Armed Forces
***********************************
Installation
***********************************
Published and
Distributed by the
Armed
Office of the
Deputy Under Secretary of Defense
(Installations
& Environment)
March 2003
Armed Forces
***********************************
Installation
***********************************
Published and
Distributed by the
Armed
Office of the
Deputy Under Secretary of Defense
(Installations
& Environment)
March 2003
Installation
TECHNICAL
GUIDE NO. 18
Table
of Contents
B. Program Operations................................................................................................................. 3
3. CONDUCT OF REVIEWS........................................................................................................ 9
A. Pre-Visit ……………………………………………………………………………..………9
4. Health and Safety …………………………………………………………………………...20
This document reflects the collective professional opinion of the pest management consultants of the Armed Forces Pest Management Board. In 2001, the document was overhauled by Mr. Kevin Fay (USA) and reviewed by the Real Property Protection Committee with re-issuance as a Technical Guide. The work of all who have been involved with the development and revision of this Guide is greatly appreciated by the AFPMB.
This is one of a series of Technical Guides (TGs) published by the Defense Pest Management Information Analysis Center (DPMIAC), Armed Forces Pest Management Board (AFPMB). The AFPMB is a directorate within the Office of the Deputy Under Secretary of Defense (Installations and Environment) that recommends policies and procedures, provides guidance, and coordinates the exchange of information related to pest management throughout the Department of Defense (DoD). As a unit of the AFPMB, DPMIAC collects, stores and disseminates published and unpublished information on arthropod vectors and pests, natural resources, and environmental biology important to the DoD. Other DPMIAC products include country- or region-specific Disease Vector Ecology Profiles (DVEPs). All TGs and DVEPs, as well as DPMIAC’s database of over 200,000 articles on pest management and medical zoology, are available at the AFPMB Web site <http://www.afpmb.org>.
TGs (formerly Technical Information Memoranda or TIMs) are not policy documents; rather, they provide technical guidance for the use of the DoD pest management community and others. Accordingly, TGs should not be construed or referenced as policy. DoD pest management policies may be found in DoD Instruction 4715.1, "Environmental Security," DoD Instruction 4150.7, "DoD Pest Management Program," other DoD directives and instructions, and implementing component directives/instructions/ regulations.
Inquiries, comments or suggestions for improving TGs may be directed to the Chief, DPMIAC, at (301) 295-7476, FAX (301) 295-7473.
A. This Technical Guide (TG) provides information on installation pest management programs and guidance for evaluation of these programs. It was written to establish uniformity in DoD pest management programs and to help installation personnel, who are responsible for the development and performance of pest management plans, and major command (MACOM) pest management consultants (PMCs), who are responsible for oversight and evaluation of these programs. This TG should not be used in place of compliance assessments or internal and external reviews.
B. This TG reflects the functional elements of an effective program as recognized by the DoD Armed Forces Pest Management Board (AFPMB). An outline of a model pest management program is presented in Section II. Section III contains guidance for PMCs in evaluating programs. Section IV contains a compilation of questions useful to installation personnel and MACOM PMCs in preparing for an on-site program evaluation, and a suggested list of installation points of contact.
C. DoD Instruction 4150.7 requires that PMCs
conduct on-site reviews utilizing the guidance in the DoD
Directive and this TG. Service
regulations may also stress the need for on-site reviews. Informal program evaluations or reviews
should be continuous by local personnel; however, on-site installation
personnel should not conduct formal reviews because of the potential for
conflicts of interest and bias resulting from self-evaluation. Installations with documented pest
management problems, such as deficiencies from environmental compliance audits,
state inspections or federal inspections, should be reviewed annually until the deficiencies are cleared.
1. All installation pest management operations shall be based on Integrated Pest Management (IPM), which is a comprehensive approach to pest control or prevention that considers various chemical, physical and biological suppression techniques, the habitat of the pest, and the interrelationship between pest populations and the ecosystem.
