2109.14,50 Page 1 of 7 FSH 2109.14 - PESTICIDE-USE MANAGEMENT AND COORDINATION HANDBOOK WO AMENDMENT 2109.14-94-1 EFFECTIVE 12/06/94 CHAPTER 50 - QUALITY CONTROL MONITORING AND POST-TREATMENT EVALUATION 51 - GENERAL CONSIDERATIONS. Pesticide coordinators, incident commanders, and pesticide project directors must ensure that project objectives are met and pesticides are applied safely, without unforeseen adverse effects on nontarget components in the environment. Use quality control monitoring to: 1. Ensure the success of pesticide projects by monitoring the application procedures and measuring the impact of the pesticide application on target and nontarget components of the environment during and after the application to include accidental exposure to employees and the public; 2. Alert project personnel of possible unforeseen impacts or conditions during a project and the need to measure the magnitude of such impacts or conditions; and 3. Determine the extent, severity, and probable duration of hazards from a pesticide misapplication or incident. 52 - TYPES OF QUALITY CONTROL MONITORING. Monitor application equipment, pesticide label compliance, drift management, and residue monitoring. 52.1 - Checking Application Procedures. Ensure pesticides are used in accordance with project plans. Project/incident commanders must verify equipment is used according to manufacturer's guidelines, the equipment is properly calibrated (within plus or minus 5 percent of optimum) and maintained, and the appropriate pesticide volume is applied to the target area. Corrective actions must be taken when there are deviations from the project safety or work plans (sec. 14.3 and 16.1). 52.11 - Label Compliance. Determine label compliance. Pesticides can be used only by qualified Forest Service personnel if the manufacturer's EPA-approved label is followed (FSM 2150). Pesticide use inconsistent with a label is a violation of Federal law (Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136)) except for the following: 1. Applying a pesticide at any dosage, concentration, or frequency less than that specified on the labeling; 2. Applying a pesticide against any target pest not specified on the labeling if the application is to the crop, animal, or site specified on the labeling, unless it specifically states on the label that the pesticide can only be used for listed pests; 3. Employing any method of application not prohibited by the labeling; and 4. Mixing a pesticide or pesticides with a fertilizer when such mixture is not prohibited by the labeling. 52.12 - Equipment Usability. Frequent inspection of equipment condition is an important aspect of pesticide application quality control. Check equipment for cleanliness, loose nuts and bolts, valves, screens, filters, gauges, and hoses. Attend to leaks immediately and repair or replace worn parts. 52.13 - Volume of Pesticide Used. Monitor the pesticide application volumes on an area basis to ensure appropriate application rates. Application volumes that are greater or less than intended may mean that the application equipment is malfunctioning, that the calibration is incorrect, or that the application is incorrect, such as overlap of swaths. Corrective action must be taken immediately whenever the volume of pesticide used is inconsistent with either the pesticide label or the project work plan (sec. 14.3). 52.14 - Monitoring Flight Pattern. Pesticide spray models can be used (sec. 15.2) to calculate effective swath widths. Once model runs have been completed, they can be checked in the field during aircraft calibration and characterization. Monitoring the flight pattern of aerial application craft is another method of quality control. Observation or chase aircraft may be used to monitor swath patterns of application. Use of electronic monitoring and regulating systems to monitor, control, and document pesticide applications is encouraged. 52.2 - Spray Deposition Accountability. Determine if the spray reached the target. Visual assessment of foliage deposit samplers (cards) or field assessment of water/soil can provide qualitative means of spray accountability. 52.21 - Spray Deposit Assessment. Two important factors influencing the effectiveness of aerial pesticide application are the quantity and uniformity of spray deposition over the spray area. Many factors influence the deposit of pesticides, including skill of the applicator, pesticide formulation, adjuvants, drop size and atomization, spray release height, weather, canopy, and target site location. The evaluation of the numbers and sizes of spray droplets on deposited surfaces is called spray deposit assessment. Kromekote paper, water sensitive paper, and oil sensitive paper cards are commonly used in spray assessment. Assessment of spray deposit allows project monitors to: 1. Check operation of the spray equipment, make adjustments of spray equipment, and calibrate the flow rate to get uniform, consistent spray patterns and target coverage; 2. Determine the relative quantities of pesticide that are deposited on the target area and drift from the target; 3. Determine relative droplet size to achieve maximum coverage and to minimize drift; and 4. Maintain a record of spray coverage and distribution for the project file for future evaluation of results. 52.22 - Drift Reduction. Aerial application of pesticides can result in drift offsite. To prevent drift, consider the following factors: 1. Influence of Droplet Size on Drift. The smaller droplets fall more slowly and are more prone to drift than larger droplets. As a spray droplet falls, it continually evaporates, thus reducing its rate of fall and increasing its drift potential relative to its initial size. 2. Atmospheric Conditions. One of the most important and complicated factors in managing drift is understanding how weather affects sprays. The most important atmospheric factors influencing drift are the wind speed and direction and the relationship between air temperature and altitude. Analyze spray behavior using aerial application models (sec. 15.2) to estimate the influence of these factors. 