09 - PESTICIDE MANAGEMENT
Pesticides belong to numerous chemical classes that vary greatly in toxicity and as such are highly regulated. When a pesticide application is deemed necessary, selection should be based on effectiveness, toxicity to non-target species, cost, site characteristics, solubility and persistence in the environment, and label specifications. A product should not be used unless explicitly labelled for a given scenario. In Texas, the label is the law!
Texas Regulation of Pesticides
Texas Department of Agriculture (TDA) - TDA is the state’s lead agency in the regulation of pesticide use and application. TDA is responsible for licensing pesticide applicators, overseeing worker protection, registering pesticides, working to minimize unnecessary impacts, and protecting endangered and threatened species. Texas A&M AgriLife Extension Service and the private sector trains license candidates.
Texas Commission on Environmental Quality (TCEQ) - TCEQ is the lead agency for the regulation of waste discharges, including pesticide discharges, into waters of the state. Various divisions of the agency address many of the groundwater protection issues related to pesticides.
Texas Department of State Health Services (DSHS) - DSHS’s General Sanitation Division tests and certifies government employees that apply pesticides.
Texas Groundwater Protection Committee (TGPC) - TGPC is a consortium of nine state agencies and the Texas Association of Groundwater Districts. The committee is charged with the state’s preparation of the Pesticide Management Plans (PMPs).
Reference additional information:
https://www.texasagriculture.gov/RegulatoryPrograms/Pesticides.aspx
https://tgpc.texas.gov/pesticides/regulation-of-pesticides/
Best Management Practices
Comply with all Federal, Environmental Protection Agency (EPA) and Texas State laws and regulations. Adhere to pesticide labels; the label is the law.
Select the least toxic pesticide with the lowest exposure potential; visit the EIQ, Environmental. Impact Quotient for helpful information https://nysipm.cornell.edu/eiq/.
Preventive programs outweigh curative programs and should be considered a staple of an IPM program.
Use Reduced Risk Pesticides when appropriate.
Know the emergency response procedure in case excessive exposure occurs.
Follow all directions on pesticide’s labelling.
Properly calibrate application equipment.
Always utilize Personal Protective Equipment (PPE) when required by the label.
Ensure facilities for storing and handling are properly sited, designed, constructed, and operated.
Maintain a designated area to mix, load, and clean sprayers with quality water.
Use caution when mixing and understand what chemicals can be mixed together. Mix pesticides in a small container to check compatibility before mixing in spray tanks.
Develop an emergency response plan including procedures to control, contain, collect, and store spilled materials.
Create, within 30 days, and maintain for two years, a record for each application of a restricted use pesticide (RUP).
Properly rinse all used pesticide containers to dispose of as non-hazardous solid waste.
Application, Storage & Transport, Emergency Response, Record-Keeping
Responsibilities of Pesticide Owners, Users, or Handlers
Whenever taking possession of a pesticide it is important to ensure that that both the pesticide labeling, and the guidance and regulations of the TDA are followed. Failure to do so can result in harm to human or animal health as well as contamination of land and water sources.
Federal law requires any person who applies or supervises the use of RUPs to be certified in accordance with EPA regulations and state, territorial, and tribal laws. Pesticide applicators must know how to apply RUPs properly and effectively. State, territorial, and tribal authorities certify applicators. To apply for certification, you must justify your eligibility, pay a fee and then pass an exam (or exams). Licensed commercial and noncommercial applicators in Texas are required to recertify annually by obtaining five continuing education credits; with one credit each from two of the following categories: laws and regulations, integrated pest management or drift minimization.
Information on training providers and the process to apply for certification:
https://www.texasagriculture.gov/RegulatoryPrograms/Pesticides/PesticideApplicatorInformation.aspx
Information on the Worker Protection Standard and Texas Hazard Communication Law (RTK), with required communications and education for safety and well-being of pesticide handlers and workers where pesticides are applied:
https://agrilife.org/aes/worker-protection-standards-wps/
The TDA designates a pesticide as a State Limited Use (SLU) pesticide due to potential adverse effects on non-target sites. SLUs are regulated on the basis of containing an active ingredient which has been designated by the state.
