2004 Integrated Pest Management Guidance Effective September 1, 2004 - 1 - 

### U.S. Department of Interior

U.S. Fish and Wildlife Service

Integrated Pest Management:

Guidance for Preparing and Implementing

Integrated Pest Management Plans2004 Integrated Pest Management Guidance Effective September 1, 2004 - 2 - What is the purpose of this guidance? This guidance is for Fish and Wildlife Servic e (we, us, Service) stations that want to develop and implement and Integrated Pest Management (IPM) plan at sites we own or manage where pest management activities occur. This guidance serves as a tool to help us achieve the lowest risk, most targeted approach for managing pest species. As we update our pest management policies, this guidance will be issued as a handbook with the updated policies.

What are the applicable authorities? As stated in 7 USC 136r-1, “Federal agencies shall use Integrated Pest Management techniques in carrying out pest management activities and shall promote Integrated Pest Management th rough procurement and regulatory policies, and other activities.” Presi dent Carter’s 1979 Presidential Memorandum directed all federal agencies to adopt IP M strategies wherever practical. Departmental and many of our own policies instruct us to adopt IPM strategies and plans, including 517 DM 1, 30 AM 12, 7 RM 14, and 620 FW 1.

What is a pest? A pest is an organism that interferes with desired resource management goals, or any organism that may cause damage to a resource that you are trying to protect. Some questions to think about when managing pests are 1) Is it a pest that occurs at levels that prevent co mpletion of management goals, 2) Is it a native or exotic species? 3) What condi tions foster the pest? 4) What are the chances of successful pest management?

What is Integrated Pest Management? The legal definition of IPM is “a sustainable approach to managing pests by combining biological, cultural, physica l, and chemical tools in a way that minimizes economic, health, and environment al risks” (7 USC 136r-1). IPM is a long-standing, science-based, decision -making process that identifies and reduces risks from pests and pest management related strategies. It coordinates the use of pest biology, environmental information, an d available technology to prevent unacceptable levels of pest damage by the mo st economical means, while posing the least possible risk to people, property, resources, and the environment. IPM provides an effective st rategy for managing indoor (museums, living quarters, visitor centers, hatc heries) and outdoor (hatcheries, wetland management areas, refuges) pests. IPM serv es as an umbrella to provide an effective, all encompassing, minimal-risk approach to protect resources and people from pests.2004 Integrated Pest Management Guidance Effective September 1, 2004 - 3 - Some of the key components to a successful IPM program include the following:

• Understand your site management objectives and establish short and long term priorities.

• Prevent pest species from becoming a pes t at your site—this is your first line of defense against any pest species.

• Identify and monitor curr ent and potential pest spec ies, their biology, and conditions conducive to support the pest( s) (air, water, food, shelter, temperature, and light).

• Understand the physical and biological factors that affect the number and distribution of pest and their natural enemies. Conserve natural enemies when implementing any pes t management strategy.

• Establish “action thresholds” at which point an approved management strategy will be implemented to reduce the pest population.

• Review available tools and bes t management practices for the management of the identifi ed pest(s). Tools can incl ude: 1) no action, 2) physical (manual and mechanical), 3) cultural, 4) biological, and 5) chemical management strategies.

• Build partnerships and consens us with stakeholders—occupants, decision-makers, and technical experts (ongoing throughout the process).

• Obtain approval, define responsibil ities, and implement selected best management strategies, in accordance with applicable laws, regulations, and policies.

• Evaluate results of management stra tegies; determine if objectives have been achieved; modify strategies if necessary.

• Document decisions and maintain records.

• Outreach and education.2004 Integrated Pest Management Guidance Effective September 1, 2004 - 4 - Why should we implement Integrated Pest Management at our sites? The reasons to implement IPM at our sites are numerous. By implementing IPM, we will:

• Reduce risks from pests and pest management related strategies to people, property, resources, and the environment.

• Save time and resources by underst anding pest biology and conditions which favor the pest.

• Implement more effectiv e pest management strategies.