2. This model pest management program is designed as a tool to help installations establish and maintain safe, efficient, and environmentally sound IPM programs. Its implementation will prevent or manage pests that may damage property, structures, or materiel.
3. Installation pest management plans are the documents for implementing this multi-purpose objective. At minimum, plans should:
a. Describe the relationship between pest management objectives and the installation's military mission, the resident installation population, and local geographical features.
b. Identify elements of various pest management functions and their relationship to each other. Priorities should be established for these functions so that resources can be wisely managed.
c. Encompass an IPM approach based on environmentally sound non-chemical measures and the judicious use of pesticides.
d. Establish program compliance with applicable public laws, federal, DoD, and military regulations, and AFPMB guidelines.
e. Identify key points of contact for implementation and coordination of the entire pest management program, e.g., medical, safety, personnel, engineering, non-appropriated fund activities, etc.
f. Be prepared by installation personnel and contain at least the following major headings:
(1) Program Operations
(a)
(b) Natural Resources Programs
(c) Wood Preservation/Protection Programs
(2) Program Management
(a) Workload Identification
(b) Program Budgeting
(c) Competency
(d) Support Agreements
(e) Contracting
(f) Construction Management
(g) Self-Help
(h) Records and Reports
(3) Facilities
(4) Health and Safety
(a) Medical Surveillance Program
(b) Work Place Monitoring
(c) Respiratory Protection Program
(d) Personal Safety
(e) Fire Protection and Public Safety
(f) Hazard Communication Program (Right-To-Know)
(5) Regulatory Compliance
(a) Pesticide Labels
(b) State and Local Regulations
(c) Quarantine
(d) Pesticide Spills
(e) Memoranda of Agreement
(6) Local Conditions
(7) Environmental Protection
(a) Sensitive Areas
(b) Pollution Abatement and Occupational Safety Projects
(c) Pesticide Disposal
(8)
(a) Commissary
(b) Exchange
Appropriate attachments, such as pesticide inventories, contracts for pest control services, SOPs, manpower equations, lease agreements, listings of certified personnel, MOAs, etc., should all be made a part of the installation's pest management plan, which is to be reviewed and updated annually. Some specific guidance for each major heading is given below.
1.
a.
b. Specific areas of concern to the reviewer include: (1) Are pest management operations warranted? (2) Are they efficient? (3) Are appropriate IPM measures being used? (4) Are pesticides being applied only IAW label directions? (5) Are all pest management operations documented in the pest management plan? (6) Is the prioritization of pest management elements appropriate? (7) Are the health and safety aspects of the pest management operation and the health or economics threat of the pest addressed? (8) Are all government pesticide applicators DoD certified? (9) Are all contract pesticide applicators state certified?
c. Priorities established for control are unique to each installation because they are based on local conditions. Examples of factors to consider in determining priorities include: impact of pests on military readiness, cost, effect on morale, health impact or disease transmission, sanitation, damage to structures, other economic losses, and fire hazards.
2. Natural Resources Programs
a. Natural resources programs and pest management programs both have areas of overlapping responsibilities. Coordination between the two programs should be addressed and identified in both the Natural Resources Plan and the Pest Management Plan.
b. Natural resources programs (e.g., agronomy,
forestry, wildlife) use pesticides for animal control and land management. Where pesticides are used, the same
requirements for pesticide applicator training and certification are required
for natural resources personnel as for pest controllers to ensure that
pesticides are used and reported properly.
c. Personnel who review natural resources programs that use pesticides should determine: (1) Are pesticides being applied IAW label directions? (2) Are pesticide applications documented in the installation pest management plan? (3) Are all pesticide applications being reported? and (4) Are natural resources personnel trained and certified in the appropriate pesticide application categories?
