Strategy

Preamble
I. Mission Statement
II. Purpose
III. Definitions
IV. Descriptions of Roles and Responsibilities
V. Notification
VI. Tiered Materials List and Exemption
Process

VII. Record Keeping
VIII. Training
IX. Reviewing Plans for New Construction and
Landscape Projects

X. Contractors
XI. Precautionary Principle
REFERENCE DOCUMENTS

Preamble

The County of Ventura has the responsibility for oversight on properties which include
hospitals, Parks, golf courses, airports, detention facilities industrial, roads
and business sites. At the direction of the Board of Supervisors, the General Services
Agency (GSA) was tasked to report and make recommendations on an Integrated Pest
Management Plan (IPM). In order to provide an opportunity to address issues which
may affect other agencies, department representatives were invited to a meeting
on December 17, 2007 to discuss the impact of the IPM on agencies outside of GSA.
The effort of this program is not to eliminate the use of pesticides but to reduce
usage and define the manner in which they are used. The approach of “least harmful
first” is applied, providing a plan to reduce the use of more toxic pesticides,
while allowing the agencies to deal with serious or urgent pest control issues as
a situation warrants. Using an IPM, the General Services Agency Landscape/Custodial
division has realized an approximate 80% reduction of harmful chemicals. Using IPM
strategies of the City of Santa Barbara, among others, GSA plans to strive towards
further chemical reductions in the future.

I. Mission Statement

It is the mission of the County of Ventura IPM Strategy to promote environmentally
sensitive pest management while preserving assets and protecting the health and
safety of the public and our employees. All costs and impacts associated with pesticide
use, including community and environmental health, will be considered. The following
IPM Strategy describes the County’s goals and demonstrates how the County will achieve
these goals.

II. Purpose

The purpose of this IPM strategy is to establish methodology that the County can
apply to:

  • Reduce and eliminate to the greatest extent possible, the use of pesticide products
    that pose known, likely, or probable human health or environmental risks;
  • Promote the use of non-hazardous and/or reduced risk alternatives that are protective
    of human health and the environment;
  • Apply pesticides in a manner that protects and enhances our region’s natural resources
    and public health;
  • Pesticide use as a model of environmental stewardship in the eyes of the public;
  • Maintain a leadership role in developing both ecologically sensitive and aesthetically
    pleasing landscapes and structures;
  • Practice a consistent standard of environmental stewardship by departments managing
    structures, landscapes, and other grounds;
  • Establish a program where pesticides categorized as toxic or persistent (Tier 1)
    are only used when there is a threat to public health, safety or the environment,
    or when use is warranted to prevent economic damage and only after other alternatives
    have been implemented and shown to be ineffective or considered and found infeasible;
  • Establish a clear criteria for pesticide use, to reduce the amount and toxicity
    of pesticides and eliminate pesticide use on County property and where feasible.

This IPM Strategy also provides for periodic re-evaluation of pesticides used by
the County. The Strategy which outlines pesticides that are being used in all departments,
and will allow employees involved in pesticide use to make conscious decisions about
the control mechanism selected, to employ the of use pesticides wisely, and to make
full use of pesticides purchased. All departments responsible for overseeing construction
projects; managing County-owned structures, grounds, landscapes; and purchasing
and/or using pesticides are affected. In addition, all contractors that are applying
pesticides on the County’s behalf will be required to subscribe to the IPM Strategy.
Disinfectants used to protect human health are excluded from this strategy and the
IPM.

III. Definitions

Contract: A binding written agreement requiring the services of
an outside provider for grounds maintenance or any pest control related services
or services that may include pest control activities.

Contractor: A person, firm, corporation, or other entity, including
a governmental entity, that enters into a contract with a department.

Emergency: A pest outbreak that poses an immediate threat to public
health or significant economic or environmental damage.

Hazardous Material: A chemical or mixture that may pose a physical
hazard, health hazard, or environmental hazard and that is regulated under the law
to control its harmful effects. This definition is not intended to be rigid or legalistic
because all materials regulated in this manner merit special attention and consideration
under this program.

IPM Committee: Is the working group consisting of representatives
from each County agency/department designated as the IPM Coordinator, and other
department representatives as deemed appropriate by individual departments involved
in the IPM strategy implementation. This committee shall be responsible for guiding
the individual agency-wide implementation of the approved IPM strategy. The IPM
committee shall meet a minimum of four times per year for the purpose of information
sharing and collaboration.

