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 GENERAL MANUAL: TITLE 190 - ECOLOGICAL SCIENCES : PART 404 –PEST 

MANAGEMENT 

 

Part 404 –Pest Management 

 

Subpart A - General 

404.0 Purpose. 

This directive sets forth Natural Resources Conservation Service (NRCS) policy for pest management. This 

pest management policy applies to all pests. 

404.1 Background.

(a) A memorandum of understanding between the Cooperative State Research, Education and Extension 

Service (CSREES) (formerly the Cooperative Extension Service) and NRCS (formerly the Soil 

Conservation Service), dated June 3, 1988, (Title 460, General Manual (GM) Part 401, Water Quality 

Policy) outlined various roles and responsibilities for CSREES and NRCS. (See Section 404.20 of this Part 

for details.) Extension refers to the local component of CSREES. 

(b) Pest management policy is applied through the conservation planning process. 

404.2 Authorities.

The following laws and initiatives require U. S. Department of Agriculture (USDA) component agencies to 

reduce both the use and the risks of pesticides, and to promote sustainable agriculture that reduces 

contamination of the Nation's natural resources: 

(a) Food, Agriculture and Energy Act of 2008; 

(b) Executive Order 13112 of February 3, 1999, Invasive Species; 

(c) Inter-Departmental Clean Water Action Plan, February 14, 1998 (i.e., signed by USDA and the 

Environmental Protection Agency (EPA); 

(d) Safe Drinking Water Act of 1996, as amended; 

(e) Food Quality Protection Act of 1996; 

(f) EPA's Pesticide Environmental Stewardship Program of 1994; 

(g) USDA's 1993 Integrated Pest Management (IPM) Initiative; 

(h) Cooperative Forestry Assistance Act of 1978, as amended; 

(i) Section 404.4 of the Secretary's Memorandum No. 1929, dated December 12, 1977, which provides the 

Department's policy statement on management of pest problems; 

(j) Endangered Species Act of 1973, as amended; 

(k) Clean Water Act of 1972, as amended; and 

(l) National Environmental Policy Act of 1969, as amended. 

404.3 Definitions.

(a) Avoidance – one of the IPM’s four strategies Prevention, Avoidance, Monitoring, and Suppression 

(PAMS) use to avoid pest impacts (e.g., using pest-resistant varieties, crop rotation, rotational grazing trap 

crops, delaying planting, etc.). Avoidance is the "A" in the approach to IPM. 

(b) Biological Pest Suppression - The process of conserving, augmenting, managing, or introducing 

beneficial living organisms to reduce a pest population or its impacts. It includes the use of insects, 
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nematodes, mites, plant pathogens, plants, vertebrates (including herbivores), and other living organisms. 

Biological pest suppression is usually an activity in the PAMS approach to IPM. 

(c) Biological Pest Suppression Recommendation – A specific written or spoken instruction that includes 

specifics on approved suppression agents, methods of release, and management. 

(d) Chemical Pest Suppression - The use of pesticides such as herbicides, insecticides, or fungicides to 

reduce a pest population or its impacts. Chemical pest suppression is an activity in the PAMS approach to 

IPM. 

(e) Chemical Pest Suppression Recommendation – A specific written or spoken instruction that includes 

pesticide formulation, application rate, timing, and method of application. 

(f) Cultural Pest Suppression - The use of practices other than chemical or biological suppressions to 

reduce a pest population or its impacts. It includes practices and techniques such as narrow row spacing or 

optimized in-row populations, alternative tillage approaches such as no-till or strip-till, cover crops or 

mulches, or using crops with allelopathic potential. 

(g) Environmental Risk - The potential to negatively impact ecosystem values and functions. 

(h) Invasive Species - A species that is: 1) non-native (or alien) to the ecosystem under consideration; and 

2) whose introduction causes or is likely to cause economic or environmental harm or harm to human 

health (Executive Order 13112). 