3. Wood preservation/protection programs. Wood protection programs are included in installation pest management plans if wood preservatives (pesticides) are used. An effective ground-line inspection and maintenance program can greatly prolong the service life of poles and result in substantial savings. The reviewer should determine: (1) What are the treated wood investments and annual usage? (2) What is the age of poles in relation to ground-line inspection and treatment? (3) Do the procurement specifications properly identify treatment standards, and (4) Is quality assurance provided in specifications and upon receipt of treated wood?
1. Workload Identification
a. Workload identification is the basis for planning, programming, and budgeting the entire program (funding, people, pesticides, equipment, shop facilities, etc.). Good pest management plans contain definitive program information required to accomplish the pest management mission.
b. Annual work plans (standing job orders) must be current and complete, thoroughly address all aspects of the pest management program, and be written in clear, concise terms.
c. Service requests (trouble calls) must also be complete and concise.
2. Contracting. Frequently, installation requirements are met, at least in part, by using commercial pest control services. When these services are used, the contracts must receive technical review and approval from PMCs. Pesticide applications done by contract have the same recording and reporting requirements as those done by in-house forces. Contracts should require a Quality Assurance Evaluator (QAE) monitoring plan. Installation QAE personnel should be trained in QAE inspection procedures and operations for the contracts they evaluate. Service regulations provide necessary guidance on using pest management QAE personnel. The most common types of contracts are augmentation contracts for maintenance services; outlease contracts that are usually let through natural resources offices for agricultural purposes, and pre-construction soil treatment termite control contracts.
3. Construction Management. Coordination mechanisms must be in place to ensure that necessary pest management construction/protection procedures are used from the outset for all construction projects at the installation level. All plans and specifications should be reviewed by qualified design review personnel that have had some training in pest management. All pesticide usage in repair or construction projects should be reported for inclusion in installation reporting systems.
4. Support Agreements. Many installations enter into support agreements with state, local, and federal organizations to receive pest management services. Sometimes these are called interservice support agreements (ISSAs). Specific areas of concern to the reviewer include: (a) Are services being provided to the installation in compliance with applicable regulations? (b) Is adequate service being received? and (c) Does the service effectively assist the installation by reducing manpower requirements?
5. Self-help
6. Program Resources (Current and Proposed). Installation pest management personnel must manage their resources effectively.
a. Areas of concern to the reviewer for resource planning and funding include the preparation, execution, timeliness, and prioritization of the budget.
b. Specific areas of concern to the reviewer in manpower (staffing) planning include: (1) Have grade-level requirements been identified? (2) Have program deficiencies been identified and backlogs documented? and (3) Have manpower survey and workload definition studies been completed?
c. Specific areas of concern to the reviewer for materials and equipment planning include: (1) Do inventories of pesticides and equipment reflect control requirements? (2) Is equipment functioning properly? and (3) Have materials been ordered to meet projected needs?
7. Records and Reports. Pesticide use on DoD
property must be reported.
8. Competency
a. Applicator Personnel. All pesticide applicators and other personnel who directly influence the selection and application of pesticides on DoD property must be periodically trained and certified. The pest management plan should identify these personnel. Specific areas of concern include: (1) certification categories, (2) screening candidates/coordination with installation personnel office, (3) percent certification (goal = 100%), (4) in-house training programs, and (5) recertification training.
b. Quality Assurance Evaluator (QAE) personnel should be DoD-trained IAW guidance furnished in implementing Service directives. Areas of concern include: (1) QAE training, (2) pest management QAE training, and (3) refresher training.
c. Technical References and Operational Guidance. Installation in-house pest management personnel should have reference materials available in the shop. These references include: (1) periodicals, (2) reference publications, and (3) labels/material safety data sheets for each pesticide on hand.
1.
2. Particular items to consider include: (a) personnel traffic flow, (b) ventilation, (c) emergency equipment, (d) spill kit, (e) physical security, (f) shop signs, (g) storage and handling practices, (h) plumbing systems, (i) fire protection systems, and (j) disposal procedures.
