HomeMy WebLinkAboutStaff Report 215-10TO: HONORABLE CITY COUNCIL e
FROM: CITY MANAGER DEPARTMENT: PUBLIC WORKS
DATE: APRIL 19,2010 CMR:215:10
REPORT TYPE: INFORMATION
SUBJECT: Staff Update on Less-Toxic Pest Control Program for City Operations
RECOMMENDATION
Staff recommends that the City Council accept this report titled Update on Less-Toxic Pest
Control Program for City Operations.
BACKGROUND
In 2001, the City of Palo Alto adopted a reduced-risk pest management policy and drafted an
Integrated Pest Management plan for the use of pesticides by City staff and contractors.
The goals of the Integrated Pest Management program are to:
• minimize water quality and other eco-toxicity impacts from the City's pesticide use;
• minimize total pesticide use; and
• use the least toxic pesticides when pesticide use is required
These goals are achieved through an annual quantification of the City's pesticide use and
continual improvement of pest control strategies.
Integrated pest management also known as reduced-risk or less-toxic pest management,
encourages long-term pest prevention and suppression through a combination of techniques
including biological controls, habitat manipulation, use of resistant plant varieties, improved
landscape and building hygiene, and structural repair and pest barriers. Integrated Pest
Management sanctions synthetic chemical pesticides only as a last resort, and only with the least
toxic chemicals available. While the City of Palo Alto has used these principles for many years,
additional storm water protection regulatory requirements resulted in a more formal, structured
Integrated Pest Management program in 2001. It should be noted that some pest controls, such
as use of mulching, mowing, and mechanical removal of weeds, were in place before
quantification of pesticide use began in 2001, so that reductions in the use of some pesticides
have been greater over the long term than the data indicates. In addition, natural pest population
cycles may fluctuate annually depending on climate, food availability and site conditions and so
annual pest management and pesticide use may fluctuate accordingly.
CMR:215:1O Page 1 of4
To evaluate the chemical toxicity of chemicals used, a tiered system is used based on a City of
San Francisco study which considers (1) acute human toxicity and chronic health risks; (2) the
level of training required to use the product; (3) inclusion ofa chemical on the Clean Water Act
303d list for impairment of a local water body; (4) environmental toxicity; and (5) a chemical's
persistence and mobility in soil. Tier 1 chemicals are of highest concern, Tier 2 are of moderate
concern, and Tier 3 are of lowest concern. To be identified as a Tier 1 chemical, a product needs
to be identified as high risk with regard to only one of the five criteria above. Because of this
strict criteria, most pesticides are classified as Tier 1.
A primary focus of the City's IPM program is to identify and reduce the use of a subset of Tier 1
pesticides that exhibit ecotoxicity. Ecotoxicity is defined as toxicity to birds, fish, bees, and
aquatic indicator species, and potential secondary or non-target poisoning from consumption of
rodent baits based on product "Material Safety Data Sheets" and other resources.
DISCUSSION
This update summarizes the IPM program's overall program successes, specific 2009
accomplishments and the program's priorities for 2010. It should be noted that while Public
WorkslEnvironmental Compliance coordinates the City's IPM efforts, City staff in Community
Services (Golf, Open Space, Parks) and other divisions of Public Works (Facilities) should be
largely credited with the positive results of their hard work to achieve the City's IPM goals. The
attached 2009 Pest Management and Pesticide Use report includes photos and detailed
information.
2009 Program Accomplishments:
Total Active Ingredient, Tier 1 and Ecotoxic Pesticide Use (2001~2009)
500 ,..-------446-........... ----44-9--------....." III Total Pesticides Applied I
450 +----....... ---~
390 _ 400 +-----.. --~
In g 350+----... Ii 300 -1-2-'1'8--;; e 250
0)
.5 200
i 150 u
<C 100
50
o
2001 2002 2003
355
2004 2005
Year
2000 2007
DTier 1 Pesticides
• Ecotoxic Pesticides
252
2008 2009
• Both the City's total active ingredient as well as ecotoxic pesticide use decreased to
historically low levels since the program's inception in 2001. Ecotoxic pesticides use fell
by 43% in 2009 which is significant because ecotoxicity reduction is the primary driver
of the City's pesticide reduction efforts.
CMR:215:10 Page 2 of4
• The herbicide Roundup (glyphosate) use has fallen 78% and insecticide use has fallen
75% since their highest use levels in 2003; rodenticide use decreased by 54% since 2008
and wil1likely further decrease due to new non-pesticide control methods.