List of SLU regulated ingredients on the TDA website:
https://www.texasagriculture.gov/RegulatoryPrograms/Pesticides/StateLimitedUsePesticide.aspx
SLUs have restrictions relating to purchase, use, and distribution. It is the joint responsibility of the person in control of the golf course and the applicator to ensure the application complies with regulations and that correct record-keeping is maintained.
Texas Pesticide Classifications State Limited Use
The TDA refers to five classifications of pesticides:
General-Use pesticides can be purchased and used by the general public. They do not require a license for personal use on an individual’s property or for distribution.
Restricted-Use pesticides will state “restricted-use” on the product label as required by the EPA.
State Limited Use pesticides contain certain active ingredients that have the potential to cause adverse effects to nontargeted vegetation.
Regulated Herbicides have additional restrictions in regulated counties to prevent a hazard to desirable vegetation caused by drift or an uncontrolled application.
Prohibited Pesticides. https://www.texasagriculture.gov/RegulatoryPrograms/Pesticides/ProhibitedPesticides.aspx
Additional information on Texas Pesticide Classifications: https://www.texasagriculture.gov/RegulatoryPrograms/Pesticides/AgriculturalApplicators/PesticideClassifications.aspx
Personal Protective Equipment (PPE) & Human Health Risk
Pesticides belong to numerous chemical classes that vary greatly in toxicity. Risk to human health associated with pesticide use depends on both pesticide toxicity and the level of exposure- i.e., the amount of product and length of time involved with any contact. The risk of a highly toxic pesticide may be very low if the exposure is sufficiently small. There are four pesticide signal words that help provide indicators for what level of risk is present when applying.
Source: www.epa.gov
PPE is used for protection against chemicals contacting the person loading, mixing, and spraying the chemical. It is important to read the label thoroughly and use the minimum required PPE listed on the pesticide label, users may always choose to use more PPE than required on the label.
Employees will need to wash clothes that may have pesticide residues on them; washing requires the use of hot water with clothes that are suspected to have pesticide residues. Run another empty load once the clothes are washed.
Best Management Practices
Provide adequate PPE for all employees who work with pesticides (including equipment technicians who service pesticide application equipment).
Ensure that PPE is sized appropriately for each person using it.
Make certain that PPE is appropriate for the chemicals used.
Ensure that PPE meets rigorous testing standards and is not just the least expensive.
Store PPE where it is easily accessible but not in the pesticide storage area.
Forbid employees who apply pesticides from wearing facility uniforms home where they may come into contact with children.
Provide laundering facilities or uniform service for employee uniforms.
The federal Occupational Safety and Health Administration (OSHA) requires employers to fit-test workers annually who must wear tight-fitting respirators.
Where using respiratory protects ensure compliance with Occupational Safety and Health Administration (OSHA) 1910.134 Respiratory Protection Program.
Sprayer Calibration
Proper calibration of equipment is necessary to accurately and correctly apply any pesticide. Spray technicians must be experienced, licensed, and properly trained. Use an appropriately sized applicator for the size of area being treated. Minimize off-target movement by using properly configured application equipment. It’s good practice to calibrate all application equipment at the beginning of each season (at a minimum) or after equipment modifications. Equipment should be checked daily when in use. Calibration of walk-behind applicators should be conducted for each person making the application to take into consideration their walking speed, etc. Always use recommended spray volumes for the targeted pest to maximize efficacy.
Source: Adapted from Integrated Pest Management for Turf and Ornamentals, Edited by Anne R. Leslie (1994).