IPM Coordinator: Individual designated for those departments that
apply pesticides or contract with pesticide applicators. The GSA Facilities &
Maintenance (F&M) (Special Services Manager) is the individual to coordinate
these activities on a countywide basis and to serve as the primary point of contact.
The IPM coordinator(s) shall be trained in the principles of low risk IPM, safe
application of pesticides, and alternatives to pesticide use.

The IPM Coordinator shall be responsible for:

1. Coordinating efforts to adopt IPM techniques.
2. Communication with all staff on the goals and guidelines of the program.
3. Coordinating training programs for staff.
4. Facilitating meetings with the IPM Committee.
5. Coordinating with other public agencies that are practicing IPM programs.

Integrated Pest Management (IPM): A decision-making process for
managing pests that uses monitoring to determine pest levels and tolerance thresholds
and combines biological, cultural, physical, and chemical tools to minimize health,
environmental, and financial risks. The method uses extensive knowledge about pests,
such as infestation thresholds, life histories, environmental requirements, and
natural enemies to compliment and facilitate biological and other natural control
of pests. The method uses the most toxic pesticides only as a last resort and includes
the following guiding principles.

1. Monitor each pest ecosystem to determine pest population, size, occurrence, and
natural enemy population, if present. Identify decisions and practices that could
affect pest populations. Records of all such monitoring shall be kept.
2. Set threshold and action levels. The threshold level refers to the point where
a pest problem causes an unacceptable impact. The action level is the level of vegetation
or pest population at a specific site at which action must be taken to prevent the
population from reaching the threshold level.
3. Consider a range of potential treatments for the pest problem. Employ non-chemical
management tactics first. Consider the use of chemicals only as a last resort, select
and use the least toxic formulation effective against the target pest, and use pesticides
only in accordance with other provisions of this strategy.
4. Monitor treatment to evaluate effectiveness. Such monitoring records shall be
kept.
5.Ongoing education of the public.
6. Special circumstances, i.e. protection of botanical specimen, or other mitigating
factors may allow exemptions to the process outlined above.

Landscapes: Grounds that are actively managed such as parks, plantings,
lawns around public buildings, right-of-ways, watersheds, orchards, and open space,
etc., excluding large tracts of forestland.

Tiered Materials List: List of pesticides classified into four
tiers on the basis of their hazard potential, updated annually by the IPM Committee.
All pesticides considered for use by County departments are screened through the
hazard criteria and will fall into one of the following tiers:

Tier 1: Highest concern
Tier 2: Moderate concern
Tier 3: Lowest concern
Tier 4: Insufficient information available to assign to above tiers

Pesticide Free Zones: A site or area within a site so designated
as a “Pesticide Free Zone” by specific departments in order to further reduce and
eliminate pesticide use in areas of higher public exposure or areas with high environmental
sensitivity.

Pesticide: Any substance, or mixture of substances, used for defoliating
plants, regulating plant growth, or for preventing, destroying, repelling, or mitigating
any pest, which may be detrimental to vegetation, humans, or animals.

Sustainable Design, Construction, and Maintenance: Principles,
materials, and techniques that conserve natural resources and improve environmental
quality throughout the life cycle of the landscape and its surrounding environment.
Sustainable designs for buildings and landscapes incorporate methods that reduce
the potential for pest problems from the start and with long-term maintenance needs
in mind.

Toxicity Category I Pesticide Product: Any pesticide product that
meets United States Environmental Protection Agency criteria for Toxicity Category
I under Section 156.10 of Part 156 of Title 40 of the Code of Federal Regulations.

Toxicity Category II Pesticide Product: Any pesticide product that
meets United States Environmental Protection Agency criteria for Toxicity Category
II under Section 156.10 of Part 156 of Title 40 of the Code of Federal Regulations.

IV. Descriptions of Roles and Responsibilities

• Department Head
• Departmental IPM Coordinator
• IPM Committee

Department Head: Department Heads shall be responsible for:

1. Ensuring that departmental procedures, budget, and staffing decisions support
implementation of the IPM Strategy.
2. Providing training to grounds management staff in the requirements of this IPM
Strategy.
3. Designating an Integrated Pest Management Coordinator to ensure products used
by the Department meet the standards outlined in this IPM Strategy and represents
the Department on the IPM Committee.

