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HomeMy WebLinkAbout04.b.2) Adopt Integrated Pest Management (IPM) PolicyyAz) Central Contra Costa Sanitary District ' BOARD OF DIRECTORS POSITION PAPER Board Meeting Date: September 15, 2011 subject: ADOPT INTEGRATED PEST MANAGEMENT POLICY Submitted By: Initiating Dept. /Div.: Melody LaBella, Assistant Engineer Engineering /Environmental Services REVIEWED AND RECOMMENDED FOR BOARD ACTION: *1 � VVI. M. LaBella C. Swanson A. Farrell es M. Kelly ral Manager ISSUE: Protecting public health and the environment is the District's mission and adopting this policy will strengthen our commitment to protecting the environment by reducing the amount of pesticides the District uses in its operation. RECOMMENDATION: Adopt the proposed Integrated Pest Management (IPM) Policy. FINANCIAL IMPACTS: Anecdotally, agencies, and businesses that convert from the traditional method of managing pests using pesticides to the IPM approach experience higher initial costs. However, over the long run, costs are usually found to be comparable, since the transition to an IPM approach is a gradual process and any increase in initial cost would be reduced over time. As well, a toxicity excursion in the treatment plant caused by pest control chemicals could result in the need to spend a significant amount of money to find the cause of the toxicity. ALTERNATIVES /CONSIDERATIONS: The Board could choose to not adopt the policy and continue with the current pest management strategy. However, this is not recommended, as the use of pesticides can cause harm to the environment and that does not support the District's mission, nor does it lead by example in implementing the IPM practices that we recommend to our customers and the public. Finally, because all treatment plant drains return to the headworks, excessive use of pesticides on -site could enter the wastewater stream and cause toxicity excursions that violate our NPDES Permit. BACKGROUND: Pesticides, when minimized through use in an integrated fashion with less toxic alternatives, can be a useful tool in managing organisms considered to be a nuisance or harmful to human health. However, pesticides can be highly toxic to non - target organisms and have been implicated as a potential stressor to numerous fish species and plankton in the Delta. IPM is a method used to control pests in an POSITION PAPER Board Meeting Date: September 15, 2011 Subject: ADOPT INTEGRATED PEST MANAGEMENT POLICY environmentally - responsible manner. IPM combines different techniques to prevent pest damage without harming the environment or human health. IPM practices include monitoring, modifying pest habitat, protecting natural enemies, and, when needed, the use of less -toxic pesticides. In addition to general environmental and human health concerns related to pesticides, there are some specific regulatory concerns around the on -site usage of pesticides that could impact the District. In accordance with our NPDES Permit, CCCSD is required to perform a monthly toxicity test of our treated effluent — a test that is greatly influenced by the presence of pesticides. As well, the State Water Resources Control Board recently released a draft policy for toxicity assessment and control that would dramatically increase our toxicity testing requirements. Since pesticides can cause toxicity in water and wastewater, it is possible that our on -site pesticide practices could impact the toxicity of our wastewater, causing the District to violate our NPDES permit and /or spend a significant amount of money on a toxicity reduction evaluation to discover the source of toxicity. Many Bay Area agencies, including San Francisco Public Utilities Commission, the City of Palo Alto, East Bay Municipal Utility District, and Contra Costa County have adopted IPM policies. Through their Municipal Regional Stormwater Permits, all Bay Area stormwater agencies are now required to adopt IPM Policies, hire IPM contractors for municipal grounds and facilities, and provide outreach to the public and pest management professionals. The District can be a strong industry leader by adopting and implementing the proposed IPM Policy and setting the proper example in our own pesticide usage, while we inform the public about ways they can reduce their own use of pesticides, and the reasons for doing so. RECOMMENDED BOARD ACTION: Adopt the proposed Integrated Pest Management Policy. Number: Authority: Effective: Revised: Reviewed: Initiating Dept. /Div.: Engineering /Environmental Services Central Contra Costa Sanitary District BOARD POLICY & PROCEDURE — PROPOSED PURPOSE The purpose of this policy is to promote the combined use of physical, cultural, biological, and chemical control methods to effectively manage pests with minimal risk to humans and the environment. 