Environmental Fate and Transport
Pesticides, wherever they are applied, have the potential to interact with wildlife or migrate into surface and subsurface waters. A key environmental consideration concerns the runoff and leaching potential of a selected pesticide. Prior to application, it is important to consider the particular characteristics of each pesticide and site. Key issues include proximity to surface water; the water table and well-heads; soil type; prevailing winds; presence of endangered species and so on.
Environmental hazards related to a pesticide are listed on pesticide product labels. The “Environmental Hazards” are found under the general heading “Precautionary Statements,” which provides language advising the user of the potential hazards to the environment and off target organisms – found under three headings: general environmental hazards, non-target toxicity, and endangered species protection.
Best Management Practices
Select pesticides that have a low drift, runoff, and leaching potential; understand pesticide sorption principles so that appropriate decisions can be made.
Labels provide warnings about these potential risks with each product.
Before applying a pesticide, evaluate the impact of site-specific characteristics (for example, proximity to surface water, water table, and well-heads; soil type; prevailing wind; etc.)
Before applying pesticides, monitor wind conditions to ensure accurate target of intended application; establish a safe wind speed for application, i.e., 10 mph or less.
Understand site characteristics that are prone to leaching losses (for example, sand-based putting greens, coarse-textured soils, shallow water tables).
Select pesticides with reduced impact on pollinators.
Select pesticides that, when applied according to the label, have no known effect on endangered species present at the facility.
For information on reducing risk from misapplication due to pesticide drift, reference: https://agrilifeextension.tamu.edu/solutions/flag-the-technology/
Pesticide Transportation, Storage, and Handling
It is important to carefully review and comply with storage information on pesticide labels as improper storage is a form of misuse. Pesticides are at their highest risk before dilution therefore it is especially important to take care of them during storage and transportation.
Key potential risks to human health and the environment are linked to spills, fire, and contaminated runoff.
Ideally pesticide storage facilities will be in a separate building at a distance from other structures. This is important to reduce contamination in the case of large accidental spills and to allow easy access to service vehicles in case of an emergency. Fire extinguishers suitable for chemical fires should be readily available. PPE should be kept off site but within easy access.
To minimize runoff and water contamination risks it is important to consider the immediate environment when selecting the site for a storage facility. Storage facilities should be at least 400 feet downhill from drinking water supplies; 200 feet from surface water and should not be placed within the 100-year floodplain.
Pesticide storage should always be locked and have signage indicating, Danger, Keep Out, Chemical Hazards, or similar. The local fire department should be informed about the storage unit, what it contains, and where it is located.
Best Management Practices
Storage facilities should be a lockable concrete or metal building with sufficient access to allow fire department approach.
Do not store pesticides near burning materials or hot work (welding, grinding), or in shop areas.
Store, mix, and load pesticides away from sites that directly link to surface water or groundwater.
Storage facility floors should be watertight and sealed with a chemical resistant paint. The floors should have a continuous sill to retain spilled materials and no drains, although a sump may be included.
Sloped ramps should be provided at the entrance of storage facilities to allow the use of wheeled handcarts for moving material in and out of the storage area safely.
Shelving and surfaces in the pesticide storage and transportation should never be wooden as wooden surfaces can absorb spilled pesticides. All shelving should be made of be made of sturdy plastic or reinforced metal, painted to avoid corrosion.
Automatic exhaust fans and an emergency wash area should be provided.
Explosion-proof lighting may be required.
Light and fan switches should be located outside the building, so that both can be turned on before staff enter the building and turned off after they leave the building.
Avoid temperatures less than 40°F or greater than 100°F inside the pesticide storage facility.
Do not transport pesticides in the passenger section of a vehicle and never leave pesticides unattended during transport.
Place a spill containment kit in the storage area, in the mix/load area, and on the spray rig.