Establishing an Integrated Pest Management Coordinator: Each department
will be responsible for designating an Integrated Pest Management Coordinator. Departments
will be responsible for providing Integrated Pest Management training in addition
to opportunities for the Coordinator and other employees responsible for pest management.

The Coordinator will be responsible for:

1. Managing the IPM program for the Department.
2. Attending meetings of the IPM Committee.

IPM Committee: This advisory committee is responsible for:

1. Meeting on a regular basis to review and discuss pest management practices.
2. Identifying the types of pest problems that have been encountered.
3. Identifying the alternatives currently used for phased out pesticides.
4. Identifying planned changes to pest management practices.
5. Evaluating the effectiveness of any changes in practice implemented.
6. Discussing any IPM Committee dissentions on any issues.
7. Developing, adopting, and periodically reviewing the Tiered Materials List.
8. Reviewing emergency pest control decisions.
9. Investigating low-risk/least hazardous alternatives to conventional treatments.
10. Assisting departments in implementing the IPM Strategy by developing educational
information for staff and vendors about IPM plans and programs.
11. Annually reviewing the written IPM Strategy and recommending appropriate revisions
to ensure the program meets the intended purpose and goals of IPM.

The Committee is made up of IPM Coordinators, vendor representatives and staff involved
in the day-to-day operations and oversight of pest management operations. The Committee’s
role is supportive of the IPM Coordinator.

IPM Committee: The committee shall consist of GSA Parks, Ventura
Sheriff’s Department, Todd Road Jail, Public Works Administration Roads, GSA F&M,
Department of Airports and the Department of Harbors.

V. Notification:

Any department that uses pesticides shall comply with all Federal, State and Local
rules and regulations for notification and record keeping.

VI. Tiered Materials List and Exemption Process

The IPM Committee shall develop a tiered risk assessment of pesticides. A prioritized
list of materials will be developed to identify materials that may be targeted for
IPM Committee review of the product’s contents, precautions, need for the product,
and adverse health and environmental effects. The IPM Committee will make product
recommendations and establish and prioritize the Tiered Materials List for future
materials phase out. The lists shall be distributed to committee members for their
use and to the Resource Management Agency for their information.

Criteria for developing materials lists shall be based on acute and chronic toxicity
of products and chemicals known to cause cancer and known to cause reproductive
toxicity. Environmental impacts of the products shall also be considered. The approved
materials list shall screen pesticides for the following risk parameters:

A. Acute Toxicity: The potential for a pesticide to cause immediate
harm.

1. Hazard Category: Each pesticide product registered by EPA is
assigned hazard category I, II, III, or IV by the Agency based on characteristics
of the full product formulation, including acute toxicity, and skin and eye irritation.
In evaluating the acute data, EPA assigns the hazard category based on the greatest
hazard, i.e. ingestion, inhalation, skin absorption, eye irritation, etc.

The table below shows the toxicity ranges that apply for each category. (Note: LD50
indicates lethal dose 50%; LC50 indicates lethal concentration 50%.) A relatively
non-toxic product (via ingestion, inhalation, or skin absorption) could be placed
in the highest hazard category merely on the basis of extreme eye irritation. Products
in category I are most hazardous and bear the signal word DANGER on their labels.
Those in category II are labeled WARNING. Both category III and IV products are
labeled with CAUTION. Product category was determined from label signal words, and
category III and IV products were not distinguished from each other.

EPA Category I II III IV Signal Word DANGER WARNING CAUTION CAUTION Oral LD50 (mg/kg
body wt) Less than 50 Between 50 and 500 Between 500 and 5000 More than 500 Inhalation
LC50 (mg/liter air) Less than 0.2 Between 0.2 and 2 Between 2 and 20 More than 20
Dermal LD50 (mg/kg body wt) Less than 200 Between 200 and 2,000 Between 2,000 and
20,000 More than 20,000 Eye Effects: Corrosive Non-reversible opacity Severe irritation
Reversible opacity Persisting 7 days Moderate irritation No opacity Reversible 7
days No irritation Skin Effects: Corrosive Severe irritation Moderate irritation
Mild irritation

2. Restricted Use Pesticides: Some pesticides are restricted for
use by the state to only certified pesticide applicators and are not available to
the general public because of high toxicity, particularly hazardous ingredients,
or environmental hazards.

