[Green Pest Management] From Program to Practice

As pest management professionals, we are in the business of protecting health, property, food and the environment, though the public at large may not be as keenly aware of our role in protecting the environment as we are.

Our clients are increasingly adopting green practices because they are truly concerned about the environment, and want to do their part to protect and conserve it. Thus, many of our clients buy cars that sip gasoline like 100-year-old cognac; recycle household waste and tend compost piles with almost unnatural loving care; install extra insulation and high-efficiency windows; and replace incandescent light bulbs with CFBs and LEDs. Expect them to demand green options for their pest management programs as well.

In the past, the meaning of “green” was fuzzy. Today, our clients have formal green programs from which to choose. It’s up to us to find out what they require and want, and offer them programs that meet their needs.

Some clients might just want our assurance that we are doing the environmentally right thing. Others will desire more formal proof of our green practices; for them, we can become NPMA GreenPro or Green Shield certified. Still others will be participating in LEED or organic certification. These programs award green credentials only to those who are systematically practicing green methods in everything they do.

Especially if you want to target schools, day-care centers, health-care facilities, office structures, and government buildings, you have to get your green on — and show that, in your company, IPM is more than just a buzzword.

Today, the pest management industry has offerings to satisfy everyone’s green needs. For the “how-to” guide to creating and performing these programs, read on.
 

IPM.

To borrow some philosophy from Forrest Gump, “Green is as green does.” Nobody has the copyright to the word “green,” so green is what you say it is — but only if you’re truthful in your actions.

Are your technicians trained to look for non-chemical ways to prevent pests? Are they equipped and trained to do minor structural repairs, and to make practical recommendations to their clients when larger repair projects need to be done? Do they select the pest control material that will get the job done effectively with minimum impact on the environment? If so, you’re on the right track toward being able to claim green practices. In your advertising, on your company website and in the brochures your sales force distributes, reinforce the message that, as an industry, we strive to offer pest management practices that support our clients’ decision to live their lives in an environmentally responsible manner.
 

NPMA’s GreenPro.

National Pest Management Association (NPMA) member firms that have become Quality Pro certified can take their credentials one step further and become GreenPro certified — and garner referrals from clients seeking green practitioners. In order to become GreenPro certified, and to earn the right to display the GreenPro Certified Eco-Effective logo on your advertising materials, your company must:

• Train employees in practical methods of Integrated Pest Management, and employ IPM methods to prevent and solve pest problems.
• Prepare employees for, and proctor their completion of, a written exam on the principles upon which GreenPro is based.
• Have written policies pertaining to allowable pest management practices.
• Create a separate contract for GreenPro services, apart from contracts used for non-GreenPro service programs.
• Keep records documenting that those clients that choose GreenPro service actually receive the level of IPM service that they agreed to purchase.
   

More information on NPMA GreenPro is available from the National Pest Management Association’s website, www.npmagreenpro.org.
 

Global Green.

Eligibility for GreenPro certification is limited to U.S. companies, since its principles are grounded in U.S. laws and regulations, and on practices endorsed by the U.S. Environmental Protection Agency. However, the National Pest Management Association recently introduced Global Green, a program that is similar to GreenPro, but that is open to companies from all over the world.

As with GreenPro, those desiring to offer pest management services under the aegis of the Global Green program must perform employee training and testing, practice verifiable IPM methods and materials, and justify all actions with rigorous documentation.

Further information on Global Green, with instructions and information in English, Spanish, French and German, can be found at www.wepma.org/globalgreen.
 

Green Shield.

Formally sanctioned green credentials are not for everybody, but if your market research and business model lead you to decide to open a branch of your company that offers green practices, consider applying for Green Shield certification and offering this rigorously administrated and highly respected service.

Green Shield is a certification conferred on qualified companies by the IPM Institute, a non-profit organization under the eponymous leadership of its founder, Thomas Green. Pest management firms must do these things in order to obtain and maintain Green Shield certification:

• Train their personnel to employ Integrated Pest Management practices.
• Use monitoring and inspection to spot problems early, and identify and correct conditions that are conducive to pests.
• Refrain from scheduled, “by the calendar” application of pesticides.
• Apply practical non-chemical methods.
• Use only least-impact pesticides approved by the Green Shield Certified organization.
• Keep records that include documented justification for any pesticide applied.
   