(i) IPM - IPM is a sustainable approach to manage pests that combines the use of PAMS strategies to 

maintain pest populations below economically damaging levels, to minimize pest resistance, and to 

minimize harmful effects of pest suppression on human health and environmental resources. IPM 

suppression systems may include biological suppression, cultural suppression, and/or the judicious use of 

chemical suppression. 

 (j) Mechanical Pest Suppression - A form of pest suppression that utilizes physical methods to reduce a 

pest population or its impacts. Mechanical suppressions include cultivation, hoeing, hand weeding, 

mowing, pruning, root plowing, roller chopping, vacuuming, etc. Mechanical pest suppression is an 

activity in the PAMS approach to IPM. 

(k) Mitigation – The process of minimizing the potential for harmful impacts of pest management activities 

on soil, water, air, plant, and animal resources and humans through the application of conservation 

practices (e.g., Filter Strip, Conservation Crop Rotation, Residue Management, Irrigation Water 

Management, etc.) and/or management techniques (e.g., early harvest, delayed planning, resistant varieties, 

transgenic crops, and the of pheromones, etc.). 

(l) Monitoring – Proper Identification of pests and the extent of pest populations and/or the probability of 

future populations (e.g., pest scouting, soil testing, weather forecasting, etc.). Records are kept of pest 

incidence and distribution for each field or site which provides the basis for crop rotation selection, 

economic threshold, and suppressive actions. Monitoring is also conducted after suppression actions to 

determine the effectiveness of the treatment. Monitoring is the "M" in the PAMS approach to IPM. 

(m) National Agriculture Pesticide Risk Analysis (NAPRA) - A detailed pesticide environmental risk 

analysis tool that quantitatively evaluates the potential for pesticides to be transported by water and 

adversely affect non-target organisms. Results include the probabilities of pesticide leaching below the 

root zone and runoff beyond the edge of the field to exceed toxicity thresholds for humans, fish, 

crustaceans, and algae based on local crop management techniques, weather, and soil conditions. NAPRA 
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can be used to refine Windows Pesticide Screening Tool (WIN-PST) results and evaluate mitigation 

techniques. 

(n) Organic crop – An agricultural commodity that is organically produced consistent with Section 2103 of 

the Organic Foods Production Act of 1990 (7 U.S.C. 6052). 

(o) Pest - A plant, animal, or other organism (including invasive and non-invasive species) that directly or 

indirectly causes damage or annoyance by destroying or devaluing food and fiber products, causes 

structural damage, or creates a poor environment for other organisms. 

(p) Pest Suppression Reference – Written recommendations by the Extension Service, Agricultural 

Research Service (ARS) and other reputable sources that publish peer-reviewed documents which include, 

but are not limited to, bulletins, IPM guides, manuals, crop protection guides, brochures, fact sheets, 

computer software, and Web-based materials. 

(q) Pesticide - A substance or mixture of substances intended for preventing, destroying, repelling, or 

mitigating pests; or a substance or mixture of substances intended for use as a plant growth regulator, 

defoliant, or desiccant. Pesticide applications are suppression activities in the PAMS approach to IPM. 

(r) Pest Management – For the intent and purpose of this Agency, is the evaluation of environmental risks 

associated with a client’s probable pest suppression strategies and the assistance to clients to mitigate the 

identified environmental risks. Pest management may also include assistance to clients to suppress weeds 

(on non-cropland) to ensure successful implementation and/or maintenance of conservation practices. 

(s) Pest Management Environmental Hazard Analysis – An evaluation of the potential for a client’s pest 

management activities to have a negative impact on the offsite and on-site ecosystem. This is usually 

accomplished with WIN-PST, NARA, erosion prediction models, and other tools as needed to evaluate 

impacts to air quality, and animal and plant resources. 