• Increase scientific management of pest species rather than being reactive or managing pests on a calendar basis . Increase our accountability by monitoring our pest populations and documenting our management

actions.

• Decrease liability from i nadequately managing our pests.

• Increase coordination and partnerships for effective pest management; decrease or eliminate unnecessary pesticide use.

• Decrease pest resistance from repeti tive pesticide use; increase safer use of pesticides and other management tools.

• Reach our short and long term site management objectives.

Is there a standard format for devising an IPM plan? No, there is not a standard format for IPM plans. IPM plans have several key components, but because plans are site specific, you should design your plan to help meet your specific pest management objectives. To ensure a successful plan, you should develop y our plan with the involvement of potential stakeholders, and you should inco rporate a peer review process for your plan.

What are the key compone nts of an IPM plan? An IPM plan has several key components. The remainder of this guidance will outline these components . IPM plans are “living” documents that require periodic reviews and updating as new information on pest management

becomes available.

• Background. Briefly discuss the need to manage pests at your station. This includes a generalized ecologica l perspective as well as state and federal mandates, executive order s, and Departmental and Service2004 Integrated Pest Management Guidance Effective September 1, 2004 - 5 - directives and policies. Discuss the mandates of your site and how specific pest species are interfering with your site management objectives.

• Site description(s). Document the conditions at your site including habitat type, soil type, proximity to su rface and ground water, wetlands, drainages, and potential sources of new infestations. For indoor sites, document the layout of your facility and internal conditions that may be contributing to your pest problem. Many factors su ch as soil composition, pH, temperature, timing, etc., will impact the success of your pest management strategies. Document if t here are sensitive resources at the site, such as unique habitat areas, rare or listed species, or other species of concern that may limit pest management options. For example, if a rare plant community is known to be pr esent at a particular site, and the species may not recover from burning, then that treatment option would be inappropriate at that site. Similarly, a broad spectrum herbicide would be inappropriate unless it was used as a spot treatment only on the pest in question and appropriate precautions were in place to eliminate drift, leaching, and runoff.

• Objectives. Make objectives attainable, time-specific, and measurable. Identify the specific pest(s) that require management and indicate what defines successful pest management at the site. For example, this may be a 90%reduction of an invasive plant s pecies, a reduction in a cockroach population so they are no longer seen during the day, or in the case of agriculture, maintaining a pest below its economic threshold.

• Consensus building and partnerships. Partnerships and cooperation are key elements to implementing an effecting IPM program. Look to others who may have experience with managing your pest(s). Identify partnerships you will use to help you meet your pest management objectives. Build consens us with potential stakeholders prior to deciding pest management strategies.

• Pest biology. Understanding the pest biology and ecology will provide insight into selecting the best pest management tools, timing considerations, and prevention methods . Know your pest species and its biology. Describe the biology and ecol ogy of each pest species, including factors relevant to its growth, dis persal, reproductive or vegetative
success, etc.

• Monitoring and mapping. Monitoring and mapping help identify the nature an extent of a pest problem. Monitoring and mapping are critical components of a successful IPM progr am and should occur prior to any pest management action. Mapping is essential to assess the location2004 Integrated Pest Management Guidance Effective September 1, 2004 - 6 - occupied by the pest species each y ear and your plan’s effectiveness in succeeding years. Early detection of a pest can save time and money. Clearly define monitoring and m apping protocols and who will be responsible for these activities. I dentify the location of the pest, and identify its location within the contex t of the surrounding landscape. For agricultural pests, designate crop sc outing methods and frequencies, and designate action thresholds above which unacceptable crop damage, adverse effects on wildlife, and/or sustainability or desired cooperative farming efforts would be threatened. Surv eying for sources of the pest and conditions that perpetuate the pest (e.g., disturbance activities in the case of many weed species) may be valuable in determining prevention

methods.