• The Parks Department launched a pesticide-free park program that began with Sarah
Wallis Park. One or two parks will be added each year alternating between north and
south Palo Alto.
• The golf course implemented a successful perimeter trapping program for gophers. This
action significantly reduced the use of ecotoxic rodenticides. Trapping has proven to be
better at controlling gopher populations than the chemical controls used in previous years
and is less expensive.
• Language for a new Landscape Maintenance Contract was updated to include
requirements for Bay Friendly techniques (which supports IPM), the use of organic
fertilizers and IPM requirements. The contract will be awarded in 2010 and an update on
its impacts will be provided in the 2010 IPM Report.
Program Accomplishments since 2001
• The City was awarded IPM Innovator of the Year Award in 2003 by the California
Department of Pesticide Regulation.
• Alternative forms of pest control have been implemented to avoid pesticide use including
the use of power washing to control tussock moths, visual barriers and raptor perches to
reduce ground squirrel activity, goats for open space weed control and heavy mulching to
reduce weeds in parks, structural repairs to deter mice and rats, and experimenting with
newer pesticides that meet the City's Tier 2 criteria.
• The City was the first public agency or business to require its structural pest control
operators to be Eco Wise Certified in 2007. Eco Wise Certified is a rigorous Bay Area
wide program developed by pest control and water quality professionals and the National
Resources Defense Council which demands rigorous less-toxic pest control services and
training from pest control operators. The City's current Eco Wise Certified pest control
operator, Pestec, uses no spray poisons to control ants or stinging insects, and only
exclusion methods and traps to control mice and rats. The Facilities Division undertook
an ambitious 18 month process to install door sweeps, and make various building repairs
to block access to pests across the City. This has reduced pest control complaints and
resulted in a much higher efficacy of pest controL
• Piloted the use of "bee tunnels." The City's contractor, Pestec, identified a method of
rerouting bees that are entering and exiting their hives away from people when
human/bee interface is likely. The device protects bees and humans when a potential for
interaction is likely.
• Annually updated information is available to the public on the City's website showing
pesticide use by location, date applied and pest managed.
CMR:215:10 Page 3 of4
• The City co-funds and operates in-store programs that direct the public to least-toxic pest
control products and offers periodic workshops on less-toxic pest control.
2010 Priorities for City of Palo Alto IPM Program
Staff will continue to target the reduction of the City's use of ecotoxic pesticides and those that
are used in large amounts. Specific task reconnnendations are to:
1. Continue to follow and encourage the success of perimeter trapping for gophers which
should nearly eliminate all rodenticide use except for small amounts used for ground
squirrels.
2. Explore options for ground squirrel control to further reduce ecotoxic pesticide use.
3. Investigate IPM and less-toxic product alternatives for weed control at the golf course.
4. Track the addition of pesticide-free parks in the City and the results of adding IPM
language into landscape maintenance contracts.
5. Track and support as appropriate the expansion of Eco Wise Certified.
ENVIRONMENTAL REVIEW
This is not a project under the California Environmental Quality Act (CEQA).
ATTACHMENT
Attachment A: 2009 IPM Report
PREPARED BY:
DEPARTMENT HEAD:
CITY MANAGER APPROVAL:
CMR:215:
ATTACHMENT A
Background
City of Palo Alto
2009 IPM Program Report
February 8,2010
In 2001, the City of Palo Alto adopted a reduced-risk pest management policy and drafted an
Integrated Pest Management (IPM) plan for the use of pesticides by City staff and contractors.
The goals of the IPM program are to:
• minimize water quality impacts from pesticide-related ecotoxicity;
• minimize total pesticide use; and
• use the least toxic pesticides when pesticides are needed.
These goals are to be achieved through an annual quantification of the City's pesticide use and
continual improvement of pest control strategies.
Integrated pest management (IPM), also known as reduced-risk pest management, encourages long
term pest prevention and suppression through a combination of techniques including; biological
controls, habitat manipulation, use of resistant plant varieties, improved landscape and building
hygiene, and structural repair and pest barriers. IPM sanctions synthetic chemical pesticides only as a
last resort; and only with the least toxic chemicals available. While the City of Palo Alto has used these
principles for many years, additional storm water protection regulatory requirements resulted in a more
formal, structured IPM program. It should be noted that non-chemical controls, were in place before
quantification of pesticide use began in 2001, so that reductions in the use of some pesticides have
been greater over the long term than the data indicates.