Pesticide Inventory & Storage
Pesticides degrade over time; do not store large quantities of pesticides for long periods - and only mix the amount planned for use. When bringing in new product, date the labels to be able to identify the oldest in inventory. Adopt the “first in–first out” principle, using the oldest products first to ensure that the product shelf life does not expire. Utilize computer software systems to record inventory and use. Safety Data Sheets (SDS) and copies of labels for all pesticides on hand should be kept in an easily identifiable location, outside the pesticide storage facility.
Best Management Practices
Avoid purchasing large quantities of pesticides that require storage for greater than six months.
Adopt the “first in–first out” principle, using the oldest products first to ensure that the product shelf life does not expire.
Ensure labels are on every package and container.
Arrange containers so the labels are clearly visible. Securely fasten loose labels to ensure containers and associated labels are kept together.
Damaged labels should be replaced immediately.
Store flammable pesticides separate from those that are non-flammable.
Store liquid materials below dry materials to prevent leaks from contaminating dry products.
Ensure that oil containers and small fuel containers (service containers) are properly labeled and stored within the facility.
Keep a separate notebook with copies of labels and SDS sheets outside of the storage area in an office.
Consult inventory when planning and before making purchases.
Maintain inventory copies off site for review in case of fire to help containment issues.
Pesticide Mixing/Washing
Pesticide leaks or spills, if contained, will not percolate down through the soil into groundwater or run off the surface to contaminate streams, ditches, ponds, and other waterbodies. One of the best containment methods is the use of a properly designed and constructed chemical mixing center (CMC).
Handling open pesticide containers, measuring pesticide materials, or working with pesticide application equipment presents an exposure risk to the handlers and the environment. Applicators and handlers must put on label-required PPE prior to opening pesticide packages. Consider using closed systems when available.
Mixing is an important part of proper spraying application and it is important that the mixer know what they are spraying, and which chemicals can be mixed together. If uncertain, a jar test should be prepared to make sure the chemicals are compatible. A jar test is a simple method of using small samples of the mixture and mixing in a small jar. This will allow observation of the reaction and make sure a complete mixture can be achieved.
The specific mixing and sequence of mixing instructions on the label should be followed. No chemicals should be mixed without proper supervision. Management should always be involved in the selection and initial stages of mixing to avoid accidents. The most common accidents occur by staff misunderstanding the rates, distractions, and mixing of the wrong materials. Facilities should be ventilated and provide secondary containment of incidental spills due to normal mixing/loading practices, plus secondary containment in the event of large accidental spills.
Best Management Practices
Loading pesticides and mixing them with water or oil diluents should be done over an impermeable (watertight) surface, so that spills can be collected and managed.
The mixing station surface should offer easy cleaning and the recovery of spilled materials.
Pump the sump dry and clean it at the end of each day.
Liquids and sediments should be removed from the sump and properly managed and disposed of.
Apply liquids and sediments from the sump the same as a pesticide, strictly following label instructions.
Sweep up solid materials and use as intended.
Rinsate may be applied as a pesticide (preferred) or stored for use as makeup water for the next compatible application. Caution: do not mix herbicide rinsate with other products.
Collect wash water (from both inside and outside the application equipment) and use it as a pesticide in accordance with the label instructions.
Pesticide Container Disposal
Federal law (FIFRA) requires pesticide applicators to rinse all empty pesticide containers before taking other container disposal steps. Under the federal Resource Conservation and Recovery Act, or RCRA, a pesticide container is not empty until it has been properly rinsed. The improper disposal of a hazardous waste can result in fines and/or criminal penalties. Pesticide containers that have been properly rinsed can be handled and disposed of as non-hazardous solid waste.
Best Management Practices
Refer to the label for disposal requirements.
Rinse empty pesticide containers immediately after use in order to remove the most residue.
Rinse containers during the mixing and loading process and add rinsate water to the finished spray mix.
Rinse emptied pesticide containers by either triple rinsing or pressure rinsing.
Puncture or crush empty and rinsed pesticide containers and dispose of according to the label.
