Integrated Pest Management Regulation - Summary of Requirements and Explanatory Notes. for. Landscape Pest Managers

Transcription

1 Integrated Pest Management Regulation - Summary of Requirements and Explanatory Notes for Landscape Pest Managers February, 2008 Ministry of Environment Environmental Management Branch Integrated Pest Management Program

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3 Table of Contents 1. INTRODUCTION SUMMARY OF REQUIREMENTS FOR LANDSCAPE PEST MANAGEMENT Pesticide User Licences Training and Pesticide Applicator Certificates Use of Integrated Pest Management Public Notification General Requirements for Protection of People and the Environment Pesticide Transport, Storage and Use Standards for Protection of People and the Environment Reporting and Record Keeping Requirements EXPLANATORY NOTES FOR SELECTED REQUIREMENTS...11 Introduction IPM Requirements Use of Preventative Measures Prior to Pesticide Use Pest Identification Prior to Pesticide Use Monitoring Pest Populations and Their Location Determining the Injury Threshold for Each Pest and Applying it to the Determination of When to Use a Pesticide Selecting Pest Treatment Methods Based on Consideration of Practical Alternatives to Pesticide Use and Protection of Human Health and the Environment Evaluating the Effectiveness of Pesticide Use Public Notification Requirements Notification Requirements for Public Use in Outdoor Public Use Areas Standards for Pesticide Transport, Storage and Use Pesticide Containment, Transport and Storage Equipment Maintenance and Calibration Requirements for Pre-Treatment Inspection of Treatment Areas and Briefing Applicators of Requirements Protecting Bodies of Water During Pesticide Use Protection of Wells, Domestic Water Sources, Irrigation Systems and Agricultural Water Sources Establishing No-treatment Zones to Prevent the Release of Pesticide Spray or Runoff Onto Adjacent Property Unless Property Owner or Manager Agrees Otherwise Precautions to Prevent Unprotected Human Exposure to Pesticide Recording Prevailing Meteorological Conditions During Pesticide Use Broadcast Spraying or Foliar Spraying Outdoors is Restricted to Wind Speeds Less than 8 km/hour Use of Slug Baits...52 APPENDIX 1: List of Additional Resources and References for Landscape Pest Managers...54 i

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5 1. INTRODUCTION This document has been prepared by the Ministry of Environment to assist pest managers to understand requirements under the B.C. Integrated Pest Management Act (IPMA) and Regulation (IPMR) when considering pesticide use for managing landscape pests. The main objectives of the legislation is to prevent harm to human health and the environment and to promote the use of Integrated Pest Management as a means to reduce risk. This document includes a summary list of all the IPMA and IPMR requirements for landscape pest managers, followed by Explanatory Notes for selected requirements. The selected requirements were identified by industry contacts and Ministry staff as requiring guidance to help proponents understand or achieve the requirements. In many cases the selected requirements are new as of the enactment of the Integrated Pest Management Act in January, 2005, replacing the former Pesticide Control Act. The main requirements selected for Explanatory Notes include: Use of Integrated Pest Management, Posting treatment notice signs, Pesticide transport and storage, Preparations (equipment maintenance, site inspections, briefing applicators), and Requirements for human health and environmental protection during pesticide use. The main objectives of this document are to: 1. Provide a summary of requirements for the landscape industry sector for quick reference, 2. Promote the same understanding of the requirements across the landscape industry, interested public and ministry staff, 3. Provide background information and examples that may assist landscape pest managers determine the most appropriate way to meet requirements, and 4. Promote compliance with the requirements. This is not a legal document and the contents should not be relied upon for legal purposes. In all cases the Integrated Pest Management Act and Regulation will prevail. This document includes information on other key regulations, guidelines and best management practices applicable to pesticide use in B.C., but should not be relied upon as a complete source of all such information. 1

6 Summary of Requirements 2. SUMMARY OF REQUIREMENTS FOR LANDSCAPE PEST MANAGEMENT Note: The requirements listed below that have an explanatory note, are identified with an icon and the page number where the explanatory note is located. 2.1 Requirements for Obtaining a Pesticide User Licence A pesticide user licence is required if a person (including an individual, business or corporation) provides a service involving the use of a pesticide, under a contract for services (IPMA s. 1 4 (1)(c)) 2. This requirement for a licence includes services for the management of landscape pests on either public or private land. A pesticide user licence is also required for a use that is not a service, but is a use on public land for the management of: pests of gardens and landscaping, including the management of weeds in sidewalks and on parking lots (IPMR s. 5(1)(i)). This requirement for a licence includes pesticide use by regional districts, municipalities, crown corporations, hospitals, schools and universities for landscape pest management on public land. Effective January 7, 2007, a licence is also required for the use of a pesticide that is not a service but is on private land and is used for: the management of pests in outdoor areas of a multi-residence property containing at least four separate units, to which more than one occupier has access (IPMR s. 5(1)(f)). This requirement for a licence includes pesticide use by the owners or managers of multiresidence buildings for structural or landscape pest management on private land. All licence holders (licensees) are required to ensure compliance with standards for the use of integrated pest management and the protection of human health and the environment, as specified in the Act and Regulation. The Administrator may suspend or revoke a licence for failure to comply with the Act or Regulation (IPMR s. 15(1)). A licence is not transferable without the written authorization of the Administrator (IPMR s. 47 (1) (b)). A licensee must provide the Administrator with written notice of a change in any information provided by the licensee in an application (e.g., classes and amounts of pesticides used, types of use, change in business location or contact information) within 30 days of the change (IPMR s. 47 (1) (c)). 1 s. is used as the abbreviation for Section number in this document 2 Gives the section number of the Integrated Pest Management Act (IPMA) or Regulation (IPMR) which contains the requirement. 2