To evaluate the chemical toxicity of chemicals used, a tiered system is used! (based on a City of San
Francisco study) which considers (1) acute human toxicity and chronic health risks; (2) the level of
training required to use the product; (3) inclusion of a chemical on the Clean Water Act 303d list for
impairment of a local water body; (4) environmental toxicity; and (5) a chemical's persistence and
mobility in soil. Tier 1 chemicals are of highest concern, Tier 2 are of moderate concern, and Tier 3 are
oflowest concern. To be identified as a Tier 1 chemical, a product needs to be identified as high risk
with regard to only one of the five criteria above.
A primary focus of the City's IPM program is to identify and reduce the use of a subset of Tier 1
pesticides that exhibit ecotoxicity. Ecotoxicity, for this report, is defined as toxicity to birds, fish, bees,
and aquatic indicator species, and potential secondary or non-target poisoning from consumption of
rodent baits based on product MSDSs and other resources.
This 2009 update summarizes the year's successes and challenges, reports on the City's 2009 pesticide
use data, discusses program accomplishments and progress on the 2008 report recommendations, and
makes 2010 project recommendations.
1 See Appendix I: Evaluation and Rating of Pesticide Toxicity Risk
1
Summary of 2009 Program Achievements and Pesticide Use Changes
1. The City's total active ingredient and ecotoxic pesticide use decreased to historically low levels
since the program's inception in 2001. Ecotoxic pesticides use fell by 43% which is significant
because ecotoxicity reduction is the primary driver of the City's pesticide reduction efforts.
2. The golf course implemented a successful perimeter trapping program for gophers. This action
significantly reduced the use of ecotoxic rodenticides. Trapping has proven to be better at
controlling gopher populations than the chemical controls used in previous years.
3. The Parks Department launched a pesticide-free park program that began with Sarah Wallis Park.
One or two parks will be added each year as funding allows, alternating between north and south
Palo Alto.
4. Language for a new Landscape Maintenance Contract was updated to include requirements for Bay
Friendly techniques (which supports IPM), the use of organic fertilizers and IPM requirements.
The contract will be awarded in 2010 and an update on its impacts will be provided in the 2010
lPMReport.
2
2009 Pesticide Use Information
1. Total Active Ingredient Use Trends
Total active ingredient use decreased by 17 pounds (6%) in 2009 because of a reduction in use of
aluminum phosphide, flutolanil and imazypyr.
Figure 1: Total Pesticide Active Ingredient Use by Year (2001-2009)
500
446 449
.-. 450 11 = 400 II:
~ 350
CD & 300
.E
CD 250 > :;:; u 200 c( ....
0
1:
150
::s 100 0
E 50 c(
0
2001 2002 2003 2004 2005 2006 2007 2008 2009
Year
3
350
300
j 250 ::::=. -c .m 200
"D e r 150
4» > ts 100 c(
50
0
2. Tier 1-3 Pesticide Use
The City's use of Tier 1,2, and 3 pesticides for calendar years 2001 through 2009 is displayed in
Figure 2. Figures 3 through 6 provide annual pesticide use, by tier, for controlling fungus, rodents,
weeds, and insects, respectively.
Figure 2: Tier 1, 2, and 3 Pesticide Use by Year (2001-2009)
2001 2002 2003
Tier 1 Pesticide Use
2004 2005
Year
2006 2007 2008
.Tier 1
l1Tier2
DTier 3
2009
In 2009, total Tier 1 use remained almost identical to the previous year-one pound less of Tier
1 active ingredient was use.d in 2009. A decrease of 36 pounds of aluminum phosphide and
imazapyr was offset by a 43 pound increase in Mancozeb use.
Tier 2 Pesticide Use
Tier 2 pesticide use decreased by 15 pounds largely because of 14 pounds less flutolanil
(ProS tar) applications. Fludioxonil (Medallion ), flutolanil (ProStar), and glyphosate (Roundup)
comprised 92% of the Tier 2 pesticides used in 2009. The use of Roundup herbicide decreased
slightly in 2009 but has reduced by 81 % from the peak level of 2003 due to heavy mulching
and mechanical weed removal. Total herbicide use is at an historical low.
Tier 3 Pesticide and non-chemical controls
Tier 3 products were not used in 2009, but non-toxic pest control measures which are favored
over Tier 3 product use continue to expand. Non-chemical controls include power washing for
tree pests, mulching to reduce weeds, structural repairs to deter ants and mice, and trapping for
gophers.
4
Toxicity of Pesticides Used for Key Pests
A majority of the Tier 1 pesticides are used for controlling fungi, rodents and insects. Most Tier 2 pesticides are for weed control. Most
Tier 3 products have been used for insect or weed control.