1. Medical Surveillance Program. All pest management personnel must participate in a medical surveillance program. This program should include, at minimum, annual physical examinations and blood cholinesterase testing (where carbamate or organophosphate pesticides are used).
2. Workplace Monitoring. As an employer, the installation is required to provide a safe and healthful workplace for pest management personnel. Annual hazard evaluations by medical department personnel are recommended. Areas of concern include: (a) frequency of hazard evaluation, (b) hazards to which workers are exposed (e.g., vapors, liquids, particulates, electrical, noise), and (c) exposure to contaminated equipment.
3. Respiratory Protection Program.
4. Personal Safety. As an employer, the installation must provide pest management personnel with adequate protection from exposure to hazards. Areas of concern include: (a) availability of adequate protective equipment and clothing, (b) laundering of protective clothing, (c) facilities for emergency decontamination, (d) a shower and change room available for daily use, (e) adequate warning signs posted, (f) antidotes available at the emergency treatment room for pesticide poisoning, and (g) enforcement of safety requirements.
5. Hazard Communication Program (Right-To-Know). Installations are required to have a hazard communication program in place, which includes having copies of material safety data sheets readily accessible to all employees.
6. Fire Protection and Public Safety. The installation emergency services (fire/medical/police) should be made aware of the hazards of pesticides being used and stored on the installation so that proper precautions can be taken in the event of fire, spill or accidental poisoning involving pesticides. Areas of concern for reviewers include: (a) Are pesticide storage facilities included in the installation fire protection plan? (b) Are the shop and dispersal equipment secured? and (c) Has a pesticide inventory been provided to fire/safety personnel at least annually?
1. Pesticide Labels. Pesticides must be applied in accordance with label directions. Specific areas of concern to the reviewer include: (a) Are all pesticides used on the installation EPA/state registered? (b) Are both target pest and site on the label? (c) Have environmental warnings been taken into consideration? (d) Are all pesticide service containers labeled (i.e., no unmarked containers)? and (e) Is the purchase of non-standard pesticides approved by the MACOM PMC?
2. State and Local Regulations. Installation pest management personnel will comply with state and local regulations, such as restrictions on pesticide applications in sensitive environmental areas and the need to obtain permits to perform control in areas where protected/endangered species are found. Where compliance questions exist, issues will be raised to MACOM, Service Headquarters, or the AFPMB as appropriate.
3. Quarantine. Installation pest management personnel should be aware of quarantines that apply to installation activities. Quarantines may involve movement of property into or out of quarantine areas (household/retrograde), state permits to move specimens, and availability of segregated storage areas.
4. Pesticide Spills. Pesticides stored and used on the installation should be included in the Spill Prevention and Countermeasures Plan (SPCCP) and the Installation Spill Control Plan (ISCP). A spill kit should be available in the pest management facility.
5. Memoranda of Agreement (MOAs). Installation pest management operations may be affected by MOAs with state and local agencies. A copy of the MOA, or other applicable documents (e.g., ISSAs), should be attached to the installation pest management plan.
Installation pest management personnel should maintain liaison with other nearby DoD installations and state/local agencies, such as fish and wildlife, county agricultural extension, public health, and mosquito control agencies. Coordination should also be maintained with installation medical personnel for information on surveillance and potential health threats. This contact is the responsibility of the installation pest management coordinator.
1. Sensitive Areas. Installation pest management personnel should be aware of the potential adverse environmental impacts of pest management operations.
2. Operations of special interest are: (a) use of restricted-use pesticides; (b) use of any pesticide that may contaminate surface or ground waters (aquifers), or cover more than 640 acres in one application; (c) pest management activities that may adversely affect endangered, threatened or protected species or their habitats; and (c) aerial application of pesticides.
3. Specific areas of concern for the reviewer include: (a) identification of environmentally sensitive areas or operations, (b) preparation of pertinent pesticide migration or drift into non-target areas.