7 Summary of Requirements If a licensee believes that the Act or Regulation has been contravened (by the licensee themselves, or another person) in a manner involving the release of pesticide into the environment, the licensee must give written notice to the Administrator as soon as possible after forming the belief (IPMR s. 47 (1) (e)). 2.2 Requirements for Individuals to Obtain Training and Hold a Pesticide Applicator Certificate Each pesticide use (that requires a licence) must be performed by, or supervised by, a person who holds a pesticide applicator certificate (certificate holder) endorsed for the appropriate category of pesticide use (IPMA s. 5(1), 5 (2)). A certificate holder must not supervise more than four uncertified individuals and must be no more than 500 m from, and in continuous contact which is either (a) visual or (b) auditory, with each person being supervised (IPMR s. 46 (1) (b) (ii), 46 (2)). Only a certificed applicator can use a Permit-Restricted or Restricted class pesticide. The certificate of each individual using or supervising the use of a pesticide must be at or near the treatment location during the pesticide use (IPMR s. 49 (1) (c)). 2.3 Requirements for Use of Integrated Pest Management (see Explanatory Notes pages 13 to 27) A licensee may use a pesticide only after undertaking all of the following actions in accordance with integrated pest management principles: Identify and implement, or identify and advise the owner or manager of the treatment area, of reasonable measures to prevent pests; Identify pest species and pest complexes to be managed; Monitor to determine the population of pests and their location; Determine the injury threshold for each pest and apply them to the determination of when to use a pesticide; Select pest treatment methods based on: consideration of practical alternatives to pesticide use, and protection of human health and the environment; and Evaluate, following each pesticide use, the effectiveness of that use. 2.4 Public Notification Requirements Notification is required by means of a Treatment Notice when pesticides are used on the property of a school or child care facility, the common areas of multi-residence properties 3 and other outdoor public use areas 4 (IPMR s. 10). 3 A multi-residence property is a parcel of land on which is located two or more separate units occupied as living accommodation, whether the units are in the same building or detached. An outdoor common area of a multi-residence property is an area that is within 5 m of an entrance or window to living accommodations or maintained for purposes of passage, parking or recreation. 4 An outdoor public use area is an outdoor, landscaped area of public land that is maintained for the purposes of public passage or recreation (e.g., playing fields in a municipal park). 3

8 Summary of Requirements Notification Requirements for Pesticide Use on the Property of a School or Child Care Facility At least 72 hours before using a pesticide on the property of a school or child care facility, a licensee must provide a Treatment Notice to the school or facility administrator, principal or manager (or their agent) (IPMR s. 10 (7)). 5 Notification Requirements for Pesticide Use in Outdoor Common Areas of Multi-residence Properties At least 48 hours before using a pesticide in an outdoor multi-residence common area, a licensee must provide a Treatment Notice to the owner or manager of the building (or the agent of either) and either: Provide a Treatment Notice to each person who has access to the common area within 48 hours after the pesticide use (IPMR s. 10 (4) (b) (i)); or Post a Treatment Notice at each gate or opening to fenced outdoor common areas, and at intervals around outdoor common areas that are not fenced (IPMR s. 10 (4) (b) (ii) (B)). 6 7 Notification Requirements for Pesticide Use in Outdoor Public Use Areas Before using a pesticide in an outdoor public use area, a licensee must post a Treatment Notice: At each gate or opening that provides access to treatment areas that are fenced (IPMR s. 10 (6) (a)); or At intervals around or along the treatment area if it is not fenced so that the notice is clearly visible and will provide notice of the pesticide use to any person approaching the treatment area (IPMR s. 10 (6) (b)) (see Explanatory Note page 28). Treatment notices must not be removed by the licensee for 48 hours after the pesticide use (IPMR s. 10 (4) (b)). Written Notice Following Pesticide Use Immediately following a pesticide use that required giving or posting a treatment notice, the licensee must provide written notice to the owner, manager, administrator or principal (or their agent), giving notice that the pesticide use occurred and of any differences between the information given in the treatment notice and the actual pesticide use (IPMR s. 10 (12)). 5 This notice period may be shortened only with the consent of each person who has access to the proposed treatment area and is entitled to notice of the proposed use either in writing or by posted notice. 6 So that the notice is clearly visible and will provide notice of the pesticide use to any person approaching the common area. Treatment notices must not be removed by the licensee for 48 hours after the pesticide use. 7 This notice period may be shortened with the consent of each person who has access to the proposed treatment area and is entitled to notice of the proposed use either in writing or by posted notice. 4