Figure 3: Summary of pesticides used to control fungus Figure 4: Summary of pesticides used to control rodents
300.----------------------------------------------. 40
300 -+.. _Tier 2 M ..
35
.Tier2
ilTier 1
:e 30 -@. 250
1: t 200
I!!ITier 1 II 1: 25
CD
=150 .s
~ 100 :e
< 50
o
400
2001 2002 2003 2004 2005 2006 2007 2008 2009
Year
Figure 5: Summary of pesticides used to control weeds
350 +--~~~~~~~~ DTier 3 -11/
S 300 +1-----• Tier 2
STier 1
-'I 250
1 200
If .-150
CD
.i:t 100 ~
50
o
2001 2002 2003 2004 2005 2006 2007 2008 2009
Year
120
CD .e 15
CD > :e 10
< 5
0
2001 2002 2003 2004 2005 2006 2007 2008 2009
Year
Figure 6: Summary of pesticides used to control insects
50 I==---=---~===:::~-45r----------r~-------------------=~====~
i 40 1-------..J
:35
OTier3
c :; 30 T----~~~~~~~~~
I!! 25 ,--------
CD .s 20
~ 15
~ 10
5
o
.Tier2
2001 2002 2003 2004 2005 2006 2007 200S 2009
Year
5
Top five active ingredients used by weight
Figure 7 presents the five most-used pesticide active ingredients by weight for 2009. Mancozeb,
aluminum phosphide and imidacloprid are Tier 1 pesticides. Flutolanil and glyphosate are Tier 2
pesticides.
Figure 7: Top Five Pesticides Applied by Weight
All others
17%
Aluminum Phosphide
(Fungicide)
4%
I midacloprid
(Insecticide)
4%
Flutolanil (Fungicide)
7%
Glyphosate (Herbicide)
25%
Mancozeb (Fungicide)
43%
Figure 8: Usage History for 2009 Top Five Active Ingredien1s
350~~~~~==~~~~==~~~~=-~~~~==~~~~~~~
300 .....
fn
@. 250
.!
1:$ 200
C
'B 150
C J 100
50 +.1i1I~
o +--="-
Mancozeb
(Fungicide)
Glyphosate
(Herbicide)
Flutolanil
(Fungicide)
Active Ingredient
Imidacloprid
(Insecticide)
Aluminum
Phosphide
(Fungicide)
,----'-~
6
Table 1: 2009 Change in Top Five Active Ingredient Usage
Amount
Changed Percent Location
Active Ingredient Tier 2008 2009 (Ibs) Change Used
Mancozeb (Fungicide) 1 66 109 43 64% Golf Course
Parks, PWD
Operations-
Glyphosate (Herbicide) 2 69 63 -6 -9% Trees
Flutolanil (Fungicide) 2 32 18 -14 -44% Golf Course
I midacloprid (I nsecticide) 1 8 10 2 24% Trees
Aluminum Phosphide Open Space-
JFun9icide) 1 36 10 -26 -72% Foothills Park
Ecotoxic Pesticide Use in 2009
The primary driver ofthe City's IPM policy and plan is the avoidance of ecotoxicity in water bodies from
pesticide use. Ecotoxicity, for this report, is defined as toxicity to birds, fish, bees, and aquatic indicator
species, and potential secondary or non-target poisoning from consumption of rodent baits based on
product MSDSs and other resources. Ecotoxic pesticides are a subset of Tier 1 pesticides as described
previously in this report. A product's potential ecotoxicity does not necessarily mean an immediate threat
to the environment; how, where, and when the pesticide is applied and the product's breakdown time are
all factors in its ultimate environmental impact.
Factors to consider:
• Some product formulations use procedures that restrict product entry into the environment, such as
containerized ant baits and dusts (applied in wall cracks and crevices) ..
• Conversely, even small amounts of some pesticides such as non-containerized pyrethroids (e.g.,
bifenthrin, cyfluthrin, delta-methrin) usually associated with sprayed ant pesticides, should be targeted
because of their persistent toxicity in urban creek and Bay sediments when rain or irrigation washes
them from surface areas into waterways.
• Pesticides not identified by the EPA as known ecotoxins are not free of risk. Proprietary inert
ingredients and synergistic effects of multiple pollutants may still impact water quality and for that
reason, large amounts of use of any single product are warranted for potential reduction.
7
Figure 9: Total Active Ingredient, Tier 1 and Ecotoxic Pesticide Use (2001-2009)
500~--------------------------------------------------------------~
446 449
450+----------------------------------------------~
400 + ................... --.-='-=-----
IIITotal Pesticides Applied
DTIer 1 Pesticides
U; 350 +------.D
C.