(t) Prevention - The practice of keeping a pest population from infesting a field or site. Preventative 

techniques include, but are not limited to, using pest-free seeds and transplants, cleaning tillage harvesting 

and other equipment between fields and/or farms, feeding weed free roughage to livestock, applying 

management techniques that maintain or improve plant community resilience and resistance to pests, 

scheduling irrigation to avoid situations conducive to disease development, and eliminating alternate hosts 

or sites for insect pests or disease organism, etc. Prevention is the “P” in the PAMS approach to IPM. 

(u) Specialty Crop –Fruits and vegetables, tree nuts, dried fruits, and nursery crops (including floriculture), 

as per Specialty Crop Competitiveness Act of 2004, Public Law 108-465-December 21, 2004. 

(v) Suppression - Suppressing a pest population or its impacts using cultural, biological, or chemical pest 

suppression. Suppression is the "S" in the PAMS approach to IPM. 

(w) WIN-PST - A basic screening tool for pesticide environmental hazard analysis, designed for use by 

NRCS field office staff, crop consultants, certified crop advisors, and other partners. WIN-PST 

qualitatively evaluates the potential for pesticides to be transported by water from the area of application 

and adversely affect some non-target organisms. WIN-PST considers the influence of climate, irrigation, 

residue management, and pesticide application method and rate class on the potential for pesticide leaching 

below the root zone and runoff beyond the edge of the field. It also incorporates long-term pesticide 

toxicity to humans and aquatic life in its overall risk ratings. WIN-PST provides environmental hazard 

information that a planner can use to formulate appropriate mitigation techniques that meet water quality 

criteria in Section III of the Field Office Technical Guide (FOTG). 
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Subpart B - Policy

404.10 Pest Management and Technical Assistance.

(a) Guidance and requirements in this Subpart are applicable to all NRCS technical assistance that involves 

pest management. All NRCS employees will follow these requirements when providing such technical 

assistance. Third Party Vendors/Technical Service Providers and other non-NRCS employees will use 

these pest management requirements when assisting clients with conservation activities for which NRCS 

has technical responsibility. 

(b) NRCS roles in pest management are to: 

(1) Evaluate environmental risk associated with a client’s probable pest suppression strategies; 

(2) Provide technical assistance to clients to mitigate the identified environmental risk of pest 

suppression strategies through mitigation practices and activities; 

(3) Assist clients to adopt IPM techniques that protect natural resources; and 

(4) Assist clients to: (a) inventory, assess, and suppress noxious and invasive weeds on noncropland, and (b) may provide assistance to clients to suppress weeds to ensure successful 

implementation and/or maintenance of permanent vegetative conservation practices (e.g., buffer 

type practices). 

(c) Technical Assistance 

(1) NRCS pest management assistance applies to all land uses, all crops including organic and 

specialty crops, and all pests including invasive species. 

(2) NRCS shall not develop chemical pest suppression recommendations or change pesticide label 

instructions for clients. NRCS personnel who are “professionally certified” and/or licensed for 

pesticide application may make available a site-specific rate within the pesticide’s label range 

when adequate reference source(s) are available to justify a specific rate. “Professionally 

certified” refers to meeting the requirements for local and State agency certification related to 

pesticide and/or licensed refers to meeting the requirements for local and State agency certification 

related to pesticide and/or pest management, and criteria established by the State Conservationist 

(STC) that demonstrates an understanding of the pest and pest control alternatives through 

programs such as the Certified Crop Adviser and the Certified Range Management Consultant 

certification programs. NRCS shall not develop biological pest suppression recommendations 

except for biological weed suppression utilizing grazing animals. NRCS may provide clients with 

the most current biological and chemical pest suppression references. Pest suppression references 

will be based on reputable scientific research that is peer reviewed from universities, Extension 

Service, ARS, Animal and Plant Health Inspection Service (APHIS) and non-profit nongovernment organizations such as biological and agricultural research centers, stations, and 

foundations. The recommendations in these references must be in accordance with all Federal, 

State, Tribal, local laws, and regulations. 

(3) NRCS may assist clients to develop appropriate cultural and mechanical methods of pest 

suppression based on established NRCS conservation practice standards. 