It is against the law to use empty pesticide containers for another function. Empty containers must be rendered unusable (i.e., punctured) and disposed of according to label directions. There are approved recyclers for plastic pesticide containers, refer to TCEQ: https://www.tceq.texas.gov/p2/hhw/about.html.
Emergency Preparedness and Spill Response
Advance preparation on what to do when an accident occurs is essential to mitigate human health effects and environmental impact. An emergency response plan should be in place. The plan should include:
Names and quantities of pesticides in inventory.
Location of property, including a map and directions (to relay over phone in emergency).
Names, addresses, and phone numbers of the designated spokesperson, superintendent, and key employees.
Plan of facility showing pesticide storage locations, flammable materials, electrical service, water supply, fuel storage tanks, fire hydrants, storm drains, and nearby wetlands, ponds, or streams.
Location of emergency equipment supplies.
Procedures to control, contain, collect, and store spilled materials.
Contact information for fire, police, hospital, pesticide bureau, spill clean-up firm, board of health, and facility owner.
Ensure that copies of the plan are located near the pesticide storage facility and the office and distributed to local police and fire departments. Maintain copies in English and any other language commonly used by employees.
Best Management Practices
Develop a golf course facility emergency response plan that includes procedures to control, contain, collect, and store spilled materials.
Ensure an adequately sized spill containment kit is readily available.
Designate a spokesperson who will speak on behalf of the facility should an emergency occur.
Host a tour for local emergency response teams (e.g., firefighters) to show them the facilities and to discuss the emergency response plan. Seek advice on ways to improve the plan.
Be Prepared for Emergencies
Be sure to always prominently post important telephone numbers, including:
CHEMTREC, for emergency information on hazards or actions to take in the event of a spill
Texas Commission on Environmental Quality (TCEQ) 1-800-832-8224 or (512) 239-2507
TCEQ Small Business Assistance Program 1-800-447-2827
Texas State Poison Control Center 1-800-764-7661 (1-800-POISON1)
National Pesticide Information Center (http://npic.orst.edu/) 1-800-858-7378
Pesticide Record-Keeping
Pesticide applicators who have a private applicator license or certificate are required to maintain records of their applications of RUPs and state-limited-use pesticides under the Food, Agriculture, Conservation and Trade Act of 1990 and the Texas Pesticide Laws and Regulations.
Commercial and noncommercial license holders must keep records of all pesticide applications in Texas. Pesticide record-keeping requirements for state and federal restricted pesticides in Texas: https://www.texasagriculture.gov/Portals/0/Publications/PEST/pes_rkbroch.pdf
Records must contain:
Date and time of application
Person for whom application was made
Location of land
Product name
EPA registration number
Rate of product per unit
Amount applied per unit
Pest treated
Site treated
Total acres or volume of area treated
Wind direction and velocity and air temperature
Method or Type of Equipment Used to Make Application
Non licensed Applicator’s name Working Under Licensee
FAA “N” number of aerial equipment; ID number of other application equipment
Applicator name and license number and/or person making the application
Spray permit number for regulated herbicides applied in a regulated county - spray permit not required for golf course applications
Documentation to verify training of persons working under the supervision of a licensed pesticide applicator
Best Management Practices
Records must be maintained for two years.
Records must be kept accessible and available for copying and must be maintained at the applicator’s primary place of business as designated on the applicator’s pesticide license.
Records of application must be made available for inspection by TDA upon request.
Keep a backup set of records in a safe, but separate storage area.
Records do not have to be kept on TDA forms but must contain the required information.
Use records to monitor pest control efforts and to plan future management actions.
There are several resources available to assist with record-keeping, examples include:
GreenKeeper https://www.greenkeeperapp.com/marketing/
Playbooks for Golf https://goplaybooks.com/coverage.html
Sparks https://sparks2.com/
PeRK https://cropwatch.unl.edu/unl-releases-perk-20-pesticide-recordkeeping-app
Source: TDA Portal