• Ecotoxic Pesticides
1: 300 +-0,...",------
CD :s ! 250 g
200 CD
~ u 150 c(
100
50
o
2001 2002 2003
Ecotoxic pesticide use trends
2004 2005
Year
2006 2007 2008 2009
In the first three years of Palo Alto's IPM program, the recorded use of ecotoxic and other Tier 1 active
ingredients decreased because of expanded use of non-chemical and less toxic pesticide controls, a
suspended use of some products while the goals of the City's IPM program were clarified, and because
not all information was able to be captured from contractors. In 2004 and 2005, ecotoxic pesticide use
increased because of weather conditions which resulted in the need for more fungicide use at the golf
course, but then decreased from 2006 to 2008 because of less PCNB and thiophanate-methyl use and
because the Tier 2 fungicides fludioxonil (Medallion) and flutolanil (Pro Star) were rotated into the suite
of fungicides used throughout the year.
In 2009, the golf course helped reduce the City's ecotoxic use further by switching to trapping for gophers
in lieu of chemical controls. This reduced the City's ecotoxic pesticide use to 28 pounds, the lowest
number in the program's history.
Rodents (gophers and ground squirrels), insects and weeds now pose a similar challenge in terms of
which pests currently prompt the use of ecotoxic pesticides.
Rodenticides for rats and mice are essentially no longer in use because of structural repairs that Facilities
Division has made, and because the City's structural pest control provider does not use bait for mice or
rats. The expanded gopher trapping in 2009 was very successful and Open Space plans to use more
trapping for their gopher problem in 2010. Staff anticipates that rodenticide use will continue to decrease
because of these efforts.
Insecticides used to control insect tree pests comprised 36% ofthe City's ecotoxic pesticide use in 2009,
but these products are injected into the ground around tree roots and pose minimal threat to surrounding
areas. Less than one percent of one additional ecotoxic pesticide is applied to tree foliage.
Approximately 28% of the City's ecotoxic pesticides are used for weed control at the golf course. Staff
will investigate alternative control measures in 2010.
8
Table 2: Locations of Ecotoxic Pesticide Use in 2009 and Potential for Reduction
D' .:. Active Ingredient Percent of Ecotoxic Opportunity for Reduced Use ,-"' product used and pest
Low.
Action: Staffhas already
significantly increased power
washing to control insects and
Operations-Imidacloprid 36% (10.20 Ibs) incorporates many IPM measures
Trees (Merit) Insects into tree pest management
Imidacloprid is injected into
ground around tree roots and thus
greatly minimizes potential
release to surrounding
environment.
Moderate.
Open Aluminum 36% (IO.l8Ibs) Phosphide Action: Staffwill experiment Space/foothills (Fumitoxin) Gophers with perimeter trapping in 2010
to reduce rodenticides.
Mecoprop-P, Low
Diacamba,
Golf course carfentrazon-ethyl, 27% (7.54Ibs) Action: Weeds are difficult to
2,4-D 2-Ethylhexyl Weeds control because of high standards
Ester * for golf course playability and
(Speedzone) turf stress.
Clopyralid, Moderate
Golf course Monoethanolamine 1% (0.37) Action: Staffwill investigate Salt (Lontrel Turf Weeds alternatives for golf course weeds and Ornamental) control.
Low
Trees Spinosad <1%(0.02) A very small amount of this
(Conserve) Insects product is used each year and not
considered a priority active
ingredient to target for reduction.
*These four actIVe mgredlents are all used m one product. Their weIght has been totaled together for ease of
review
9
Table 3: Progress on 2009 Recommendations for
City of Palo Alto IPM Program
Recommendation Status
1) Follow and encourage the success of perimeter Perimeter trapping has proved hugely
trapping for gopher and ground squirrels. successful and has greatly reduced the
gopher population at the golf course,
leading to a subsequent 72% reduction in
aluminum phosphide use. The golf course
plans to continue using perimeter trapping
and is exploring trapping options for ground
squirrels which should also further reduce
rodenticide use.
2) Set up initial meeting with Department ofFish A meeting was held with Open Space,
and Game, Berkeley biologist and City staff to Environmental Compliance and Dr. Gilbert
explore reintroduction of native weasels to City Proulx. Open Space is considering if and
property. when a reintroduction could proceed and
will be the lead for this action.
