2004 Integrated Pest Management Guidance

Effective September 1, 2004 

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U.S. Department of Interior 

U.S. Fish and Wildlife Service 

Integrated Pest Management: 

Guidance for Preparing and Implementing 

Integrated Pest Management Plans 
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What is the purpose of this guidance? 

This guidance is for Fish and Wildlife Service (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 through procurement and regulatory 

policies, and other activities.” President Carter’s 1979 Presidential Memorandum 

directed all federal agencies to adopt IPM 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 completion of management goals, 2) Is it a 

native or exotic species? 3) What conditions 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, physical, and chemical tools in a way that 

minimizes economic, health, and environmental 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, and available technology to 

prevent unacceptable levels of pest damage by the most economical means, 

while posing the least possible risk to people, property, resources, and the 

environment. IPM provides an effective strategy for managing indoor (museums, 

living quarters, visitor centers, hatcheries) and outdoor (hatcheries, wetland 

management areas, refuges) pests. IPM serves as an umbrella to provide an 

effective, all encompassing, minimal-risk approach to protect resources and 

people from pests. 
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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 pest at your site—this is your first 

line of defense against any pest species. 

• Identify and monitor current and potential pest species, 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 pest management strategy. 

• Establish “action thresholds” at which point an approved management 

strategy will be implemented to reduce the pest population. 

• Review available tools and best management practices for the 

management of the identified pest(s). Tools can include: 1) no action, 2) 

physical (manual and mechanical), 3) cultural, 4) biological, and 5) 

chemical management strategies. 

• Build partnerships and consensus with stakeholders—occupants, 

decision-makers, and technical experts (ongoing throughout the process). 

• Obtain approval, define responsibilities, and implement selected best 

management strategies, in accordance with applicable laws, regulations, 

and policies. 

• Evaluate results of management strategies; determine if objectives have 

been achieved; modify strategies if necessary. 

• Document decisions and maintain records. 

• Outreach and education. 
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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 understanding pest biology and conditions 

which favor the pest. 

• Implement more effective 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 inadequately managing our pests. 

• Increase coordination and partnerships for effective pest management; 

decrease or eliminate unnecessary pesticide use. 

• Decrease pest resistance from repetitive 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 your plan with the involvement of 

potential stakeholders, and you should incorporate a peer review process for 

your plan. 

What are the key components 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 ecological perspective as well as state and 

federal mandates, executive orders, and Departmental and Service 
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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 surface 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 such as soil composition, 

pH, temperature, timing, etc., will impact the success of your pest 

management strategies. Document if there 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 present 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 species, 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 consensus 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 ecology of each pest species, including 

factors relevant to its growth, dispersal, 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 program and should occur prior to any 

pest management action. Mapping is essential to assess the location 
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occupied by the pest species each year and your plan’s effectiveness in 

succeeding years. Early detection of a pest can save time and money. 

Clearly define monitoring and mapping protocols and who will be 

responsible for these activities. Identify the location of the pest, and 

identify its location within the context of the surrounding landscape. For 

agricultural pests, designate crop scouting 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. Surveying 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 strategies to reduce the pest 

population. An action threshold is usually quantitative and species specific 

(generic examples used): 5 insects/leaf 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, monitoring and other preventative 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 available 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, volunteers, grants, or additional 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 the 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 pests to new sites. Identify routes 

of invasion and how these can be intercepted to reduce the chance 
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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 newly disturbed sites; prevention 

should include a reporting plan whereby staff can report new 

occurrences of an invasive species and quickly respond by 

eliminating new satellite pest populations. Note: Some of these 

methods may fall under mechanical/physical or cultural methods as 

well. 

o Mechanical/Physical Methods. These methods employ 

mechanical tools for pest prevention or removal. These methods 

may include mowing, cutting, swathing, 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 debris 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 cultural practices can help reduce pest 

impact such as mulching, winter cover crops, changing planting 

dates to minimize pest impact, burning, flooding, trap crops, crop 

rotations that include non-susceptible crops, moisture 

management, addition of beneficial insect 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 applicable 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 the applicable authorities pertaining 

to pesticide use, safety, storage, disposal, reporting, etc. If you are 

unaware of these authorities, please consult with your local 

Environmental Contaminant Specialist, Regional IPM Coordinator, 

or Regional Environmental Contaminants 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 IPM 
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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 organisms. This discussion should 

focus on selecting the least risk, most efficacious product available. 