• Action Thresholds. An action threshold is the point at which you take action to reduce the pest population. Establish clear action thresholds before implementing management st rategies to reduce the pest population. An action threshold is usual ly quantitative and species specific (generic examples used): 5 insects/l eaf in a random sample of 20 plants per acre, 10 percent feeding damage to a plant, 5 flies in a bedroom, etc. Below the threshold level, no direct management action occurs to reduce the pest population; however, monitori ng and other prevent ative tools will continue to be implemented.

• Review of management options and tools. Include a comprehensive review of known management options and their efficacy. When evaluating tools, it is helpful to look at them from a risk/benefit standpoint. Also, you

must consider staff time and availabl e funding when determining feasibility of various management methods. You should select those methods, or combination of methods, that are feasible, efficacious, and yet most protective of non-target resources, including wildlife, personnel, and the public. If costs of pest management exceed available funding, you may want to seek partners, vo lunteers, grants, or additio nal internal funding, if available. When weighing risk/benefit and cost, be sure to include the potential cost of not managing the pest species (loss of species diversity and habitat, loss of crop, etc.). You should consider the following management options for all pest species:

o No action. Document the impact of t he no action alternative based on your current pest management scheme.

o Prevention. This is the most effective and least costly management option. Document methods to prevent new introductions or the spread of the pes ts to new sites. Identify routes of invasion and how these can be intercepted to reduce the chance2004 Integrated Pest Management Guidance Effective September 1, 2004 - 7 - of invasion. Prevention may include source reduction, using pathogen-free or weed-free seeds or fill; exclusion methods (e.g., barriers) and/or sanitation methods, like wash stations, to prevent reintroductions by vehicles, personnel , horses, etc. Often invasive species are the first to invade ne wly disturbed sites; prevention should include a reporting plan whereby staff can report new occurrences of an invasive species and quickly respond by eliminating new sate llite pest populations. Note: Some of these methods may fall under mechanical/ph ysical or cultural methods as

well.

o Mechanical/Physical Methods. These methods employ mechanical tools for pest prevent ion or removal. These methods may include mowing, cutting, swat hing, sheering girdling, digging, trapping, installing barriers, sealing, caulking, and heat and cold

treatments. In the case of mosquito management, filling unneeded ditches and puddle sites near facilities and removing tires and other moisture–collecting de bris are important.

o Cultural Methods. Cultural methods are a manipulation of the habitat to increase pest mortality by making the habitat less suitable to the pest. Many different cult ural practices can help reduce pest impact such as mulching, winter cover crops, changing planting dates to minimize pest impact, burn ing, flooding, trap crops, crop

rotations that include non-su sceptible crops, moisture management, addition of beneficial inse ct habitat, reducing clutter, vacuuming, proper trash disposal, and other habitat alterations.

o Biological Control Agents. These agents are organisms which can be introduced to your sites, such as herbivores, predators, parasites, and hyperparasites. If applicable, ensure introduced agents are approved by the applicabl e authorities, such as the Animal and Plant Health Inspection Service.

o Pesticides. If choosing pesticides as part of your management strategy, you must comply with t he applicable authorities pertaining to pesticide use, safety, storage, di sposal, reporting, etc. If you are unaware of these authorities, pl ease consult with your local Environmental Contaminant Specia list, Regional IPM Coordinator, or Regional Environmental Contam inants Coordinator. If pesticides do become part of your IPM strategy, then you must prepare pesticide use proposals (PUPs) and report annual pesticide usage data (there are some exceptions, consult your Regional IPM2004 Integrated Pest Management Guidance Effective September 1, 2004 - 8 - Coordinator for more information). You may attach the PUPs as an appendix to your IPM plan.

Pesticide use in an IPM program is usually more successful when it is integrated with other management strategies. If you choose pesticides as one of your tools, you must review the pesticides available to manage the pest and discuss the risks and benefits of the pesticide(s) selected versus those not selected, including potential risks to non-target or ganisms. This discussion should focus on selecting the least risk, mo st efficacious product available. If you need assistance in evaluating toxicity, leaching potential, persistence, or other pesticide -related risks, please contact the

local Environmental Contaminant S pecialist or the Regional IPM Coordinator or Coordination Team. Please keep in mind that many factors affect the efficacy of pesticides, including the pH and hardness of your mixing water. Cost should not be the primary factor in selecting among pesticides. If the least costly pesticide is the most likely to cause harm to trust resources or humans, you

should select an alternativ e product if one exists.