3) Track and support as appropriate the expansion of Eco Wise has been adopted by the
Eco Wise Certified into a program that is adopted Biointegral Resource Center and has
and managed by the Structural Pest Control funding for 2010. Its primary goal is to
Board. make EcoWise self-supporting and to
continue as a third-party [PM certifier to
companies and practitioners.
Outreach on Eco Wise Certified could be
done in 2010, although if future program
funding fails it may seek sponsorship of
another organization in the following year.
4) Go out for bid for next three-year structural pest Revisions to the contract language were
control contract emphasizing Eco Wise Certified made. The contract will be awarded in early
requirements. 2010.
5) Advocate and publicize the use of bee tunnels. Outreach was conducted through a tour.
Sharing this [PM strategy will continue
periodically.
6) Explore the timing for inclusion ofIPM language Environmental Compliance staff suggested
into landscape maintenance contracts. changes to the Landscape Management
Contract which will be awarded in 2010.
Parks staff anticipates that a majority, if not
all, of the ECD suggestions will be
incorporated into the new contract. Changes
include: a preference to have Bay Friendly
Certified landscapers, increased mulching
and organic fertilizer usage.
7) Investigate the possibility of having a pesticide-The Parks Department successfully
free park or demonstration site in the City. launched its first pesticide-free park at
Sarah Wallis Park. The Parks Department
plans to add one or two additional parks to
the list of those that don't use pesticides
each year as funding allows.
10
IPM Program History 2001-2009
Accurately assessing the success of the City's efforts to reduce pesticide use and use least toxic products is
difficult when relying solely on yearly numerical fluctuations in pesticide use. Variations in weather patterns,
natural pest population cycles, and challenges associated with quantifYing pest control efforts that use
biological or mechanical controls in lieu of pesticides are all important considerations. The following are·a
summary of key Palo Alto IPM accomplishments to date:
2001
• IPM policy is the first City Policy in the County
to be adopted. The IPM Committee drafts the
IPM Plan and Procedures.
• A tiered system for analyzing City pesticide use
is adopted and the first annual report on the
City's pesticide use is completed.
• IPM Committee votes to discontinue use of
organophosphate pesticides due to water quality
concerns associated with their use.
• Solarizing non-native plants at Pearson
Arastradero Preserve (weeds are covered in
plastic tarps and destroyed by heat).
• Mechanical removal of weeds in Open Space
Ponds
• Bermuda grass replaces bent grass at bowling
green to reduce need for pesticides.
• City begins mulching in lieu of glyphosate use
to control weeds (both pre and post emergent).
Mulching becomes a significant contributor to
the reduction of herbicide use in the City.
• Herbicide spraying discontinued at schools due
to Healthy Schools Act.
2002
• Completed five extensive IPM plans and related
training for ants, weeds, yellowjackets gophers
and ground squirrels.
• Identified all leased fucilities and contractors
for inclusion in the City's annual pesticide
reports.
2003
A visual barrier installed at the golf course
decreased ground squirrel damage by 100%.
GIS view of pesticide application
next to Adobe creek
• City receives Department of Pesticide Regulation IPM Innovator award
http://www.cdpr.ca.gov/docslipminov/awardsl03awards.htm
• Piloted new methods to reduce yellow jackets in Parks and Open Space.
• Piloted gopher reduction strategies at Foothills Park using trapping as a primary method.
11
• In partnership with Santa Clara County Airport and
Baylands and golf course Staff implemented two new
measures to reduce ground squirrel populations
2004
a. The installation of a visual barrier hung along the
golf course/airport fence line to decrease the
ground squirrels' ability to see predators and
thus reduce activity.
b. a trap design around Baylands buildings that can
capture up to four ground squirrels at a time.
• Created pesticide data entry system using a centralized
database and simplified reporting interface. This
streamlines staff reporting time and allows staff to also
print mandatory monthly DPR reports.
• Transferred pesticide use information in database to GIS
format allowing for visual assessment of pesticide
applications next to creeks and the Bay.
• Use of goats in Open Space areas to control weeds
proves successful (reintroduction of goats to this area is
on hold due to mountain lion concerns in that area).
2005
• Scope of Services for City wide IPM contract drafted.
RFP to go out in 2006.
• Less toxic, botanically-based insecticides ordered for
Facility staff use and related Approved Pesticide List for
Facilities and staff at the Regional Water Quality
Control Plant who are responsible for their own pest
control
• Confirmed pesticide reduction hierarchy
2006
• Hired Eco Wise Certified structural pest control
company to service all City facilities (pestec)
• Identified less toxic fungicide alternatives
• Provided mini grants «$5,000) to golf course and Art
Center for structural pest control.
• Improved the City's database system.