9 Summary of Requirements Summary of the Treatment Notice Requirements for Landscape Pest Management Type or Location of Pesticide Application Give notice 72 hours before treatment Post 48 hours before treatment Post at time of treatment No posting required On the property of a school or child care facility X 8 X 9 Outdoor areas within 5 m of an entrance or window or an area maintained for recreation, public passage or parking on a multi-residence property Outdoor, landscaped area of public land maintained for public passage or recreation Use of only Excluded pesticides Insect baits used in bait stations placed in concealed locations not accessible to children or pets Insecticide applied to an outdoor wasp nest Herbicide used to manage weeds along fences or in cracks in the pavement on roads, sidewalks or parking lots Granular pesticides used in flower, vegetable or shrub beds and mixed into soil X 10 X X X X X X Offices, shopping malls and other work places Follow WorkSafe BC Requirements Information to be Included in a Treatment Notice A Treatment Notice must contain all of the following information (IPMR s. 63 (1)). (see Explanatory Note page 28): A description of the area to be treated; Name of the targeted pest; The federal Pest Control Products Act registration number of the pesticide to be used and its active ingredient; Proposed date and start time, and proposed alternate dates and times of the pesticide use; Name and licence number of the licensee and a phone number at which the licensee or an employee can be reached for more information about the proposed pesticide use; Precautions that should be taken to minimize exposure to a pesticide or its residues, including a statement that indicates the period following the use during which people should not enter the treated area (re-entry period); and If fruit-bearing trees or other food crops are treated, the number of days before food can be harvested safely. 8 Provide notice to the school or facility administrator. 9 A posted notice is required if pesticide is used on the outdoor public use area of these properties. 10 Also provide notice to the building owner or manager. 5

10 Summary of Requirements Characteristics of a Posted Treatment Notice When the regulations require a Treatment Notice to be posted, it must have the following characteristics (IPMR s. 63 (2)): For signs posted in outdoor areas, they must be at least 550 cm 2 in size (a letter size sheet of paper), or for signs posted in indoor areas, they must be at least 200 cm 2 in size (one half a letter size sheet of paper). If the notice may be exposed to water, it must be constructed of water resistant material. Use type or letters that are clearly legible to a person approaching the treatment area. The notice must contain a cautionary symbol (such as a stop sign or raised hand) that will draw the attention of a person approaching the treatment area. The notice must display, in bold block letters, the words NOTICE OF PESTICIDE USE or in place of the word pesticide, the word insecticide, herbicide, or another category of pesticide. Situations When the Notification Requirements May Be Altered The provision and posting of a treatment notice (except to the owner or manager, or their agent, where required) for pesticide use in a multi-residence common area or outdoor public use area is not required if the pesticide is: (IPMR s. 12) an insecticide applied to a wasp nest that is outdoors, or is indoors and no person will have access to the treatment area within the 48 hour period after the use; a herbicide and is used to manage weeds along fences or in cracks in the pavement on roads, in sidewalks or in parking lots; a granular pesticide used in flower, vegetable or shrub beds and mixed into soil; or a bacterial pesticide applied to water. The notice period before use of a pesticide in a multi-residence common area or on the property of a school or a child care facility may be shortened only with the consent of each person who has access to the proposed treatment area and is entitled to notice of the proposed use (either in writing or by posted notice) (IPMR s. 10 (10)). 2.5 General Requirements for Protection of People and the Environment Under the IPM Act there are two general requirements that underpin the legislation (IPMA s. 3): 1. A person must not use, handle, release, transport, store, dispose of, or sell a pesticide in a manner that causes or is likely to cause an unreasonable adverse effect (adverse effect means harm to humans, animals or the environment). Note: When considering how to comply with the more specific requirement of the Act or Regulation, a person must also consider whatever additional steps may be necessary to ensure there will not be an unreasonable adverse effect and to ensure that all pesticide label specifications are followed. 6

11 Summary of Requirements 2. A person must not use a pesticide in a way different than the manner specified on the label of the pesticide container. 2.6 Pesticide Transport, Storage and Use Standards for Protection of People and the Environment Pesticide Transport (see Explanatory Note page 34): Pesticides must be transported in a manner that is sufficient to prevent escape, discharge or unauthorized removal of the pesticide from the transport vehicle; and that prevents contamination of food or drink intended for human or animal consumption, or of household items such as furnishings, clothes, toiletries, or bedding (IPMR s. 33 (2)). Pesticide Containment (see Explanatory Note page 34): A pesticide must be kept, handled, stored or transported in the container in which it was originally packaged and with the label originally affixed by the manufacturer, or in an appropriately designed and labeled container 11 (IPMR s. 65). Pesticide Storage (see Explanatory Note page 34): Pesticides (other than domestic or excluded pesticides) must be stored in a storage facility that is (IPMR s. 66 (1) (b)): Separated from (and not used for storage of) food intended for human or animal consumption; Ventilated so that pesticide vapours are vented outside; Locked when unattended; and Accessible only to persons authorized by the person storing the pesticide. Each door providing access to a pesticide storage facility must have a sign that is clearly visible to a person approaching, with the words WARNING: CHEMICAL STORAGE AUTHORIZED PERSONS ONLY written in block letters. Fumigants and other pesticides that release vapours and bear a poison symbol on the label must be stored in a facility that is not attached to or within a building used for living accommodations. Within 60 days after starting to store pesticides at a location, a pesticide licensee must provide notice of the storage location to the fire department responsible for fire protection at that location. 11 One designed for the containment of the pesticide, with a label that displays the pesticide s trade name, the name and concentration of the pesticide s active ingredient and the pesticide s registration number under the federal Act. This requirement does not apply to tanks being used for mixing pesticides, or for holding pesticides during use. 7