4. Pollution Abatement and Occupational Safety Projects. Areas of concern include: (a) Have design and construction of adequate storage facilities been accomplished? (b) Is a disposal system for pesticide rinse water available and used at the installation? and (c) Does the installation have an installation restoration plan?
5. Pesticide Disposal. Excess or unusable pesticides may require disposal as a pesticide-related waste through Resource Conservation and Recovery Act (RCRA) procedures. Specific areas of concern to the reviewer include: (a) Do excess pesticides, excess finished formulations, empty containers and rinse water require disposal? (b) Do local regulations apply to disposal? (c) Has the MACOM PMC been notified to redistribute excess pesticides? and (d) How are leftover pesticides from daily operations handled?
1. Pesticide products are sold in exchange activities, commissaries, and self-service stores. Proper storage and display practices are needed to prevent toxic hazards and accidental contamination of personnel and materials.
2. Areas for review include: (a) Are pesticides segregated to prevent spillage or leakage onto foods or dry goods? (b) Are warning signs used to alert the public of hazards? (c) Are proper displays used to keep pesticides out of the reach of children? (d) Are designated storage areas used to reduce hazards? (e) Do procedures exist to ensure that clean-up materials are available, with personnel knowledgeable in their use? and (f) Are only EPA-registered, general-use pesticides offered for sale?
Installation pest management programs are reviewed on site to update guidance, resolve problems, and assess installation compliance with policies and regulations. This section provides guidance for PMCs who are responsible for reviewing these programs.
A. Pre-Visit. A program review begins before the actual on-site review.
1. Notification
a. Coordinate telephonically with MACOM installation personnel (medical and engineer activities are suggested) to schedule an on-site visit.
b. Issue notification letters approximately 30 days prior to the review. This allows the installation sufficient preparation time.
2. Identification of Priority Topics
a. Coordinate with the cognizant Pest Management Coordinators to determine any specific problem areas to be considered as priority topics during the review.
b. Check previous pest management program review findings. Follow up on priority findings or problems identified in previous reports.
3. Identify time, location and participants for an in-briefing. It is desirable for the installation engineer, health and safety personnel, environmental coordinator, natural resources personnel, morale, welfare and recreational personnel, commissary personnel, and the exchange manager to be included in the briefing. Ensure that this briefing is coordinated with the installation commander.
4. Prior to the on-site visit, review the pest management plan, Integrated Pest Management Information System (IPMIS) data, applicable state and local regulations that affect the program, and other applicable documents and records. If they are not at hand, request copies of these documents from the installation during initial telephonic coordination.
1. Conduct a formal in-briefing with the key personnel identified above.
2. The review should include: A physical visit to the grounds, including shop facilities, applications sites, and interviews with personnel and activities that are involved in the program. Compare actual operations with the pest management plan and review shop records. The reviewer should keep the following questions in mind while conducting the review:
a. How is the pest management program supposed to work? What are the installation's chain of command and the actions taken by the installation to regulate and direct the pest management program? The reviewer's understanding is usually gathered from multiple sources, such as in-briefings and installation orientations. During this step the reviewer will answer questions such as: has the installation prepared a (1) pest management plan, and is it current and properly reviewed, (2) a Spill Prevention Control and Counter-measure Plan (SPCC), an Installation Spill Control Plan (ISCP), and/or a spill standard operating procedure (SOP), are the SPCC and ISCP referenced in the Pest Management Plan, and (3) a fire protection contingency plan?
b. Is the current pest management program adequate? Evaluate the strengths and weakness of pest management procedures and plans. Here the reviewer examines existing written plans and SOPs and looks for indicators such as: (1) clearly defined responsibilities, (2) adequate chain of command and/or responsibility, (3) awareness and capability of personnel, (4) coordination and cooperation between organizations with pest management responsibilities, (5) division of duties, (6) preventive measures, (7) documentation and record keeping, and (8) internal verification processes. This step determines the direction for the remainder of the review.