2007
• Implemented Bco Wise Certified contractor service into
City operations and consolidated related billing and
service levels.
• Completed 50% of recommended building repairs to
reduce overall conditions that encourage pest activity.
• Tested two Tier 2 fungicide alternatives.
Goats are used to reduce weeds at Enid
Pearson Arastradero Open Space Preserve.
A bee tunnel is installed over a bee hive in
a public parking lot.
Dr. Gilbert Proulx provides information on
gopher biology and trapping.
• Held two region-wide trainings for IPM structural pest control
2008
• Medallion and Prostar, two Tier 2 fungicides, were incorporated into ongoing use at the golf course.
• A gopher and ground squirrel workshop was held inspiring staff to experiment with the use of perimeter
trapping to control these animals.
• The City's contractor, Pestec, identified a method of rerouting bees that are entering and exiting their
hives away from people when humanlbee interface is likely. Staff developed a public education piece
and internal protocol for responding to bee complaints.
• Completed structural building repairs identified in 2007 needed for ant and rat control.
• Public Works Trees incorporates power washing to remove tussock moths from trees in City parks.
2009
• Perimeter trapping proved hugely successful and reduced aluminum phosphide use by 72%.
• The Parks Department launched its fIrst pesticide-free park at Sarah Wallis Park.
• IPM language was added to parks maintenance contract.
• Palo Alto ecotoxic and total active ingredient pesticide use the lowest in program history.
2010 Recommendations for City of Palo Alto IPM Program
Based on analysis of 2009 data
Staff recommends that the City continue to target the reduction of ecotoxic pesticides and those that are
used in large amounts. These recommendations factor in reduced funding and staff resources from
previous years' budget reductions. Specific task recommendations are to:
1. Continue to follow and encourage the success of perimeter trapping for gophers.
2. Explore options for ground squirrel control to further reduce ecotoxic pesticide use.
3. Track and support as appropriate the expansion of Eco Wise Certified.
4. Advocate and publicize the use of bee tunnels.
5. Track the addition of pesticide-free parks in the City and the results of adding IPM language into
landscape maintenance contracts.
6. Investigate IPM and less-toxic product alternatives for weed control at the golf course.
13
Appendix I: Evaluation and Rating of Pesticide Toxicity Risk
1. Information sources for pesticide evaluation
Information used to evaluate hazards are obtained from the sources listed in Table 1 below:
Table 1-Pesticide Information Sources
Information
Product Literature
Product MSDS
Product Label
Other Manufacturers' Data
Registration Documents
Ingredient Data
Specific Product Risk Ratings
Source
Crop Data Management Systems Website
Manufacturers' Websites
Calif. DPR Website
EPA Reregistration Eligibility Decisions
(R.E.D.) Website
EPA & Other Websites
Toxicology Literature
San Francisco & Seattle IPM Websites
2. Defining pesticide risks. Three factors defme the overall risk:
a) The level of hazard inherent in the chemicaL Some pesticide ingredients can cause
immediate, acute injury (e.g., eye irritation), while others may take years for their toxic
effects to be seen (e.g., cancer).
b) The level of exposure that the user, near-by person, or the environment might incur.
For example, consider a rat poison contained in a tamper-resistant trap, versus that same
rat poison in pellet form spread on the ground next to a building foundation.
c) The susceptibility of the exposed person or animal to the hazard. For example, people
with asthma may be more susceptible to air-born chemicals. Also, children, the elderly, or
people recovering from an illness may each have a somewhat lesser tolerance to chemical
exposures than would an average healthy adult.
3. Qualifying the criteria used to define pesticide risks
There are several dozen chemical hazards and exposure issues that can be used to evaluate the
overall risk of individual pesticides. Examples include: toxicity to humans and animals;
potential to cause cancer; use in a sprayer versus sprinkling as a powder; and flammability.
The US Environmental Protection Agency (EPA) and California Department of Pesticide
Regulation (DPR) routinely evaluate the top 20 or so of these criteria when making decisions
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about registering pesticide products. The Cities of San Francisco and Seattle use similar criteria
as part of their IPM programs. RWQCP staff primarily use the San Francisco criteria list in
reviewing pesticides used in Palo Alto. The risk evaluation criteria are described below: These
descriptions are adapted from extensive reports that are available on the San Francisco and
Seattle IPM websites.
a) EPA Hazard Class -"Signal Words" are required by US EPA onpesticide labels to indicate
the overall hazard category for a product, based on acutely toxic effects. Listed from most to
least hazardous, the signal words are: I-Danger, II-Warning, III-Caution, or IV-Caution. It is
preferable to use pesticides labeled as "Caution."
b) Use Restricted to Certified Applicators -Some products evaporate easily, are easily absorbed
through skin, or have other characteristics that make them a high risk to untrained users. The
EPA designates in its registration decisions which products are to be used only by a certified
applicator. It is preferable to use products that have no use restrictions.
c) Chronic Toxicity -Longer term tests on active pesticide ingredients indicate their likelihood
of causing cancer, reproductive or developmental harm, or disruption of hormone systems.