(4) NRCS shall evaluate the environmental risks of cultural, biological, and chemical pest 

management suppression techniques selected by the clients. NRCS will provide assistance to 

clients to develop appropriate mitigation for all identified significant risks associated with pest 

suppression. 

(5) When chemical methods of pest suppression are chosen by the client that pose a significant 

risk to an identified natural resource, NRCS shall assist clients to adopt and implement a 

conservation system that addresses the appropriate pesticide loss pathways that have been 

identified as impacting the resource. 
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(6) The minimum treatment is following the pesticide label. When clients request assistance with 

IPM techniques that include pesticides, NRCS will provide an evaluation and interpretation of the 

pesticide risk for the planned pesticides as well as alternative pesticides identified by the client 

that may present a lower risk. NRCS shall not recommend specific pesticides formulation, rates, 

timing or application methods. 

(7) NRCS shall cooperate with the appropriate Federal, State, Tribal, and local agencies when 

assisting clients with pest management. 

(8) NRCS shall cooperate with APHIS and appropriate State agencies when assisting clients with 

pests (e.g., invasive species), which may require quarantine or eradication to suppress the spread 

of the pest. Typical NRCS assistance may include providing available resource information such 

as soils and climate data. 

(9) NRCS pest management activities must be in compliance with all Federal, State, Tribal, and 

local environmental laws, regulations, or ordinances. 

(10) NRCS shall assist clients to assess pest management risk to beneficial animals (e.g., native 

pollinators, honeybees, parasitic wasps, lady beetles, etc.) and to develop appropriate mitigation. 

(11) NRCS shall not provide assistance in suppressing pests in or on animals (e.g., fly suppression 

for livestock, worm suppression for goats). Regarding suppressing pests on animals only, the 

roles in 404.10 (b) (1)-(3) apply to NRCS involvement. 

(12) It is the clients', or their representatives', responsibility to ensure that all pesticides applied are 

currently registered for their intended use at their location by EPA, and that the application of the 

pesticides are not further restricted by State or other local laws or ordinances. The product label 

must contain specific instructions for the proposed use; or the proposed use must be permitted by 

special local needs registration or emergency exemptions from registration. 

(13) On NRCS-operated properties, such as Plant Material Centers, personnel who apply or 

supervise the application of approved pesticides must follow all label instructions and be trained 

and certified according to State pesticide applicator regulations, and wear the appropriate Personal 

Protective Equipment. 

(14) NRCS will cooperate with Federal and State (and equivalent) conservation agencies and the 

private sector to identify research needs for pest management and mitigation that reduce 

environmental risk. 

404.11 Certification. 

NRCS personnel and partners providing conservation planning and practice application assistance for pest 

management must meet certification requirements established by the STC in accordance with GM 

180.409.11. 

Subpart C - Responsibilities

404.20 Department of Agriculture. 

(a) Responsibilities, as described in a June 3, 1988, memorandum of understanding between CSREES and 

NRCS (i.e., Title 460, GM, Part 401, Water Quality Policy), are as follows: 
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(1) CSREES agrees to provide assistance to NRCS in support of the development and use of sitespecific information and to address water quality issues; 

(2) CSREES and NRCS agree to cooperate in encouraging each State's (or equivalent) Extension 

and NRCS organizational unit to develop guidelines and appropriate pesticide components for use 

in landowners'/operators' conservation plans; and 

(3) NRCS agrees (as outlined in a USDA companion document to the June 3, 1988, memorandum 

of understanding between CSREES and NRCS) to: 

(i) ". . . provide site-specific resource data and planning assistance with regard to 

pesticide use and impacts of water quality to pesticide users and others making land use 

and management decisions;" and 

(ii) ". . . assist landowners with the implementation of acceptable pesticide management 

practices." 

(b) Additionally, to meet the requirements of the Food Quality Protection Act of 1996, NRCS is committed 

to promoting IPM that provides both economic and environmental benefits. 