B. Chronic Toxicity: The ability of the pesticide to cause long
lasting harm.

1. Carcinogens (active ingredients only): For the purposes of the
County of Ventura IPM Strategy, this will include all pesticides on the State of
California Environmental Protection Agency Office of Environmental Health Hazard
Assessment Safe Drinking Water and Toxic Enforcement Act of 1986 list of Chemicals
Known to the State to Cause Cancer or Reproductive Toxicity.

2. Reproductive/Developmental Toxicants (active ingredients only):
“Chemicals known to the State of California to cause cancer or reproductive toxicity.”
The source used for the development of the Materials Phase-Out List is the State
of California Environmental Protection Agency Office of Environmental Health Hazard
Assessment Safe Drinking Water and Toxic Enforcement Act of 1986 list of Chemicals
Known to the State to Cause Cancer or Reproductive Toxicity.

3. Endocrine Disruptors (active ingredients only): These are pesticides
with the ability to mimic or block the effects of hormones in humans and other wildlife.
Because of the similarity of the endocrine system across many species, its critical
role in development and reproduction, and its extreme sensitivity to very low levels
of hormone-like compounds, there is the potential for endocrine disrupting substances
in the environment to adversely affect wildlife and humans. Although the science
is relatively new and in many cases highly controversial, considerable evidence
of effects in wildlife and some evidence in humans have caused many scientists to
warn of potential dangers from exposure to endocrine disrupting chemicals. Under
the Food Quality Protection Act, the EPA is required to screen pesticide ingredients
for endocrine system effects. Until that screening is done, a comprehensive list
of endocrine disruptors will not be available. For the purpose of this strategy
development, the source used for the development of the Tiered Materials List is
the State of Illinois Environmental Protection Agency list of known, probable, or
suspected of causing endocrine system effects (Illinois EPA Endocrine Disruptors
Strategy, February 1997.).

4. Ecotoxicity (active ingredients only): Based upon the required
precautionary statements on product labels, pesticides that warn of potential toxicity
to non-target wildlife species will be considered in the development of the Tiered
Materials List. Of primary concern is toxicity to: • Birds • Aquatic Organisms •
Bees • Other wildlife or domestic animals

5. Persistence: Pesticides are considered to be persistent if their
half-lives exceed 100 days. For the purposes of the approved materials list, the
Oregon State University Extension Pesticide Properties Database, the Agricultural
Research Service/US Department of Agriculture Pesticide Properties Database or Hazardous
Substances Databank will be used in that priority.

6. Water Pollution Hazard (active ingredients only):

• Leaching potential
• Runoff potential

The Ground Water Ubiquity Score (GUS) index is used to identify those pesticides
that have a high potential to contaminate the ground water.

Ranking by Tiers: Materials will be classified into tiers on the
basis of their hazards.

Tier Definitions:

Tier 1: Highest concern
Tier 2: Moderate concern
Tier 3: Lowest concern
Tier 4: Insufficient information available to assign to the above tiers

The criteria for assigning materials to tiers are as follows:

Tier 1: (Any of the following are true)

  • Products in EPA Hazard Category 1, Signal Word DANGER
  • Restricted use pesticides
  • Products with known, likely, or probable carcinogens as active ingredients (EPA
    list of Chemicals Evaluated for Carcinogenic Potential classified as Carcinogenic
    To Humans, and Likely To Be Carcinogenic To Humans)
  • Products with reproductive toxicants as active ingredients (CA Prop 65 list)
  • Products with known or probable endocrine disrupters as active ingredients
  • Products labeled as highly toxic or extremely toxic to birds, aquatic species, bees,
    or wildlife
  • Products with active ingredients with soil half lives greater than 100 days (not
    applicable to products used only indoors on to products used in bait stations)
  • Products with active ingredients with mobility ratings high or very high or with
    specific label warnings about groundwater hazard (Not applicable to products used
    only indoors on to products used in bait stations)
  • Products containing the rodenticides brodifacoum, bromethalin, or bromadionone

Tier 2:

  • All products not assigned to Tier 1 or Tier 3

Tier 3: (All of the following are true)

  • Product contains no known, likely, or probable carcinogens
  • Product contains no reproductive toxicants (CA Prop 65 list)
  • Product contains no ingredients listed by Illinois EPA as known, probable, or suspect
    endocrine disrupters
  • Active ingredients has soil half-life of thirty days or less
  • Product is labeled as not toxic to fish, birds, bees, wildlife, or domestic animals

Tier 4: Not enough information

The Tier 1 list of pesticides will be used by the IPM Committee to determine future
product elimination.