More information on the Green Shield Certified program is available at www.greenshieldcertified.org.
 

LEED.

Office buildings, schools, health-care facilities, government buildings, grocery stores and even residential properties are among the market segments that are seeking to demonstrate their environmental responsibility in a more verifiable and formalized manner. Not only in the United States, but in Mexico, Canada and more than 130 other countries around the world, LEED is growing. Your company would do well to learn how to provide LEED-compliant service programs.

LEED stands for “Leadership in Energy and Environmental Design.” It is a program offered by the U.S. Green Building Council and its affiliates in many other countries. Building management organizations overseeing the operation of existing structures, as well as those involved in construction of new buildings, seek LEED certification as a way of demonstrating — and being recognized for — their environmentally responsible practices. The motivation to become LEED-certified is not strictly altruistic; LEED-certified buildings cost less to operate because of increased energy efficiencies; they command higher rental and resale prices; and management gains the benefits of a happier workforce.

Getting to Know Your LEED Contact Get to know key players in the LEED process, including the property manager and the LEED consultant. Due to the complexity of navigating the many categories of LEED compliance and the certification process, building management firms often employ a professional LEED consultant. The LEED consultant’s role is to guide building management firms toward a program that will be accepted by the U.S. Green Building Council, and will get them the maximum number of credits toward the grade of LEED certification they seek. You may have to negotiate with the LEED consultant to get approval for a material you would like to include in your list of least-risk materials, particularly if that material is not named on the San Francisco Reduced-Risk Pesticide list.

Building and real-estate managers seeking LEED certification must prove that multiple aspects of their structures — and the practices used in constructing, maintaining and utilizing those structures — use resources responsibly and minimize adverse effects on the environment. Toward LEED certification, credits may be earned by having energy-efficient window glass and wall insulation; energy-saving heating and cooling systems; alternate energy sources such as solar and wind power; recycling and waste-disposal practices that conserve resources and minimize pollution; and an indoor and outdoor environment that promotes the well-being of employees.

Pest management represents a small piece of the credits that can be earned toward LEED certification. However, those building management firms that are pursuing LEED at the highest levels (LEED certification comes in five flavors: LEED Certified, LEED Bronze, Silver, Gold and Platinum) will try to get every credit they can earn. Thus, you can expect many of your property-management clients to ask for a LEED-compliant pest management program.

Let’s get down to the nuts and bolts of building a LEED-compliant program. The rules for LEED-compliant pest control state that you must:

• Practice responsible Integrated Pest Management;
• Use only least-risk pesticides except when a suitable least-risk material is not available or would not be effective, or in emergency situations; and
• Provide written notification to all building occupants at least 72 hours prior to the use of any non-least risk material. In the case of emergencies, you must notify all building occupants within 24 hours of completing the pesticide application. Notification can be provided on paper or electronically, i.e., via email.
   

Create and perform your LEED program according to the following instructions:

1. In writing and on company stationery, start your LEED program by naming the property and providing its address; follow with an introductory statement confirming your commitment to responsible Integrated Pest Management practices.

2. State that the objective of your program is to prevent and control pests inside and immediately outside of the building while maintaining a healthy working and living environment for those working in and visiting the building.

3. Define your IPM program as being based on inspection and monitoring, with pesticides to be used only when and where they are needed.

4. Make it clear that non-chemical materials and strategies will be relied on first and before considering any pest control material; define what is meant by “non-chemical materials and strategies” (sanitation, pest-proofing, rodent traps, insect light traps, use of appropriately chosen and appropriately located lighting, etc.).

5. State that, when it is necessary to use a pest control material, normally only least-risk pesticides will be applied. Provide a list of pest control materials that are considered least-risk; some examples include materials with the active ingredient boric acid, diatomaceous earth, horticultural oils, and non-synergized pyrethrins. (LEED accepts the San Francisco Reduced-Risk Pesticide List, most recently revised in 2013, as a guide to what is accepted as a “least-risk” pest control material. You can view or download the current version of the San Francisco list by typing “2013 San Francisco Reduced-Risk Pesticide List” into any search engine. You will find this list somewhat arbitrary in terms of which materials it deems acceptable; however, it may be possible to negotiate acceptance of other, similar materials with the consultant who advises your client on LEED compliance.)