3. Tank Mix. The final mix placed in the aircraft hopper is referred to as the tank mix. Mixes with a high percentage of water are subject to rapid evaporation when atomized. Low volatile mixes are usually less prone to drift. 4. Method of Application. Flying height should be as low as safety permits. This may be 10 to 50 feet above the vegetation. As flying height increases, spray droplets remain suspended longer and are more susceptible to wind and evaporation. Selection of proper aerial application equipment is as important as selecting the proper pesticidal formulation. In fact, significant improvements can be made in reducing drift from normal formulations through use of proper spray delivery systems. 5. Atomization of Spray. A major factor influencing amount and distance of drift is spray droplet size. The greatest potential for reducing drift hazard is through reduction of small (less than 100-micrometer diameter) droplets. Whenever possible, this should be done by reducing the range of sizes produced rather than by increasing average drop size, since large droplets can result in poor plant coverage. The range of atomization (production of small droplets) is influenced by several factors including the amount of boom pressure, nozzle type, nozzle location on boom, shear across nozzle orifice, aircraft speed, and physical properties of the tank mix. a. Boom Pressure. Generally the higher the pressure the finer the atomization. b. Nozzle Type. Usually the smaller the orifice the smaller the droplets. Other nozzle factors affect the degree of atomization, such as pathway of the discharge channel and use of whirl plates in the "T-Jet" hollow- cone nozzles. c. Shear. Shear across the nozzle orifice causes droplet breakup. Shear increases as the aircraft speed increases. d. Nozzle Location on Boom. Strong vortices are created during flight by helicopter rotors or the wings of fixed- wing aircraft. Droplets entrained in these vortices are propelled upwards in a circular pattern under high velocities. Droplets trapped in this motion may drift long distances. To reduce this phenomenon, it is recommended that booms do not exceed 75 percent of the rotor diameter or wing span of the aircraft. e. Physical Properties of Tank Mix. Various types of additives or adjuvants added to the tank mix will affect atomization and evaporation. Consult the label, a technical representative, or Forest Service specialist regarding the effects of additives or adjuvants and their selection. 6. Topography. Topography of the treatment site and surroundings must be considered in planning and scheduling spray operations. Most treatment sites are on sloping ground. Spray applied to slopes during early morning under inversion and stable conditions will drift downslope. Spray applied after the sun has warmed the surface (sometimes within a few minutes after sunrise) will move upslope with the wind. There is little potential for build-up of pesticides in canyons and valleys under lapse conditions. Warm air rises and as it ascends, fine drops are carried aloft and diluted in the atmosphere. 52.3 - Pesticide Residues Monitoring. Determine which pesticide projects require residue monitoring on a case-by-case basis. Residue monitoring requirements must be documented in an implementation plan and should be based on direction in an environmental assessment and decision document. On controversial operational pesticide projects, residues monitoring may be used to determine the presence or absence of unacceptable environmental effects. On field experiments and pilot control projects, residue monitoring may be required to secure registration. Monitoring sample points should be determined when monitoring plans are developed for such projects. The number of samples varies with statistical requirements and specific conditions of the project area. The need for pesticide residue monitoring and specific sampling protocol should be identified in the project work plan. Whenever necessary, pesticide residue sampling can be used to measure the accumulation, movement, and degradation of pesticides following introduction into the environment. Residue monitoring activities may include monitoring pesticides or their degradation products in air, soil, water, vegetation, aquatic and terrestrial animals, and/or humans. 52.31 - Air. Monitoring air currents and wind speed during pesticide projects permits on-site adjustment of spray strategies to minimize the effects of wind on spray deposit both on and off- site (drift). 52.32 - Soil. Monitor soils in and adjacent to treatment sites before and after pesticide applications and where spills or emergency dumps of pesticides have occurred. 52.33 - Vegetation. Use vegetation monitoring procedures to check residues in or on target and non-target vegetation. 52.34 - Animals. 1. Aquatic. In some instances, such as during aerial pesticide applications, extensive monitoring of aquatic organisms may be necessary. Outline such procedures in a monitoring plan. 2. Terrestrial. Conduct post-treatment surveys for dead or distressed animals on a case-by-case basis. If such animals are found, they should be: a. Collected and sent to an appropriate laboratory for residue analysis, or b. Buried if such impacts have been predicted, as in the use of rodenticides. Use the results to determine if unanticipated impacts on terrestrial animal species have occurred. 