C. Establishing “Pesticide Free Zones”: Pesticide Free Zones are
sites or areas within a site established to be free of pesticide applications. The
following have been established as Pesticide Free Zones.

  • Playgrounds – No pesticides will be applied within 100 feet of playgrounds unless
    an emergency situation arises.
  • Picnic Areas – No pesticides will be applied within twenty-five feet of picnic facilities
    unless an emergency arises.

The IPM Committee will base decisions to add to the list of Pesticide Free Zones
upon monitoring the effectiveness of alternatives and other factors. It is the intention
over time to expand these zones as time and resources allow.

VII. Record Keeping

(a) Each department that uses pesticides shall keep records of all pest management
activities whether applied by a vendor or a county employee. Each record shall include
the following information:

(1) The target pest;
(2) The type and quantity of pesticide used;
(3) The specific location of the pesticide application;
(4) The date the pesticide was used;
(5) The name of the pesticide applicator;
(6) The application equipment used
(7) Prevention and other non-chemical methods of control used;

VIII. Training

Increasing knowledge of staff and contractors who design and maintain buildings
and landscapes is critical to the success of the IPM Program. Consequently, providing
ongoing training and educational opportunities to County staff and contractors regarding
building and landscape IPM concepts, practices, and products will be a priority.

The IPM Coordinator shall invite speakers and arrange for other educational opportunities
to assist departments in implementing the IPM Program each year. Department Directors
shall ensure that IPM Coordinators inform employees on departmental policies and
procedures relevant to this IPM Program and keep staff current with best landscape-management
practices and technologies that utilize Integrated Pest Management. Department Directors
shall also support employee involvement in identifying and implementing strategies
to minimize the use of pesticides and in evaluating replacements to chemicals targeted
for phase-out.

  • All staff associated with planning, design, construction, and maintenance of buildings
    and landscapes shall receive an orientation to the IPM Strategy and their roles
    and responsibilities in implementing it in a written or verbal format.
  • All personnel involved in pest management activities shall receive training on:
  • IPM Strategy.1. Identification and lifecycles of typical southern California pests, weeds and
    beneficial insects; determining threshold levels for different types of landscapes;
    monitoring techniques; and strategies for successful management of these pests
    2. Noxious weed identification, control, and regulations
    3. Pesticide laws and safety
    Specific best management practices as appropriate

Training will be provided by County staff, IPM consultants, IPM technical advisors,
and invited guest speakers. The IPM Coordinator, with assistance from the IPM Committee,
will schedule training. Training and educational opportunities, both formal and
informal, will also occur at landscape staff meetings. Managers and supervisors
are not only expected to participate in the training, but to fully support involvement
of their staff and contractors in the training.

In making landscaping staffing and budget decisions, departments shall consider
the potential environmental tradeoffs; for example, will reduced staffing require
increased use of pesticides to maintain the landscape at the same standard? Will
short-term IPM expenditures result in long-term savings?

IX. New Construction and Landscape Projects

Poorly planned landscape designs may require intensive maintenance and greater reliance
on pesticides for pest control than landscapes created with integrated pest management
design specifications.

Departments participating in a County project that includes the design of new landscape
or renovation of an existing one shall design and construct the project consistent
with IPM design specifications. The IPM Coordinator for each department will review
all project plans to ensure that, where possible, the design considers IPM measures
and the following strategies.

In planning, designing, and installing landscape owned and managed by the county,
site objectives shall include future management and maintenance practices that protect
and enhance natural ecosystems. A landscape, facility, or road right-of-way should
be planned and designed taking into account parameters that will enhance the intended
use of the land and minimize pest problems. Design will take into account such factors
as types of uses, soils, grading and slope, water table, drainage, proximity to
sensitive areas, selection of vegetation, and vector control issues. County grounds
designers, planners, managers, crews, and their contractors shall give priority
to IPM strategies when designing new and renovating existing landscaped areas. These
include:

  • Using proper soil preparation and amendment
  • Specifying weed-free soil amendments
  • Using mulches to control weeds, conserve water, and build healthy, biologically
    diverse soils
  • Use weed control fabrics under organic mulches
  • Use site adapted and pest resistant plants: “the right plant for the right place”
  • Group together plants with similar horticultural needs
  • Retain and use regionally native trees, shrubs, and perennials where appropriate,
    preferably from genetic stock
  • Pre-plant control of noxious weeds and invasive, non-native plant species
  • Plant for erosion and weed control
  • Assess whether landscapes can still meet the intended site use objectives while
    modifying the aesthetic standard and/or applying less maintenance
  • Match maintenance standards to site objectives in the design stage
  • Construct walkways so as to prevent weed intrusion;
  • and Plant vegetation that will encourage the presence of beneficial insects and
    birds