12 Summary of Requirements Preparing for Pesticide Use (see Explanatory Note pages 38 to 41) A licensee must ensure that (IPMR s. 71 (1)): Each individual who will be using a pesticide (for which the licence is required) is informed of: The boundaries of the proposed treatment area, The requirements for personal protection, and The pesticide use procedures required to protect human health and the environment; The application equipment is in good working order and, if required, is calibrated to conform to the application rates on the pesticide label; and An inspection of the treatment area is carried out to ensure that the applicable regulatory requirements and standards can be met in carrying out the use. Protecting People and the Environment A licensee must ensure that the following precautions are taken in carrying out pesticide use (IPMR s. 71 (2)): Precautions to prevent unprotected human exposure to pesticide (see Explanatory Note page 47); Precautions to ensure that domestic water sources, agricultural water sources and soil used for agricultural crop production are protected for their intended use (see Explanatory Notes page 43); and Avoiding the use of pesticide over vertebrate wildlife or domestic animals that are visible to the user. 12 A licensee must not: Engage in broadcast spraying or foliar spraying outdoors if the wind speed exceeds 8 km an hour (see Explanatory Note page 50) (IPMR s. 71 (7)); Use a residual pesticide on water-saturated soil, during heavy rainfall or if heavy rainfall is imminent (IPMR s. 71 (9) (a)); Spray a pesticide on foliage covered by ice or frost or if water is flowing on the foliage (IPMR s. 71 (9) (b)); or Spray a pesticide between 30 minutes after sunset and 30 minutes before sunrise unless a lighting device is used so that the person applying the pesticide and the pesticide use are clearly visible from a distance of at least 30 m. (IPMR s. 71 (8)). 13 A container used to prepare, mix or apply a pesticide must not be washed or submerged in a body of water. Pesticides must be prevented from entering any body of water or irrigation system 12 This provision does not apply if the pesticide is a bacterial pesticide (e.g., Btk). 13 This is the amended requirement as of October,

13 Summary of Requirements used to draw water from for the containment, preparation, mixing or application of a pesticide 14 (IPMR s. 70). A licensee must ensure that their use of an herbicide does not remove vegetation that is necessary to (IPMR s. 71 (10)): Prevent erosion of a streambank; Prevent debris that would cause an unreasonable adverse effect from entering a stream; or Maintain slope stability in areas where landslides have occurred. If using a slug bait pesticide that may be harmful to children or domestic animals, a licensee must place the pesticide in bait stations that are resistant to tampering by children and animals, or in areas that are inaccessible to children and domestic animals (IPMR s. 71 (11)) (see Explanatory Note page 52). No-treatment Zones A 30 m no-treatment zone must be maintained around a water supply intake or well used for domestic or agricultural purposes (including water used for livestock or irrigation of crops) unless the licensee is reasonably satisfied that a smaller no-treatment zone is sufficient to ensure that pesticide from the use will not enter the intake or well 15 (IPMR s. 71 (3), (4)) (see Explanatory Note page 43). The licensee must ensure that a no-treatment zone between an outdoor pesticide use area and a body of water is sufficient to prevent the release of pesticide spray or runoff into the body of water (IPMR s. 71 (5)) (see Explanatory Note page 41). The licensee must ensure that a no-treatment zone between an outdoor pesticide use area and an adjacent property is sufficient to prevent the release of pesticide spray or runoff onto the adjacent property (unless the adjacent property owner or manager agrees otherwise) (IPMR s. 71 (6)) (see Explanatory Notes page 45). 2.7 Reporting and Record Keeping Requirements If a licensee has not given prior notice to the Administrator through his or her licence application about the following pesticide uses, he or she must give written notice to the Administrator at least two business days before the first intended use of a pesticide on public land (IPMR s. 40). Within 60 days after starting to store pesticides at a location, a pesticide licensee must provide notice of the storage location to the fire department responsible for fire protection at that location (IPMR s. 31). Licensees are required to maintain a record of pesticide use for each treatment location or day of use that includes (IPMR s. 35): 14 By maintaining a gap between the pesticide and the equipment used to draw water. 15 A record must be kept of the information on which the decision was based for a smaller no-treatment zone that still ensures no pesticide enters the intake or well. 9