6. Say that you will rely on two-way communications and a high degree of cooperation with building management and maintenance in order to make the program work.

7. State that non-“least-risk” pest control materials will be used only when a least-risk material suitable for the pest situation at hand is not available or would not be effective.

8. Stipulate that all building occupants will be notified at least 72 hours in advance of the use of any pest control material that is not considered “least-risk.” State that, in the case of an emergency, a non-least risk pest control material may be used without 72-hour advance notice; but when this happens, all building occupants will be notified of the emergency application within 24 hours of its completion.

9. Define “emergency.” For example, you could define “emergency” as any condition in which the presence of pests threatens the life, health or safety of persons occupying or visiting the building. For example, a hornet’s nest near the entrance to a day-care facility clearly cannot wait for 72 hours.

10. Provide a list of all pesticides to be considered for use, and applied as needed and according to the rules. For each, indicate whether it qualifies as a least-risk pesticide; how and where it is to be applied; and, if not a least-risk pesticide, what precautions will be taken in order to prevent exposure of building occupants and visitors to the material.

11. Provide a description of how your IPM program will address a variety of different pest scenarios. This portion of the written program should be in the form of a chart or matrix that names a roster of pests; gives the action threshold for each pest; describes non-chemical strategies that might be employed in order to prevent or control this pest; names least-risk materials that would be suitable for controlling the pest; and describes precautions to be taken if using a non-least risk material. At the very least, include thresholds and action plans for cockroaches, ants, stinging insects, rodents and occasional invaders. In some buildings, it may be necessary to include a plan for the unlikely (but possible) scenario of bed bugs being introduced to the building on the belongings of employees.

12. Include in your program a facsimile or template of a “Universal Notification” letter that will be used whenever it is deemed necessary to apply a pest control material that does not qualify as “least-risk.” This letter should include blanks or text fields for entering:

• The name of the pest control material;
• The common name of the material’s active ingredient;
• The date and time of the planned use;
• A description of the area where the material will be applied;
• The signal word on the label of the product; and
• A statement confirming that a need for this material was determined, based on the threat of damage to health or property.
   

Also state that, in the judgment of the pest management professional assigned to the building, a least-risk alternative is either unavailable, or would not be effective.

13. On the Universal Notification letter template, provide blanks or text fields for providing post-application notice of emergency applications. Use the same format as for non-emergency applications of non-least-risk materials, but provide an explanation that this was deemed an emergency situation, and that a 72-hour advance notice was not possible.

14. Once the written program is in place, performing it is a matter of installing, maintaining and periodically checking monitoring devices such as sticky traps; carefully inspecting the premises for pest activity and for conditions that could foster pests; applying least-risk pesticides when and only when a pest control material is necessary; and using non-least-risk pest control materials when their use is justified and explained in writing.

Need More Green? To get much more detail on the rules of organic pest management, readers are encouraged to access PCT magazine’s online archives and read past articles by this author on the subject of practical pest management in organic facilities. Visit www.pctonline.com and click on “current” issue. Then search for the December 2010 and March 2012 issues of PCT magazine.

15. Maintain a log book at every building or complex being serviced under LEED criteria. Place a copy of the written program in the log book, as well as a list of pesticides you expect to need and an action plan for responding to pest activity, as explained previously. Also place in the log book a sufficient quantity of formal daily log report blanks. On each service, the technician must complete a log report, explaining in clear narrative what service was performed; what pest activity or pest-conducive conditions were found; what action was taken; and what corrective actions the client needs to take in order to keep the facility pest-free.

The log book is key in providing an ongoing paper trail that shows compliance with the letter and spirit of the LEED rules. Finally, a quantity of Universal Notification letters should be maintained in the log book, so that the vital notification step can be easily accomplished. Remember, all occupants of a building must be notified of an impending application of a pest control material not considered least-risk; email notification satisfies this requirement. No notification is required prior to or following application of a least-risk pesticide.

16. It goes without saying that training is a component of performing LEED-compliant pest management to the expected standards. Ensure that all personnel who service LEED-certified facilities, as well as supervisors and back-up technicians, are trained in the principles and rules of LEED pest management, and in procedures for providing perfect service in LEED accounts.
 