X. Contractors

When a Department enters into a new contract or extends the term of an existing
contract that authorizes a contractor to apply pesticides to property, the contract
shall obligate the contractor to comply with all provisions of this IPM Strategy.
In addition, the contractor shall submit to the County an IPM implementation plan
that lists:

  • The types and estimated quantities, to the extent possible, of pesticides that the
    contractor may need to apply to property during its contract;
  • Outline actions the contractor will take to meet the IPM Strategy to the extent
    feasible; and
  • Identify the primary IPM contact for the contractor.

XI. Precautionary Principle

It is the policy of the County to adopt, properly implement and practice low risk/least
hazardous Integrated Pest Management with the goal of immediately minimizing the
risk of pesticide exposure to staff, the environment, and the public. This strategy
is based on what is referred to as the ‘Precautionary Principle’ (see description
below) of pest management. The guiding principles in this strategy are based on
the following:

(1) No pesticide is free from risk or threat to human health

(2) All reasonable alternative measures of pest management have been attempted and
have been shown, and documented in writing, to be unsuccessful,

(3) Pesticides suspected of being in conflict with the mission and goals of this
strategy shall not be used without an exemption, or until it is determined that
a specific product is safe for use around sensitive individuals (i.e. children,
elderly, asthmatics, etc.).

The Precautionary Principle should guide decision-making processes when it comes
to the health and safety of staff and public. All aspects of the program will be
in accordance with federal and state laws and regulations and county policies. All
departments within the County must conform to the IPM Strategy.

“The Precautionary Principle requires a thorough exploration and a careful analysis
of a wide range of alternatives. Based on the best available science, the Precautionary
Principle requires the selection of the alternative that presents the least potential
threat to human health and the County’s natural systems. Public participation and
an open and transparent decision making process are critical to finding and selecting
alternatives.

Where threats of serious or irreversible damage to people or nature exist, lack
of full scientific certainty about cause and effect shall not be viewed as sufficient
reason for the County to postpone cost effective measures to prevent the degradation
of the environment or protect the health of its citizens. Any gaps in scientific
data uncovered by the examination of alternatives will provide a guidepost for future
research, but will not prevent the County from taking protective action. As new
scientific data become available, the County will review its decisions and make
adjustments when warranted.

Where there are reasonable grounds for concern, the precautionary approach to decision-making
is meant to help reduce harm by triggering a process to select the least potential
threat. The key elements of the Precautionary Principle approach to decision-making
include:

1. Anticipatory Action: There is a duty to take anticipatory action to prevent harm.
Government, business, and community groups, as well as the general public, share
this responsibility.
2. Right to Know: The community has a right to know complete and accurate information
on potential human health and environmental impacts associated with the selection
of products, services, operations or plans. The burden to supply this information
lies with the proponent, not with the general public.
3. Alternatives Assessment: An obligation exists to examine a full range of alternatives
and select the alternative with the least potential impact on human health and the
environment including the alternative of doing nothing.
4. Full Cost Accounting: When evaluating potential alternatives, there is a duty
to consider all the reasonably foreseeable costs, including raw materials, manufacturing,
transportation, use, cleanup, eventual disposal, and health costs even if such costs
are not reflected in the initial price. Short- and long-term benefits and time thresholds
should be considered when making decisions.
5. Participatory Decision Process: Decisions applying the Precautionary Principle
must be transparent, participatory, and informed by the best available science and
other relevant information.”

Reference Documents:

1. Santa Barbara Integrated Pest Management Plan
2. Code of Regulations, Title 40, Section 156.10 of Part 156
3. Board of Supervisor letter dated October 23. 2007
4. Illinois Environmental Protection Agency (EPA) Endocrine Disrupters Strategy
of February 1, 1997
5. EPA Safe Drinking Water and Toxic Enforcement Act of 1986
6. Oregon State University Extension Pesticide Properties Database
7. Agricultural Research Service/US Department of Agriculture Pesticide Properties
Database
8. California Prop. 65 list
9. Federal Insecticide, Fungicide, and Rodenticide Act, 1996