14 Summary of Requirements If the use was performed as a service, the name and address of the person for whom the service was performed; If the service was performed for another licensee (or permit holder or Pesticide Management Plan [PMP] confirmation holder), the number of the person s licence (or permit or confirmation); If the use was not performed as a service, the name and address of the owner or manager of the treatment location; The name and certificate number of the certified applicator who used or supervised the use of the pesticide; The date and time of the pesticide use; The name of the pest targeted by, or the purpose of, the pesticide use; The trade name of each pesticide used and its registration number under the federal Act; For each pesticide used, the method and rate of application and total quantity used; If the use was outdoors, the prevailing meteorological conditions, including temperature, precipitation and velocity and direction of the wind (see Explanatory Note page 49); Pest monitoring methods and injury thresholds used to fulfill the licensee s IPM requirements in relation to the use; Advice given to the owner or manager of the treatment area, including safe re-entry time, the number of days before a crop can be harvested safely (where applicable), and any additional precautions that should be taken to minimize exposure to the pesticide; and If the licensee decided that a no-treatment zone around a water supply intake or well used for domestic or agricultural purposes may be reduced, the information on which the licensee based the decision. (see Explanatory Notes page 43) Records must be kept up to date, at the business location identified on the licence application (except as required during pesticide use) and for a period of three years after the use or application to which they relate. A licensee may keep records relating to a pesticide use at or near the treatment location during the use, provided that he or she ensures that these records are at the business location within 60 days after the completion of the pesticide treatment to which they relate (IPMR s. 83). Annual Report to the Administrator A licensee must submit an annual report of pesticide use to the Administrator by January 31 of every year (for the previous calendar year s use). The annual report must include (IPMR s. 39 (1) (2)): The name and address of the licensee and their licence number; For each pesticide used in the calendar year, the trade name, registration number under the federal Act, active ingredient and amount in kilograms; and The total area treated. The annual report of a licensee must also provide a separate record of the use of pesticides for another licensee or a permit or confirmation holder. 10

15 Explanatory Notes IPM Requirements 3. EXPLANATORY NOTES FOR SELECTED REQUIREMENTS Introduction Each explanatory note has the following format: 1. Relevant Regulation Section(s): a copy of the specific sections of the regulation that are relevant to the issue. 2. Reason for the Regulatory Requirement: what the Ministry expects will be achieved for the protection of human health and the environment and to promote use of integrated pest management. 3. Background Information: information that may be necessary to consider in determining how best to comply with the requirement 4. Some Ways for a Licensee to Address this Requirement: steps that a licensee should consider to comply with the requirement. 5. Additional Information: may include more extensive examples of treatment methods or record keeping forms or lists of references. 11

16 Explanatory Notes IPM Requirements 3.1 IPM Requirements The explanatory notes in this section provide guidance for achieving compliance with the requirements to use integrated pest management as specified in Section 68 of the IPM Regulations. Integrated Pest Management is defined (Section 1 of the Act) as a process for managing pest populations that includes the following six elements: a) planning and managing ecosystems to prevent organisms from becoming pests; b) identifying pest problems and potential pest problems; c) monitoring populations of pests and beneficial organisms, damage caused by pests and environmental conditions; d) using injury thresholds in making treatment decisions; e) suppressing pest populations to acceptable levels using strategies based on considerations of: i. biological, physical, cultural, mechanical, behavioral and chemical controls in appropriate combinations, and ii. environmental and human health protection; and f) evaluating the effectiveness of pest management treatments. While each of these elements is treated separately as a regulatory requirement, they are not mutually exclusive. All of them must be practiced together to develop an effective IPM program. IPM programs are knowledge-based with a heavy emphasis on collecting information and assessing it prior to making management decisions. The Ministry recognizes that IPM programs will likely change and improve as people gain experience and as new products, tools and information become available. It is expected that for some pests and locations, pest managers will start with a simple IPM approach and move to a more detailed approach as more information is obtained. The initial approach may involve a quick assessment of the site and pest and an evaluation of treatment alternatives. This may lead to a more detailed site assessment, the testing and implementation of an ongoing monitoring program and further review of the pest biology and treatment options. A more advanced program for a site may include implementation of pest prevention, division of a site into areas that require different levels of maintenance, refinement of monitoring and injury thresholds in relation to the maintenance levels and testing and incorporation of a greater range of treatment methods. 12

