Storage facilities should be managed to minimize quantities of pesticides stored, purchasing only what is needed for use in the near future. Rotate inventory to prevent any one product from remaining longer that than new replacements being purchased. As older pesticides are left unused, dispose of properly and according to State and County regulations.Dispose of older, unused pesticides properly and in accordance with State and County regulations.
c. Pesticides must be stored in a locked storage area that is properly posted and visible from a minimum of 25 feet from all directions of possible entry. Do not store pesticides in areas where they may get wet from rain or from possible flooding.
d. Store pesticides only in their labeled containers. Ensure that all labels are readable and attached securely to the container.
e. Provide pesticide spill kits., store the kits near pesticides, Keep them near pesticide storage areas and train employees on proper use of the kits. Spill kits should also be available on any application equipment such as spray trucks or tractors.
f. Always triple- rrinse empty pesticide containers and empty the rinse into spray equipment or properly apply to the treated area.
g. Dispose of triple rinsed empty containers as per requirements of the Santa Clara County Agricultural Commissioner.
h. When changing pesticides or cleaning the spray tanks, use tank rinse water as product over the targeted area within the application site.
9. Annual Review and Evaluation Process:To determine effectiveness of the City’s IPM Policy and IPM Implementation Plan, an annual program review process will be developed and implemented by each Department that applies pesticides. Requirements of the annual review and evaluation process are:
a. Each department that applies pesticides will designateDesignate an individual or team to be responsible for the scheduling and conducting the review process.
b. Each department that applies pesticides will meet annually to review Annually review the IPM Implementation PlanIPM Plan, levels of effectiveness and discuss IPM techniques that may improve results.
c. Review staffT training, with a and particular focus on the safe use, storage and disposal of pesticides.
d. All Discuss new modifications to the City’s IPM Policy and IPM Implementation Plan to ensure that it continues to be effective.
e. Each department will pProvideing an annual written evaluation that will be submitted to the Environmental Division Manager of the Public Works Department for inclusion into the City’s NPDES Stormwater Discharge Permit Annual Report.
APPENDIX 1
DEFINITIONS
Biological control – This method uses biological technologies to manage unwanted pests. Examples of this type of control include, but would not be limited to the use of pheromone traps for management of Indian meal moth in food storage/preparation areas, or beneficial insect release for control of certain types of weeds or invasive insects in landscapes.
Cultural control - The use of IPM control methods utilizing grazing, re-vegetation and seeding or landscaping with competitive or tolerant species to manage unwanted weeds, rodents or plant diseases.
DPR - Department of Pesticide Regulations for the State of California’ s Environmental Protection Agency. DPR, in partnership with Federal EPA and County Department of Agriculture, oversees all issues regarding the registration, licensing and enforcement of laws and regulations pertaining to pesticides.
Environmental Stewardship - The strategic approach to pest management in which the IPM practionerspractitioners focus on preserving the natural integrity and health of the environment, including public safety, while recommending or applying pest management methods. Environmental Stewardship philosophy helps to create awareness of the Best Management Practices (BMP’s) and their relationship to maintaining a healthy environment while conducting pest management activities.
Half-Life - The time it takes for one-half or 50% of a chemical to break down in the environment. This varies widely between chemical compounds. Soil microbe populations, amounts of ultraviolet light, temperature levels and/or water quality characteristics increase or decrease the half-life of a product.
Integrated Pest Management (IPM) – IPM is the strategic approach that focuses on long-term prevention of pests and their damage from reaching unacceptable levels by selecting and applying the most appropriate combination of available pest control methods. These include cultural, mechanical, biological and chemical technologies that are implemented for a given site and pest situation in ways that minimize economic, health and environmental risks.
Mechanical controls – The use of IPM control methods utilizing hand labor or equipment such as mowers, graders, weed-eaters, and chainsaws. Crack and crevice sealants and closing small entryways (i.e., around pipes and conduits) into buildings for insect and rodent management would also be mechanical methods.
Non-Agricultural - Sites not considered agricultural but where pesticide use is still regulated by the DPR. These sites include areas such as, but not limited to, cemeteries, parks, golf courses, and rights-of-way (i.e.: , roadsides and utilities).
PCA – PCA or Pest Control Advisor is one licensed by the California Department of Pesticide Regulations according to Title 3, Article 5 of the California Code of Regulations. Only a licensed PCA, who is registered with the County Agricultural Commissioner may provide written pest control recommendations for agricultural pest management, including parks, cemeteries, golf courses, and rights-of-way.
Pesticides – Defined in Section 12753 of the California Food and Agricultural Code as any spray adjuvant, or any substance, or mixture of substances intended to be used for defoliating plants, regulating plant growth, or for preventing, destroying, repelling, or mitigating any pest, as defined in Section 12754.5 (of the Food and Agricultural Code), which may infest or be detrimental to vegetation, man, animals, or households, or be present in any agricultural or nonagricultural environment whatsoever. The term pesticide applies to herbicides, insecticides, fungicides, rodenticides and other substances used to control pests. Antimicrobial agents are not included in this definition of pesticides
Production Agriculture - Sites, as defined by the California Department of Pesticide Regulation (DPR), where crops or livestock are grown.
QAL - Qualified Applicators License is a licensed applicator according to Title 3, Article 3 of the California Code of Regulations. This license allows supervision of applications that may include residential, industrial, institutional, landscape, or rights-of-way sites.
QAC - Qualified Applicators Certificate is a certified applicator of pesticides according to Title 3, Article 3 of the California Code of Regulations. Applications may include residential, industrial, institutional, landscape, rights-of-way sites.
STRUCTURALtructural PestEST ControlONTROL OperatorPERATOR (BranchRANCH I, II oOrR III) – A licensed applicator for pest control within buildings and homes according to the requirements of the Structural Pest Control Board of the California Department of Consumer Affairs.
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