There is uncertainty in evaluating animal tests of these types, and how to apply the results to
humans. Therefore, the results will be stated as probabilities, e.g., iprodione is a "probable
human carcinogen," or iprodione is "known to the State of California to cause cancer and
reproductive harm." It is preferable to avoid pesticide products that have a possibility of
causing cancer, reproductive or developmental harm, or disrupting hormone systems.
d) Contains Clean Water Act (303d) Listed Chemicals -Copper, chlorpyrifos, and diazinon are
three pesticide ingredients managed under the Clean Water Act. The City has a stated policy
of not using products with diazinon or chlorpyrifos.
e) Ecotoxicity (Animal Toxicity) -Laboratory tests on birds, fish, bees, and other wildlife
indicate how these animals may react to unintended pesticide exposures (Le., where they are
not the pest being dealt with). As described above for acute oral toxicity, the test results are
given in terms of the dose that kills half of a group of birds, fish, or other test animals. It is
preferable to use pesticides with the following toxicity levels:
• Bird toxicity> 2,000 mglkg
• Fish toxicity> 100 mg/l
• Bee toxicity> 11 Ilg per bee
f) It is preferable to avoid products that are labeled as "highly" or "extremely" toxic to these
and other animals. Brodifacoum, Bromadionone and Bromethalin are considered specific
high-risk animal toxins, particularly due to the possibility of secondary poisonings. In
addition there are concerns about two rodenticides, chlorphacino.ne and diphacinone, which
although less toxic, also present primary and secondary risks.
g) Persistence and mobility in soil-Many pesticides biodegrade readily, and tend to remain in
the area where they are placed. Other products persist in the environment, and tend to move
through soil into the groundwater or a near-by stream. It is preferable to use pesticides with
the following characteristics:
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• Persistence in soil < 30-day half-life
• Ability to move through soil == "Low"
• Not labeled as a groundwater contamination hazard
4. Rating Pesticide Toxicity The City of Palo Alto uses the San Francisco strategy of placing
pesticides into groups, or tiers, according to their relative risks. Table 2 outlines the four
tiers that are used, and the criteria that place a product into a specific tier.
Table 2. Pesticide "Tier Definition" System
All pesticide products are classified into one of four tiers based on each product's hazards:
Tier 1: Highest concern
Tier 2: Moderate concern
Tier 3: Lowest concern
Tier 4: Insufficient information
Tier 1: A product is Tier 1 if anyone of the following are true:
• Product is a restricted-use pesticide
• Product contains known, likely, or probable carcinogens, reproductive toxicants (CA Prop 65 list or
other published test) or endocrine disruptors as active ingredients (Illinois EPA list, or other
published test results)
• Product contains diazinon, chlorpyrifos, or copper, identified as important causes of impaired
waterbodies in California Regions 2 and 5 under section 303(D) of the Clean Water Act
• Product labeled as highly toxic or extremely toxic to birds, aquatic species, bees, or wildlife.
• Product contains the rodenticides brodifacoum, bromethalin, or bromadionone
• Product contains active ingredients with soil half-lives greater than 100 days
(not applicable to products used only indoors or to products used only in bait stations)
• Product contains active ingredients with mobility ratings high or very high or with specific label
warnings about groundwater hazard. (not applicable to products used only indoors or to products
used only in bait stations)
Tier 2: All products not specifically assigned to Tier 1 or Tier 3.
Tier 3: A product is placed into Tier 3 if all of the following are true:
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• Product contains no possible or probable carcinogens
• Product contains no reproductive/developmental toxicants (CA Prop 65 list)
• Product contains no ingredients listed by Illinois EPA as known, probable, or suspect endocrine
disrupters
• Active ingredient has soil half-life of 30 days or less (exception for minerals
• Active ingredient has extremely low or very low mobility in soils.
• Product is labeled as non-toxic to fish, birds, bees, wildlife, or domestic animals.
Tier 4: Not enough information. Product registration or label not found, or key data not located for
active ingredient (e.g., half-life, soil binding, ecotoxicity, etc.)
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