17 Explanatory Notes IPM Requirements Use of Preventative Measures Prior to Pesticide Use Relevant Regulation Sections: 68(1) Except as provided in section 7(1) [licence requirement exemptions], a licensee may use a pesticide only after doing all of the following in accordance with integrated pest management principles: (a) identify and implement, or identify and advise the owner or manager of the treatment area of reasonable measures to prevent pests. Reason for this Regulatory Requirement: When pest problems are prevented, pesticides are not needed. Minimizing pesticide use is a desirable precautionary approach to prevent harm to the environment and human health. Prior to pesticide use on a particular pest problem, prevention methods are to be evaluated and implemented when reasonable, or in the case of a service, the client is to be advised of any reasonable prevention methods and how these should be implemented to maintain pest problems at tolerable levels Background Information: Growing healthy plants to prevent pest problems is the key to successful IPM in landscapes. This means choosing the right plants when landscape areas are being designed and maintained and giving them the best growing conditions. Longer-term corrective management, for example, would consider replacing problem plants, rebuilding turf areas and redesigning landscape areas. Pest prevention can also includes proper disposal of waste (e.g., cuttings) and cleaning of equipment before transport to new sites to prevent spread of pests. A landscape pest management service company has an obligation to identify and implement or identify and advise the customer of preventative measures for both residential and commercial properties. Implementing preventative measures should be the goal for on-going accounts (with the understanding and cooperation of the customer/client). Even for a single pesticide treatment for a customer, there must be a reasonable effort to determine whether there are preventative measures that could apply to a customer s problem. For common pest problems, it is expected that the pest manager will have researched pest prevention in advance and communicated this information to a customer verbally or by written handouts. The landscape pest manager employed by an agency or organization such as a local government, parks board or school board should be implementing long-term management programs that incorporate pest prevention measures. They should also be involved with builders and landscape architects to choose appropriate plants that are more pest tolerant. 13

18 Explanatory Notes IPM Requirements Examples of Preventative Measures: There is considerable information about pest management in the Ministry of Environment publication Integrated Pest Management Manual for Landscape Pests in British Columbia, available from the following web site: The information in this publication includes specific preventative measures for weeds, insects, plant diseases and mites in landscaped areas such as lawns and turf, flower beds, shrub beds, borders, hedges, fence lines, around buildings, sidewalks and parking lots. Examples of preventative measures for landscape pests include the following: Weeds Installing a paved or mulched mow strip under fence lines or around buildings to block weed growth and eliminate the need to use herbicides or trimmers; Filling cracks in asphalt or concrete sidewalks or surfaces with a sealant to remove weed germination sites; Using weed-free nursery stock and bedding plants to prevent the importation of weed seeds; Applying organic mulches or landscape fabrics to prevent weeds from emerging or becoming established; Planting suitable and aggressive ground covers and massed plantings that rapidly cover the soil surface and reduce the space, nutrients and light available for weeds; When designing and planting turf areas or when renovating or repairing damaged areas, plan for long-term weed management by ensuring that there is correct drainage, soil preparation and choice of turf grass cultivars; Selecting turf grass cultivars suited to local conditions and intended use; Using correct mowing practices by keeping the mower height between 5 and 7 cm. This gives the grass more leaf area, so it can grow more vigorously, with deeper roots that are better able to compete with weeds. The dense turf also shades the soil and prevents weed seeds from germinating; Using mulching mowers and leave the grass cuttings on the turf to provide nutrients; and Promptly repairing worn or damaged areas of turf. Insects, Mites and Plant Diseases Using optimum site design with proper soil preparation, fertility and ph for the intended plants; Using proper horticultural and arboricultural practices, including good pruning and planting techniques, proper water management and drainage; Purchasing healthy, disease-resistant plantings; Avoiding monocultures by using a diversity of species and families of trees and shrubs; Removing and proper disposal of dead, infested and fallen twigs, leaves and fruit; Avoiding the use of fast-acting, high nitrogen fertilizers that promote succulent, susceptible plants; and Protecting trees and shrubs from injury by mowers, string trimmers, vehicles and equipment by using barriers, trunk protectors or temporary fences. 14

19 Explanatory Notes IPM Requirements Use good sanitation practices including disposal of waste cuttings and cleaning of equipment between jobs, as necessary, to reduce spread of weeds and diseases. Some Ways for a Licensee to Address this Requirement: Maintain information sources such as books and web sites and a list of qualified professionals / consultants who can be contacted for information / advice on preventative measures for landscape pests; For each pest, compile a list of possible prevention methods and the conditions under which they may be appropriate; Develop handouts, pest notes, etc., to communicate pest prevention methods to clients; Keep a record of the prevention advice that was provided to the customer / clients / employees or was implemented. This could be recorded on the client invoice or as notes appended to Pesticide Use Records; and Train staff to recognize and communicate practical preventative measures that can be implemented on a site. Additional Sources of Information: Further information may be obtained from the following numbered references, found at the end of the Explanatory Notes for this sector in Appendix 1: (7), (8), (9), (10), (11), (12), (22), (23), (24), (25), (26), (27), (30) Pest Identification Prior to Pesticide Use Relevant Regulation Section(s): 68 (1)(b) Except as provided in section 7(1) [licence requirement exemptions], a licensee may use a pesticide only after doing all of the following in accordance with integrated pest management principles: identify pest species and pest complexes to be managed. 35(1) A licensee who uses a pesticide, other than a wood preservative, must keep a record containing the following information for each treatment location and day of use: (f) the name of the pest targeted by the use or purpose of the pesticide use. Reason for this Regulatory Requirement: Pests must be accurately identified so that the most effective pest management measures can be designed to take advantage of research on the biology of the identified pest or pest complex. Operational pesticide use records are to include the identification of targeted pests, to allow a person to confirm the pesticide product label directions allow use for that pest. 15