2. GENERAL In support of the District's mission to protect public health and the environment, it will be the policy of Central Contra Costa Sanitary District ( CCCSD) to manage pests on CCCSD properties and facilities using Integrated Pest Management (IPM) principles and techniques. 3. POLICY Definitions IPM: a science -based strategy and decision - making process that provides effective, long -term pest control while emphasizing pest prevention and the use of non - chemical pest management practices. IPM includes the following activities: • Inspection, monitoring, and record - keeping are used to determine if thresholds for acceptable pest levels have been exceeded and to select the location, timing, and type of management strategies needed to successfully manage pests. • Appropriate and site - specific treatments are selected from educational, cultural, manual, mechanical, physical, biological, and chemical strategies. They are used within an integrated program to achieve long -term solutions that minimize hazards to human health and the environment. • Reduced -risk chemical controls are included in the treatment program when non - chemical methods are insufficient to solve the pest problem in an effective and affordable manner. Number: Authority: Effective: Revised: Reviewed: Initiating Dept. /Div.: Engineering /Environmental Services Central Contra Costa Sanitary District BOARD POLICY & PROCEDURE — PROPOSED Pest: A general term that includes problem insects, mites, arachnids, birds, mammals, weeds, and other organisms. Organisms become "pests" when their numbers are high enough to be damaging or to be a serious nuisance. Threshold Level: The point at which pest populations or environmental conditions indicate that a pest control action must be taken. Threshold levels are decided by the implementing agency and can be expressed quantitatively (five yellow jackets at a trash can, 10 percent feeding damage to a plant, three flies in a classroom) or qualitatively (light or no infestation vs. heavy infestation). Goals of this Policy 1. Minimize risks to human health, water quality, and the environment as a result of pest control activities conducted by CCCSD staff and contractors. 2. Create awareness and education of IPM techniques to staff and the public. 3. Encourage our customers to follow our example. Require Compliance with CCCSD's IPM Policy All CCCSD staff and contractors, as appropriate, will be required to comply with CCCSD's IPM Policy. CCCSD Departments will be required to help create, implement, and periodically review CCCSD's IPM Program. Designate an IPM Coordinator In recognition that the development, implementation, and oversight of an IPM Program requires a lead person and a coordinated effort, the role of IPM Coordinator shall be established and designated by the General Manager. CCCSD's IPM Coordinator will chair the IPM Committee, lead the development, implementation and oversight of CCCSD's IPM Program, work with CCCSD's Safety & Risk Management staff to maintain appropriate pest control records, serve as a resource for Departments, assist Departments in identifying priorities, acquire data to properly evaluate pest control needs and appropriate solutions, and maintain a database of the best - available information on IPM techniques for employee reference. Number: Authority: Effective: Revised: Reviewed: Initiating Dept. /Div.: Engineering /Environmental Services Central Contra Costa Sanitary District BOARD POLICY & PROCEDURE — PROPOSED Create an IPM Committee An IPM Committee will be created consisting of the IPM Coordinator and liaisons from each Department. The IPM Committee will serve as a resource to help Departments review and improve the process of making pest management decisions, consistent with the goals of this Policy. Each Department will designate a liaison to the IPM Committee. At the discretion of the General Manager, the IPM Committee may use technical assistance to develop information regarding pest control decisions. Information regarding preferred pest control solutions could include data regarding comparative efficacy, cost, environmental impact, and hazards to employees, the public, and the applicator. Require Annual Reporting CCCSD shall provide, as a method of tracking success, an annual reporting of pesticide use along with other measures of progress toward the development and implementation of CCCSD's IPM Program in the Annual Pollution Prevention Report to the San Francisco Regional Water Quality Control Board. Incorporate IPM in CCCSD Contracts The IPM Coordinator will work with CCCSD's Purchasing & Materials Manager and the Capital Projects Division to develop specifications for District contracts that include pest control, and that are consistent with this Policy and CCCSD's IPM Program. Provide IPM Training The IPM Coordinator will work with CCCSD's Safety Officer and the IPM Committee to develop education and training programs to ensure that CCCSD staff understand IPM techniques and comply with CCCSD's IPM Policy.