52.35 - Humans. Use health monitoring to determine pesticide exposure and to protect human health. Monitor human health parameters on a case-by-case basis, depending on the type of pesticide used and the health risk indicated. Sampling urine during organic arsenical pesticide operations or sampling blood cholinesterase levels during organophosphate pesticide operations are examples of human monitoring activities. If human monitoring is conducted, monitor pre-exposure conditions to establish baseline conditions. Maintain records of personal medical analyses as confidential portions of the employee's file in accordance with Privacy Act requirements (FSH 6209.13) and occupational safety and health requirements (29 CFR 1910.20). 52.36 - Water. Conduct water quality monitoring to determine if water contamination has occurred as a result of pesticide applications or incidents and if so, to what extent. The objectives of water monitoring are to: 1. Determine if application procedures are adequate and that only acceptable levels of pesticides, if any, appear in water; or 2. Provide early warning of pesticide contamination on areas such as municipal watersheds, fish hatcheries, or near private domestic water supplies. Sample points for water are normally established near downstream boundaries of treatment areas. If a spill occurs in or near water, additional monitoring may be required. Notify appropriate State and local agencies, if the spill represents a significant human health or environmental threat. Outline contingency plans for such an occurrence in the project safety plan (sec. 16.1). The contamination of water by pesticides is a function of various factors that may operate singly or in combination during and/or after a project. Before a water quality monitoring plan can be written, the monitoring objectives must be specified. A complete set of objectives provides reasons for the parameters to be monitored, and when, how long, and where monitoring will occur. The monitoring plan should focus on the management need for specific information to answer questions or solve problems. The plan must also be technically feasible and within constraints of time, personnel, and funding. 53 - GENERAL CONSIDERATIONS FOR POST-TREATMENT EVALUATIONS. Post-treatment evaluations (FSM 2155.1) are required for all projects involving pesticides, except for housekeeping-type uses, field experiments, and minor uses of less than one pound active ingredient or less than one gallon of formulated produce for any one project. Regardless of pesticide application method employed or size of area treated, the effectiveness of the prevention or suppression effort must be determined. The project work plan and its associated, approved Pesticide-Use Proposal (Form FS-2100-2) must prescribe quantitative procedures by which treatment effectiveness can be accurately assessed. For example, conduct comparative pre-suppression and post-suppression samples for defoliating insects. For vegetation control work, pre-treatment and post-treatment sampling of the plant population generally are needed. Specific methods cannot be prescribed since state-of-the-art sampling varies between pests. The most current and realistic sampling techniques should be tailored to individual pest conditions. 53.1 - Biological Effectiveness. Use post-treatment evaluations to determine whether project objectives were met. If the identified objectives were not met, another biological evaluation may be necessary (FSM 3420) to determine and correct the source of project failure. 53.2 - Application Effectiveness. Although the majority of monitoring for application effectiveness is done during quality control monitoring (sec. 52), some post-treatment checks may be needed. For example, if it is determined that an area was missed, then re-application may be necessary. Use post-treatment evaluations of applications to improve future project planning and effectiveness. 53.3 - Environmental Impacts. Conduct post-treatment evaluations to determine if there were unanticipated adverse environmental impacts that resulted during the project. The impacts can be direct or indirect. The extent of post-treatment evaluation of direct impacts of pesticide application depends on the type of pesticide and the extent of application. Possible environmental components to be monitored for direct impacts include: 1. Water and air quality; 2. Soils; 3. Non-target vegetation and animals (parasites and predators); 4. Wildlife; 5. Sensitive, threatened, or endangered species; and 6. Fish. Pesticides can be harmful to non-target organisms even if they do not directly kill non-target plants or animals. Pesticide properties such as persistence in the environment, leaching, and phytotoxicity will affect the extent of these indirect impacts. 53.4 - Human Health Effects. Conduct post-treatment evaluations of the effects of a project or pesticide on human health, as described in a project safety plan. Select the type of evaluation based on the analysis of the risk of the project. Most accounts of adverse impact on human health are often anecdotal and cannot be confirmed by scientific fact or medical surveillance. However, it is imperative that public and employee concerns are taken into account and dealt with in a sensitive manner. Post-treatment evaluations must be coordinated with pre-treatment evaluations (sec. 52.35). It is recommended that new employees who are to be routinely involved with pesticide-use projects provide a health history to be held in confidence as part of the employee records. 53.5 - Followup Action. Consider followup action whenever a post-treatment evaluation indicates a problem with a pesticide- use project. Take followup and corrective action such as: 1. Documenting problems/solutions; 2. Conducting a new biological evaluation; 3. Recommending retreatment; 4. Describing mitigation measures for future projects; 5. Changing equipment/pesticide formulation; and/or 6. Recommending alternatives.