20 Explanatory Notes IPM Requirements Background Information: In many cases pest identification must be made to the species level either by identifying a particular life cycle or through characteristics of the damage that is occurring. Correct identification is essential because monitoring, injury thresholds and treatment methods may be specific to a particular species. Some insect and disease problems cause very similar damage that can be mistaken for disorders caused by poor growing conditions (i.e., nutrient deficiency, high ph, or salt damage). Once a pest has been identified, information about its life cycle can be used to determine when and where treatments will have the greatest effect, what preventative measures would be most effective and what damage may be expressed if treatments are delayed or not conducted and which products and/or alternatives are effective in reducing numbers. Some pests, particularly diseases, have similar symptoms and positive identification can only be made by a plant pathologist. Resources to assist in identifications can be found at local offices of the Ministry of Agriculture and Lands, Ministry of Forests and Range, Universities and Colleges, Agriculture and Agri-Foods Canada Research Centres, Canadian Food Inspection Agency, garden centres, botanical gardens and private pest management consultants. Species can be sent to the provincial Plant Diagnostic Laboratory, B.C. Agriculture, 1767 Angus Campbell Rd., Abbotsford, BC V3C 2M3, Phone Some Ways for a Licensee to Address this Requirement: Implement a policy that no pesticides may be used before the pest problem is accurately identified; Ensure that your pesticide use records include the name of the identified pest(s); Have available appropriate reference materials, and preserved specimens that can be used for comparison, or other information sources for identifying pests (e.g., local experts); Train applicators in pest identification to be knowledgeable of the pests commonly found at proposed treatment locations and at specific times during the growing season; and Hire trained horticulturists who have taken courses in pest management from an approved training institute (see reference [30] for B.C. University College Horticulture Programs in Appendix 1). Additional Sources of Information: Further Information may be obtained from the following numbered references found at the end of the Explanatory Notes for this sector in Appendix 1: (7), (8), (9), (10), (11), (12) (13), (19), (21), (30). 16

21 Explanatory Notes IPM Requirements Monitoring Pest Populations and Their Location Relevant Regulation Section(s): 68 (1)(c) Except as provided in section 7(1) [licence requirement exemptions], a licensee may use a pesticide only after doing all of the following in accordance with integrated pest management principles: monitor to determine the population of pests and their location. 35 (1)(j) A licensee who uses a pesticide, other than a wood preservative, must keep a record that includes the following information for each treatment location and day of use: pest monitoring methods and injury thresholds used to fulfill the licensee s integrated pest management requirements in relation to the use. Reason for this Regulatory Requirement: Observations to identify where pests are located and their abundance, are required to determine if injury thresholds have or will be exceeded and to ensure that if a pesticide is used, it is only applied in areas requiring treatment. A record of monitoring methods is to be kept to confirm that monitoring was adequate to achieve these objectives. Background Information: Monitoring as an element of IPM is defined in the IPMA as monitoring populations of pests and beneficial organisms, damage caused by pests and environmental conditions. In landscape pest management, monitoring is used to: Detect pest populations while pest numbers are still low; Assess the size and spread of a pest population and to predict future damage levels; Determine the numbers of natural enemies present and the effect they are having on the pest population; Determine conditions that contribute to the pest problem, e.g., poor pruning can reduce air flow that may result in increased mildew; Compare pest and/or damage levels with previous monitoring results to see if pest numbers are increasing or decreasing; and Record temperatures and rainfall to determine disease infection periods. Visual inspections in the field are commonly used for landscape pests because specific monitoring (sampling) methods have not been developed for the large variety of plants and pests possible in landscapes. Visual inspections should be conducted on a representative number of plants, at regular intervals. The pest population and/or damage is estimated and recorded (e.g., percent of area infested with dandelions observed to be 10%). These visual inspections can be refined for better accuracy by using specific sampling methods that involve counting to give quantitative measures. Visual inspections and counts can be used to compare data from week to week, year to year, as long as the same methods are used. Examples of monitoring include: 17

