Pesticide Use and the Harvard Stormwater Program (Best Management Practices):
The use of herbicides, insecticides and rodenticides at Harvard University is a matter of environmental concern. These pesticides have the potential to end up in drinking water and in other aquatic systems if not managed properly.
To minimize exposure to public health and to the environment, the Environmental Health & Safety department has developed these guidelines, or best management practices (BMP's), for pesticide applications by in-house staff and by outside pest control contractors. These guidelines follow Integrated Pest Management (IPM) principles of employing natural and physical controls, and when necessary, using the least toxic chemicals.
Authorizing the Application of Pesticides
Before any contractor or in-house staff member applies pesticides at Harvard University, prior approval must be obtained from the facility manager. For each chemical submitted for approval, a sample pesticide label and material safety data sheet should be provided.
The Environmental Affairs department can assist facility managers in making a determination on pesticide efficacy and safety. Pesticide amount, date, concentration and related records are required for all chemical applications and may be requested at any time.
Pollution prevention principles and Harvard's Storm Water Pollution Prevention Plan (SWPPP) requires that we annually review the amount and rationale for chemical pesticides applied at Harvard University. A conference between EH&S staff, facility managers and pest control applicators at the end of each calendar year will help to evaluate ways of reducing the amount, concentration, and application schedule of pesticides.
The following best management practices should be applied when appropriate:
1. Inclement Weather
Weather conditions can adversely affect the efficacy of chemical treatments. During the application of pesticides, the wind velocity should be less than 5 miles per hour to avoid unnecessary drift onto non-target sites. If it is raining or about to rain, pesticide applications should be re-scheduled to avoid unnecessary runoff. And importantly, during applications, chemicals should never be applied to the point of runoff.
2. Runoff Control
Storm drains should be identified, stenciled and mapped as part of Harvard's stormwater management program. Storm drains in the immediate vicinity of pesticide application areas or drains that could potentially be impacted by runoff, must be located and covered during treatment to prevent the release of pesticides to nearby water bodies (e.g. Charles River, Muddy River, etc).
3. Drift Control
The use of power sprays to reach the upper canopy of trees should be minimized to prevent pesticide drift into buildings and into water bodies. For this reason, trees located along the Charles River should not be power sprayed with insecticides. Alternative control measures such as the injection of systemic insecticides for control of Dutch Elm beetle should be fostered.
4. Preventative Applications
The widespread use of dormant oils, and herbicides on shrubs and trees should be justified by the existence of potential pest outbreaks. The Commonwealth of Massachusetts requires notification and posting during application of lawn pesticides. Preventive applications should be scaled back to reduce unnecessary treatments since a healthy lawn is the best control for pests.
5. Application of Rodenticides
Anticoagulants, tracking powders, and other mammalian toxicants must be placed in locations that will not result in their translocation to aquatic habitats. If rodent burrows are treated, they should not be located along the banks of rivers and streams.
6. Application of Termiticides Into the Ground.
The application of termiticides must not be in an area near a well, stream or other water source. The chemical soil barrier effective for termite control requires the application of quantities of chemicals to the soil below the foundation. Wooden stakes impregnated with toxicants can be used as baits for termite control and should be fostered as an alternative to soil treatment.
7. Transportation of Pesticides
As required by 333 CMR 10.0, all pest control vendors must ensure that the following provisions are complied with in relation to the transport of a pesticide in the course of the pest controller's business:
- The container of pesticide must be kept securely sealed;
- The container must be securely fastened to the vehicle used to transport the pesticide;
- The pesticide must not be left in an unattended vehicle unless the vehicle has an enclosed storage facility that forms part of or is permanently fixed to the structure of the vehicle and the pesticide is kept securely locked in that storage facility;
- Where a pesticide is transported in a spray tank the spray tank must:(a) be securely sealed; (b) form part of or be permanently fixed to the structure of the vehicle being used to transport the pesticide; and (c) be prominently marked with the words "WARNING" OR "POISON", and the name of the pesticide product.
- The vehicle used for pest control must: (a) be designed so that the transported pesticide is separated from the driver/operator by a barrier impervious to the pesticide; (b) not be left on-public land when not in use; (c) be securely garaged in such a manner as to restrict public access when the vehicle is not in use; (d) be washed down on a grassed area and under no circumstances should the wash water be allowed to enter the stormwater or sewage system;
8. Pesticide Spills
Any pest control operator who observes any accident or spillage that involves a pesticide must report the accident spillage to the EH&S Department as soon as practicable after the accident or spillage occurs. This is in addition to and does not limit or affect any other requirements to report an accident or spillage to the fire, police, or other regulatory agency.
9. Pesticide Disposal
All empty pesticide containers and unwanted pesticides must be disposed of in accordance with product label instructions.