If a pesticide application occurs in areas that may be entered by Service staff, volunteers, or the public, you should adopt a posting plan (some pesticide labels have posting requirements as well). You should also post sign(s) befor e a pesticide application to limit entry to the site. It may be necessa ry to contact neighbors who may be chemically sensitive before sp ray events. The IPM plan, PUPs, pesticide labels, and material safety data sheets should be

available to all staff members and their location should be well

known.

• Compliance with applicable authorities. Before implementing any pest management strategy, ensure that you co mply with applicable authorities

such as the National Environmental Policy Act, Endangered Species Act, Federal Insecticide, Fungicide, and Rodenticide Act, and Occupational Safety and Health Administration r egulations. Document what measures you take to comply with any applic able authorities. If you need more information, contact your Regiona l IPM Coordinator or Regional

Environmental Contaminants Coordinator.

o National Environmental Policy Act Compliance. The development of IPM plans and the im plementation of field level IPM activities, including pesticide app lications, are subject to the National Environmental Policy Ac t (NEPA). Compliance with NEPA requires the Service to make a determination whether the proposal2004 Integrated Pest Management Guidance Effective September 1, 2004 - 9 - is covered under an existing categoric al exclusion (CX) or requires the preparation of an envir onmental assessment (EA).

 The use of a categorical exclusion depends on whether the IPM plan or activities can be covered under an existing

CX available to the Servic e found in 516 DM 2, Appendix 1 and in 516 DM 6, Appendix 1.4. Ex ceptions to the CXs (e.g., controversy over environmental effects, have significant adverse effects on public health or safety, etc.), that may preclude the use of the CX , are found in 516 DM 2, Appendix 2. The CXs and t heir exceptions should be reviewed prior to the dev elopment of an IPM plan and implementation of field-level IPM activities. In most cases, a CX will apply. The CX gener ally applicable for the preparation of the IPM plan usually will be 516 DM 6, Appendix 14B(2). If a refuge special use permit is required, the action may also be covered under the CX in 516 DM 6, Appendix 1.4C(5). Whenever a CX is used, an administrative

record should be created to document the use of the CX using the NEPA Compliance Checklist, modified as appropriate (refer to D.O. No. 127).

 The level of NEPA compliance will vary for the preparation or revision of IPM plans on a case-by-case basis, depending on the level of impacts antici pated, whether an existing CX applies, or whether an exception of the CX applies. The

more details contained in t he IPM plan to ensure that IPM activities are carried out in an environmentally-sound manner with no potential for signi ficant impacts on the local environment, the easier it will be to ensure that the implementation of field-level IPM activities can be covered under an existing CX.

 For technical assistance regarding NEPA compliance matters for IPM plans and field- level activities, consult the Regional Environmental (N EPA) Coordinator or the Washington Office (NEPA) Coordi nator. All references cited

above are found in the Service’s NEPA Reference Handbook at www.fws.gov/r9/esnepa

.

o Endangered Species Act Compliance: Federally Listed, Proposed, and Candidate Species and Designated Critical Habitat (Listed Resources). If you have listed resources at your site, ensure completion of the appropriate Section 7 compliance2004 Integrated Pest Management Guidance Effective September 1, 2004 - 10 - documentation before implem enting any pest management strategy. You may attach this as an appendix to your plan. If a determination of no effect is made, then Section 7 consultation is complete. A no effect determi nation must be supported by documentation that supports the c onclusion. The obligations under

Section 7 must be reconsidered if: (1) new information reveals impacts of this identified action t hat may affect listed species or critical habitat in a manner not prev iously considered, (2) this action is subsequently modified in a m anner that was not considered in this review, (3) a new species is listed or critical habitat is determined that may be affected by t he identified action, or (4) if the

amount of incidental take antici pated in a biological opinion is exceeded. For more information, please contact the appropriate Service Endangered Species staff or National Marine Fisheries Service (NOAA Fisheries).

o Occupational Safety and Health Administration Regulations. When preparing for pest management activities, ensure that employees are aware of the requi rements for Personal Protective Equipment and safety procedures set forth by the Occupational Safety and Health Administration (29 CFR 1910) and by Service policies in Service Manual sections 240-242.