404.21 NRCS National Headquarters Office.

(a) The Deputy Chief for Science and Technology, under the direction of the Chief, is responsible for 

providing national leadership for policy and procedures for NRCS pest management and identifying pest 

management research and technology development needs. 

(b) The Director of the Ecological Sciences Division (ESD) is responsible for developing, implementing, 

and evaluating NRCS pest management policy and procedures. 

(c) The National Pest Management Specialist of the ESD provides national leadership for pest management 

policy, environmental risk technologies, and training. 

(d) The National Water Quality and Quantity Team provide the technology development and technical 

assistance for pest management environmental risk analysis technologies, including WIN-PST and 

NAPRA. 

(e) The Director of the Soil Survey Division is responsible for maintaining the soil database to support 

interpretations for pesticide leaching, solution runoff, and adsorbed runoff loss potentials. 

404.22 NRCS National Technology Support Centers (NTSC)

 NTSC Directors will provide technical assistance to STCs/Directors of the Pacific Island and Caribbean 

Areas for pest management assistance in their respective areas. 

404.23 NRCS State Offices (or equivalent).

STCs/Directors of the Pacific Islands and Caribbean Areas are responsible for: 

(a) Targeting pest management technical assistance to specific resource concerns and locations within their 

respective States/Areas (e.g., watersheds with pesticide-impaired sources of drinking water, pesticide Total 

Maximum Daily Load requirements, air quality non-attainment areas, or highly vulnerable areas that may 

contribute to future pest suppression-related contamination, increase risk of fire, and livestock production 

reduction); 

(b) Supplementing the pest management guidance and requirements in appropriate directives, as necessary, 

making it applicable to local conditions and providing a copy to the Director, ESD; 
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(c) Ensuring that appropriate training is provided to all NRCS personnel who provide pest management 

technical assistance, and establishing a process to provide continuing education to maintain employee 

certification as outlined in GM 180, Part 409.11; 

(d) Making certain that all NRCS personnel who provide pest management technical assistance to the 

public meet the applicable requirements for their positions and the State or local testing requirements as 

required by law; 

(e) Working in consultation with respective State Technical Committees to address State-specific pest 

management issues; 

(f) Utilize appropriate technology to evaluate pest management environmental risk (e.g., WIN-PST and/or 

NAPRA for risks to water quality). Environmental risk/hazard assessment tools other than WIN-PST or 

NAPRA must be reviewed by the National Pest Management Specialist, to ensure consistency with WINPST and NAPRA; and 

(g) Providing assistance, training, and technical tools (with support of NTSC) to NRCS field service centers 

so that they are able to provide assistance to clients to recognize, inventory, assess, and suppress weeds in 

non-cropland. 

404.24 NRCS Field Service Centers (or equivalent).

(a) NRCS field service center technical leaders (e.g., District Conservationists and Team Leaders) are 

responsible for providing local leadership in implementing the pest management policy. 

(b) NRCS field service center (or equivalent) employees are responsible for: 

(1) Evaluating environmental risk associated with the client’s pest suppression choices involving 

pesticides and soil disturbing activities as per 404.40, Pest Management Environmental Risk 

Analysis of this policy; 

(2) Providing technical assistance to clients to mitigate identified environmental risk of pest 

suppression strategies with conservation practices (NRCS FOTG practices) and/or Prevention, 

Avoidance or Monitoring activities recognized by the local land grant university or regional IPM 

center as being a viable IPM technique; 

(3) Assisting clients in adopting IPM techniques that protect natural resources in addition to those 

techniques used solely for the mitigation purposes above. When the client works with qualified 

individual(s) (e.g., University Extension, Certified Crop Advisor/Pesticide Control Advisor, etc.) 

to evaluate and select IPM techniques, the field office staff should document which IPM 

techniques were adopted and what resources benefited from their adoption; 