If you need assistance in evaluating toxicity, leaching potential, 

persistence, or other pesticide-related risks, please contact the 

local Environmental Contaminant Specialist 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 alternative 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) before a pesticide application to limit 

entry to the site. It may be necessary to contact neighbors who may 

be chemically sensitive before spray 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 comply 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 regulations. Document what measures 

you take to comply with any applicable authorities. If you need more 

information, contact your Regional IPM Coordinator or Regional 

Environmental Contaminants Coordinator. 

o National Environmental Policy Act Compliance. The 

development of IPM plans and the implementation of field level IPM 

activities, including pesticide applications, are subject to the 

National Environmental Policy Act (NEPA). Compliance with NEPA 

requires the Service to make a determination whether the proposal 
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is covered under an existing categorical exclusion (CX) or requires 

the preparation of an environmental 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 Service found in 516 DM 2, Appendix 1 

and in 516 DM 6, Appendix 1.4. Exceptions 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 their exceptions should be 

reviewed prior to the development of an IPM plan and 

implementation of field-level IPM activities. In most cases, a 

CX will apply. The CX generally 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 anticipated, whether an existing CX 

applies, or whether an exception of the CX applies. The 

more details contained in the IPM plan to ensure that IPM 

activities are carried out in an environmentally-sound 

manner with no potential for significant 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 (NEPA) Coordinator or the 

Washington Office (NEPA) Coordinator. 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 compliance 
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documentation before implementing 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 determination must be supported by 

documentation that supports the conclusion. The obligations under 

Section 7 must be reconsidered if: (1) new information reveals 

impacts of this identified action that may affect listed species or 

critical habitat in a manner not previously considered, (2) this action 

is subsequently modified in a manner that was not considered in 

this review, (3) a new species is listed or critical habitat is 

determined that may be affected by the identified action, or (4) if the 

amount of incidental take anticipated 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 requirements 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 available tools and their associated benefits and risks. 

Also, document who is responsible for implementing and monitoring the 

success of your pest management strategies. 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 example, most IPM plans propose the 

following pest management prioritization 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 applicable when total elimination of 

pest species does not appear feasible in the short term and when the pest 

of concern does not disperse readily over long distances. For those 

species whose seeds disperse widely and readily, treatment of the largest 

infestation might be of the highest priority. Treatment of pest species in 

riparian areas would typically employ another strategy—treatment of the 

most upstream riparian pest population first, then those further 
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downstream. Another consideration in prioritizing sites for management 

might be based on abundance of highly valued native species. Treatment 

of the most highly valued sites first may best mitigate threats to native 

biodiversity. 

• Best management practices. Best management practices (BMPs) can 

mitigate impacts to non-target organisms. Identify BMPs such as buffers 

you will implement around drainages, wetlands, waters, or other sensitive 

sites. Identify how you will use timing 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 efforts. 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. Merely treating a site to eliminate an invasive species 

without any revegetation planning could 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. Information recorded at every inspection 

or treatment should include pest identification, population size, distribution, 

recommendations for future prevention, 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 the coordinated actions of many 

people. Indicate how staff, volunteers, cooperators, and the public will be 

informed about pest problems, including how to identify the pests, how the 

pests may cause harm, needed reporting, and cooperative management 

methods. If public outreach would be valuable, identify how the public 

and/or volunteers will be trained 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 objectives, and modify the strategies 

if necessary. 
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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 local 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