3. Formulate findings and recommendations.
a. Formulating findings and recommendations is an ongoing process that begins during the in-briefing and continues through preparation of the final report.
b. Always obtain sufficient information to support findings and recommendations. A decision must be made whether to include some or all of the supporting examples in the written report, or to simply mention them in an out-briefing.
c. Put the findings into a broad perspective, such as: (1) What are the implications of the findings? (2) Are there hazards to personnel or the environment? (3) What is the "cost" of not taking action, and (4) Are other activities affected?
4. Conduct a formal out-briefing with key personnel. Findings are reported to installation command personnel during the exit briefing. During this briefing, the reviewer communicates all major findings and observations noted during the review that will appear in the report. The out-briefing should also include a summary of the positive aspects of the pest management program and an agreement as to what items will, or will not, appear in the written report. Remember, the reviewer, whether uniformed or civilian, is there to provide an evaluation and assistance--not simply to conduct an inspection. If possible, the reviewer should avoid any action that looks like putting an installation on report. However, if the PMC finds a problem area, he must provide information to the installation commander for action to be taken.
1. Coordinate recommendations with all affected agencies.
2. Reporting Findings. The reporting process actually begins during informal discussions between the reviewer and installation personnel when discrepancies, or commendable program aspects, are noted. These findings and recommendations should be reported to installation personnel before leaving their installation. The written report is to provide documentation of the review and recommended corrective actions. This report provides the chain of command with timely documentation to determine what, if any, actions are required, and to justify additional resources, if needed. Reports should emphasize the positive aspects of the program. Never address an adverse action or item in the written report that was not covered in the out-briefing.
4. Health and Safety. Have health, safety, and fire officials evaluated their areas of responsibility within the last twelve months, as required by service regulations?
· c. Respiratory Protection Program
· c. Pollution abatement and occupational safety projects
Person/Office/Facility Items of Discussion
Installation Commander In/Out-brief
Civil Engineer or In/Out-brief program overview
Public Works Officer
Hospital Commander, In/Out-brief, program review
Preventive Medicine Officer,
MEDDAC Commander
Installation
Coordinator,
Sanitation Superintendent Courtesy visit
Environmental Officer/Coordinator Review environmental concerns
on the installation that relate to the
use of pesticides
Natural Resources Manager Discuss pest management and its
relationship to the natural resources program, outleasing
Electric Shop, Utilities Utility pole inspections, ground line
Foreman, Buildings and Grounds Chief inspection and treatment
Installation Contracting Office
quality assurance evaluation issues, pesticide usage reporting
Supply Officer Supplies, equipment, issue controls
for pesticides
U-Fix-It Stores, Self-help pest control items,
SHIP Stores distribution and accounting
Roads & Grounds Section, Grounds pest control program
Railroads, Wood Protection
Housing Office
and Self-help pest control efforts
Fire Department Fire safety, hazardous spills,
pre-fire plans
Industrial Hygiene, Environmental Surveillance of medical pests,
Health Office, Health & Safety vector-borne diseases,
Office, Preventive Medicine, industrial hygiene surveys,
Bioenvironmental Engineering respiratory protection,
occupational health program,
and workplace monitoring
Supply Department Procedures for handling pesticides
and equipment procurement
Medical Department Incidence of vector-borne
diseases, pesticides in stock,
physical examinations and
cholinesterase testing
Emergency Room Pesticide antidotes, antivenin,
emergency treatment services for
pesticide poisoning
Airfield Operations, Birds strikes/wildlife hazards,
Aviation Safety weed control
Golf Course Pesticide use, storage and
mixing areas, certification
Commissary Stored product pests,
pesticide sales
Exchange Pesticide sales, storage
Food Handling Areas Sanitation, pest problems
Stables and Kennels Sanitation, fly control
Railroad Tie inspection, materials longevity,
right-of-way vegetation control
Public Health Agencies Disease vectors, pest management
resources
Veterinarian Zoonotic diseases, food inspection,
kennels