(4) Providing assistance to clients to recognize, inventory, assess, and suppress weeds in noncropland. The field office staff will bring to the client’s attention any population of weeds in noncropland that can prevent the successful establishment of a conservation practice or degrade the 

resource base so that the land cannot support its intended use. Additionally, field office staff may 

refer the client to qualified individuals (e.g., University Extension, Certified Crop 

Advisor/Pesticide Control Advisor, State or county weed and pest coordinator, etc.) for weed 

management recommendations or provide the client with pest suppression references consistent 

with Section 404.10 (c) (2) to address identified weed concerns. Field staff shall encourage 

procedures to work with their State and/or county weed management program; and 

(5) Identifying pest management needs and informing STCs/Directors of the Pacific Island and 

Caribbean Areas, or designee(s), of these needs, as appropriate. 
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404.30 Social and Economic Considerations.

The pest management practices of the conservation plan must be designed and implemented at an 

appropriate level of complexity to address social and economic constraints, resource limitations, 

management capabilities, pest management philosophies, and other social and cultural issues. Social 

considerations include public health and safety and other societal goals, as well as social, family, and 

religious values, ethnicity, risk tolerance or aversion, land tenure, and time availability. Economic 

considerations include size of farm, type of farming system (e.g., high versus low technology, high versus 

low intensity cropping systems, etc.), available capital, and land tenure. 

404.31 Environmental Justice.

The pest management practices of a conservation system will not create undue hardship on socially 

disadvantaged or other economically limited communities or individuals. 

404.40 Pest Management Environmental Risk Analysis.

(a) Environmental risk of pest management activities must be evaluated in the conservation planning 

process, including: 

1. the potential impacts of pesticides in ground and surface water on humans and non-target plants 

and animals (see (b) below); 

2. the potential impacts of mechanical pest suppression techniques on on-site soil loss and potential 

offsite resource effects (see (b) below); 

3. the potential impacts of biological pest suppression techniques on natural resources (use land grant 

university publications or other appropriate literature); and 

4. the potential impacts of cultural pest suppression techniques (e.g., burning) on natural resources, 

specifically air and soil quality resources. 

(b) Offsite effects of pest management will be evaluated with appropriate tools and/or procedures. WINPST and NAPRA are nationally supported for evaluating offsite pesticide movement through runoff and 

leaching. 

(c) WIN-PST is designed for general field office use and provides qualitative environmental hazard 

analysis that is adequate for most situations. WIN-PST is the official tool for field office use. 

(d) NAPRA is more sensitive to pesticide application techniques than WIN-PST and provides quantitative 

results. NAPRA was designed to be used by State specialists to quantify mitigation benefits in high-risk 

areas that are identified with field office use of WIN-PST. NAPRA can also be used to refine high-risk 

WIN-PST results. 

(e) States (or equivalent) utilizing pesticide environmental risk screening tools other than WIN-PST and 

NAPRA, need to coordinate their use with the Director of the ESD and the National Pest Management 

Specialist of ESD to ensure that the technology being applied is consistent with WIN-PST and NAPRA. 

(f) The risk of environmental degradation by other pest management methods and management techniques 

(e.g., tillage, burning, biological predation, etc.) must also be assessed with appropriate analysis tools, such 

as the current NRCS-approved erosion prediction technologies (see GM 450.402.A and 402.B). 

(g) If an appropriate analysis tool or procedure is not available for a proposed pest management method, 

environmental hazard analysis is left to the professional judgment of the planner. Analysis inputs and 

results should be documented in the conservation plan to justify the need for mitigation described in 

Section 404.40 (c) below. 
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(h) When pest suppression activities have significant potential to impact identified resources negatively, 

appropriate mitigation shall be discussed with the client for their decisions. Mitigation includes 

conservation practices (e.g., Filter Strip, Conservation Crop Rotation, Residue Management, Irrigation 

Water Management, etc.) and management techniques (e.g., harvest early, delayed planting, resistant 

varieties, transgenic crops, etc., etc.). The client-selected Mitigation techniques and conservation practices 

will be planned and documented in the conservation plan.