• Selected pest management strategies and prioritization. Identify the management strategies you will employ to manage your pest(s) based on the analysis of the availa ble tools and their asso ciated benefits and risks. Also, document who is responsible fo r implementing and monitoring the success of your pest management st rategies. The timing of pest management implementation will be site and species specific. If you have multiple sites with the same pest, you should prioritize your sites based on your management objectives. For exam ple, most IPM plans propose the following pest management prioritizati on scheme: (1) prevention of new infestations, (2) management of pests at new “satellite” sites, (3) perimeter management of large pest colonies , and (4) management of the large colony.

This scheme would be particularly appl icable when total elimination of pest species does not appear feasible in the short term and when the pest of concern does not disperse read ily over long distances. For those species whose seeds disperse widely and readily, treatment of the largest infestation might be of the highest prio rity. Treatment of pest species in riparian areas would typically employ another strategy—treatment of the most upstream riparian pest population first, then those further2004 Integrated Pest Management Guidance Effective September 1, 2004 - 11 - downstream. Another consideration in prioritizing sites for management might be based on abundance of highly va lued native species. Treatment of the most highly valued sites firs t may best mitigate threats to native biodiversity.

• Best management practices. Best management practices (BMPs) can mitigate impacts to non-target organism s. Identify BMPs such as buffers you will implement around drainages, wetl ands, waters, or other sensitive sites. Identify how you will use timi ng of pest management strategies to reduce risks to non-target species. If using pesticides, you may decide to use a dye to reduce spraying of non- target site, as well as reduce unnecessary spray overlaps. Discuss the use of specific equipment or methods that will prevent or reduce the risks to non-target organisms.

• Site restoration. Consider whether the site requires any restoration activities following pest management effort s. If the pest occurs primarily on

disturbed sites or has developed dense stands in natural sites, then revegetation may be critical to assure long-term pest management, particularly for management of invasive plant species with large seed banks. If the site will need revegetation, describe the proposed reseeding or replanting efforts. Mere ly treating a site to elim inate an invasive species without any revegetation planning coul d be ineffective and would likely

result in increased costs and resources over time.

• Record-keeping. A record-keeping system is essential to establish trends and patterns in pest outbreaks. Informa tion recorded at every inspection or treatment should include pest identific ation, population size, distribution, recommendations for future preventi on, and complete information about the action taken, including the use of any pesticide.

• Education and outreach . This is a critical component of a plan because a successful IPM program depends on t he coordinated actions of many people. Indicate how staff, volunteers, cooperators, and the public will be informed about pest problems, including ho w to identify the pests, how the pests may cause harm, needed repor ting, and cooperative management methods. If public outreach would be valuable, identify how the public

and/or volunteers will be tr ained or educated to assist in pest management

efforts.

• Monitoring success. To ensure a successful IPM program, you must evaluate the results of your chosen management strategies, ascertain if you achieved your pest management objec tives, and modify the strategies if necessary.2004 Integrated Pest Management Guidance Effective September 1, 2004 - 12 - References. In addition to the guidelines above, there are numerous IPM

references accessible on the Internet. Other good sources of information are universities and your loca l county extension agents.

http://parks.state.co.us/cnap/publications .html "Creating An Integrated Weed Management Plan" http://tncweeds.ucdavis.edu/ http://tncweeds.ucdavis.edu/products.html "Weed Plan Template and Model Sample" http://www.science.org.au/nova/041/041key.htm http://edis.ifas.ufl.edu/BODY_LH080 http://www.ipmcenters.org/ http://www.ipmcenters. org/IPMRoadMap.pdf