Organic Pest Management.

Organic pest management is another area in which the rules were once unclear, and are now well defined and easy to follow. With the passage of the Organic Food Production Act of 1991, and its codification in the rules of the National Organic Program (NOP) in 2002, we have a clear procedural guideline for creating and executing pest management programs in facilities where organic processing and packaging take place.

In a nutshell, the rules for pest management in organic facilities are as follows:

1. Prior to the use of any pesticides, all non-chemical options must be tried and found to be inadequate to prevent or control pests. These include sanitation, structural repairs and exclusion (pest-proofing), physical controls such as temperature and humidity management; and mechanical controls, e.g., trapping.

2. If necessary, it is permissible to apply a pest control material named as an allowed agricultural input on the so-called “National List.” (Materials considered “National List” pesticides are those with boric acid, diatomaceous earth, horticultural oils and non-synergized pyrethrins as active ingredients.)

3. Should non-chemical measures AND the use of a National-List pesticide also fail to prevent or control pests, a pesticide NOT named on the National List may be used, provided that it is applied in such a way that no contact occurs between it and any food that is to be marketed as organic.

4. All materials that are to be considered for use must be submitted on a list of authorized pesticides and approved in advance by the organic authority responsible for sanctioning the processor’s organic handling plan.

As is the case with LEED, pest management for organic facilities begins with a carefully crafted written program that stresses your company’s commitment to the rules of the National Organic Program. Describe the program and organize the log book binder as you would for any food-processing pest management program, and add an organic preamble to the written program, stating your commitment to responsible IPM and to the rules of the National Organic Program.

Similarly to LEED, the central activities in organic pest management are inspection and monitoring. Be sure that your written program describes the centrality of these activities, and that the actual program as executed includes plenty of time for inspecting, noticing things that aren’t quite right and communicating with clients.

Since pre-approval of pest control materials is essential in being able to use non-National List pesticides in organic facilities, your organic pest management program must include a list of pesticides you plan to use. Include some “natural” products, i.e., pesticides containing boric acid, diatomaceous earth, horticultural oils, Vitamin D3, etc., as active ingredients.

Also include some back-up materials that are NOT named as agricultural inputs on the National List. For each material — particularly materials not named on the National List — give its trade name, common name and EPA Registration Number. Describe how, where and for what types of situations it will be applied; what non-pesticidal methods will be employed prior to resorting to use of that product; and what measures will be taken when it is necessary to apply the product, in order to ensure that organic food, packaging or food-contact surfaces will not be contaminated by the material. Include blanks on the form for your client to indicate approval of each material — client signature or initials, plus date approved. This pesticide authorization document will become part of your written pest management program, which in turn will be an integral part of the facility’s organic compliance documentation.

When performing pest management services under organic rules, it is absolutely essential to have a system of tracking compliance with the rules. This can be done by means of daily log reports that reference the rules by “chapter and verse;” or via less-formal reports that state directly that the action you took is in compliance with the NOP rules. In other words, you cannot just obey the rules; you have to state, in writing, what you did, and say that what you did is in compliance with the rules. In this manner, you leave a paper trail of compliance that leaves no doubt that your actions protected the organic integrity of the food.

Beyond what is described previously, there are fancier and more sophisticated ways of performing and documenting inspection findings noted, actions taken and planned, and recommendations made to the client pertaining to sanitation, physical controls, and preventive maintenance. The author would be happy to share some of these with anyone who chooses to get in touch and expresses an interest. But the bottom line is this: Effective, compliant organic programs consist of:

• A service plan written in detail and including your commitment to organic rules;
• A pre-approved pesticide authorization document; and,
• A record of daily activities that references the organic rules and shows that you did “a” before “b” and “b” before “c.”
   

That’s really all there is to it.
 

Summary.

There are many shades of green, and our clients have many ideas of what they want, or need, in terms of green service. Ask them questions, listen to their answers, and read their needs. Then follow the guidelines sketched in this article to offer your clients a hue of green that suits them.

 

The author is technical director at Plunkett’s Pest Control in Fridley, Minn. He can be reached at jbruesch@giemedia.com.