22 Explanatory Notes IPM Requirements Counting numbers of insects per leaf on 20 leaves from 10 plants picked at random from a group of 50 plants; Assessing percent infestation of weeds in small plots, e.g plots per hectare of turf to obtain average for turf area; Number of insects caught on 10 sticky traps per area; Spots of honeydew on sampling cards placed under trees that correlates with aphid abundance on trees; Counting number of insects dropping onto beating tray when 10 taps of branches used per unit area; Counting number of lesions per leaf on 100 leaves per tree on 5 to 10 trees in an area; and Correlating level of pest injury that triggers a complaint (e.g. frass from feeding caterpillars falling on cars). Monitoring should be conducted even when service is provided to a customer who requests a single treatment; a single visual inspection may suffice (e.g., an estimate of the number of larvae and/or damaged buds per branch). For on-going property maintenance, monitoring should be more precise, comprehensive and timely to determine whether the pest population / damage is increasing or decreasing. The type(s) of monitoring methods used will depend on the pest (i.e. insect, mite, disease, weed), pest location (in soil, tree top), host (turf, shrub, tree, nursery), accuracy needed and the costs of each method in terms of time to complete and equipment required to undertake method. Examples of monitoring forms are provided at the end of this note and have been adopted from those used by Dr. Michelle Gorman, IPM Coordinator, City of Victoria, Engineering and Parks Department, and are contained in the B.C. Ministry publication Integrated Pest Management Manual for Landscape Pests in British Columbia. There are a number of landscape industry computer programs used for scheduling routes that may be adapted to a monitoring record system. Some Ways for a Licensee to Address this Requirement: Collect information on monitoring / sampling methods from pest management publications, local IPM practitioners, IPM experts and consultants and other jurisdictions with similar weather, pests and landscape plantings; Assess the usefulness of these methods for determining pest levels and their location for pests your company/agency manages; Develop a record keeping system for pest monitoring methods utilized and results at each maintenance site; retain these records so they can be used for continuity with staff and clients; and Establish goals for continuous improvement of monitoring with objectives for staff training. Additional Sources of Information: Further information may be obtained from the following numbered references, found at the end of the Explanatory Notes for this sector in Appendix 1: (7), (8), (9), (10), (11), (12), (13). 18

23 Explanatory Notes IPM Requirements Pest Monitoring Form Date of Monitoring Name of Monitor Location of Pest Problem (address) Initial Monitoring Follow-Up Monitoring 2 nd Follow-Up Monitoring Pest Type: Insect Mite Animal Fungi Bacteria Physiological Pest Name and Life Stage Found Pest Estimate: 1. Very few pests Density 2. Pests found in moderate numbers 3. Pests found in high numbers 4. Pests found in very large numbers Infestation: 1. Evenly distributed over entire plant 2. Mainly on the newer growth 3. Mainly on the older growth 4. Trunk, stems or branches 5. Roots Plant Damage: 1. None 2. Minimal 3. Noticeable damage 4. Damage affecting growth 5. Causing plant death Description of the Damage/Infestation Percentage of Plants Damaged/Infested Predators/Parasites Present Host Plant Type: Herbaceous Shrub Tree Deciduous Evergreen Turf Grass Host Plant Common Name Genus/Species/Cultivar (if known) Growth Stage Comments 19

24 Explanatory Notes IPM Requirements Weed Monitoring Form Date of Monitoring Name of Monitor Location of Weed Problem (address) Initial Monitoring Follow-Up Monitoring 2 nd Follow-Up Monitoring Weed Species or Type * % Weed Cover/Species % Total Weed Cover Test Area # * * Each test area at a location will generally be the same unit area (e.g., 5 m X 5 m) Percentage of Weeds with Flowers or Seed Heads Fertilizer Dates and Types Used Seed or Turf Type Frequency of Watering and Irrigation Type Current Height of Grass or Turf Frequency of Mowing Thatch Accumulation Previous Treatment History Comments 20

25 Explanatory Notes IPM Requirements Determining the Injury Threshold for Each Pest and Applying it to the Determination of When to Use a Pesticide Relevant Regulation Section(s): 68 (1)(d) Except as provided in section 7(1) [licence requirement exemptions], a licensee may use a pesticide only after doing all of the following in accordance with integrated pest management principles: determine the injury threshold for each pest and apply them to the determination of when to use a pesticide. 35(1)(j) A licensee who uses a pesticide, other than a wood preservative, must keep a record that includes the following information for each treatment location and day of use: pest monitoring methods and injury thresholds used to fulfill the licensee s integrated pest management requirements in relation to the use. Definition (Section 1): injury threshold means the point at which the abundance of pests and the damage they are causing or are likely to cause indicates that pest control is necessary or desirable. Reason for this Regulatory Requirement: Injury thresholds are to be determined and used to ensure that a pesticide will only be used if pest numbers have or will exceed the injury threshold and will cause unacceptable damage or impact. A record is to be kept to confirm that an injury threshold was determined. Background Information: The regulatory requirement means that a pest manager will have to determine the amount of damage that is unacceptable for a given site. Damage includes reduced economic values, reduced aesthetic values or increased nuisance from pests. For service companies this will generally mean discussing and obtaining agreement with the property owner / manager on the amount of pest damage that can be tolerated so that an injury threshold can be determined. Compared to commercial agriculture, injury thresholds have not been well developed for many landscape pests. Consequently, it may be necessary to set preliminary thresholds and then refine these as further data and experience is gained. In IPM programs, deciding when to take action requires monitoring to determine when the injury threshold has been reached. Treatments are not made according to a predetermined schedule (i.e. calendar spraying). Treatments are only made when and where monitoring shows they are needed. The injury threshold depends on the pest and where it is. In landscape pest control, the injury threshold is influenced by such factors as: The location of the plant in the landscaped area; The perceptions and tolerances of the customer or people who use the landscaped site; 21