DRAFT SAMPLE POLICY
SAFETY MANAGEMENT PROGRAM POLICY/PROCEDURE MANUAL
TITLE: INTEGRATED PEST MANAGEMENT PLAN / POLICY NUMBER:PAGE 1of 13
KAISER PERMANENTE
INTEGRATED PEST MANAGEMENT PROGRAM
1.0 POLICY
1.1The Precautionary Principle states that:
When an activity raises threats of harm to the environment or human health, precautionary measures should be taken even if some cause and effect relationships are not full established scientifically. (From definition created at the Wingspread Conference on the Precautionary Principle, January, 1998.)
1.2Kaiser Permanente recognizes that the use of pesticides may be potentially hazardous to human health and the health of the environment. In keeping with the Precautionary Principle and to reduce or eliminate the threat of human or environmental harm caused by pesticides, Kaiser Permanente is adopting and implementing Integrated Pest Management (IPM), which focuses on prevention of pests both inside and outside hospitals. If corrective action becomes necessary, the least toxic and non-pesticide practices and products are given preference with appropriate notification.
1.3The main components of Kaiser Permanente’s IPM program are as follows:
1.3.1Prevention. Non-chemical prevention is the primary means of pest management in the IPM program. Proper sanitation and housekeeping, pest-proofing waste disposal, and structural maintenance are key ingredients. Reduce or eliminate pests’ sources of food, water and shelter.
1.3.2Monitoring. IPM requiresregular site inspections and trapping to determine the types and infestation levels of pests at each site and monitoring to provide accurate, timely information on pest activity – to establish whether there is in fact a pest problem and to identify its causes. Implementing a schedule and a plan for monitoring pest populations ensures the success of pest control efforts. The best way to monitor for many pests, like cockroaches, is with sticky traps.
1.3.3Determining Action Levels. An action level is the population size that requires remedial action for human or environmental health reasons.
1.3.4Record-Keeping. A record-keeping system is essential to establish trends and patterns in pest outbreaks. Information recorded at every inspection or treatment should include pest identification, population size, distribution, recommendations for future prevention, and complete information on the treatment action. Regular evaluation of the program will help determine acceptable pest population levels, effective reduction measures, and breach of the action threshold.
1.3.5Preference for least-toxic approaches. Improved sanitation and structural repair, physical and mechanical controls such as screens, traps and weeders should be used first to control a pest outbreak. Choose the least toxic chemical control strategy only when a mix of other strategies is shown to be inadequate.
Least-toxic materials to consider include: boric acid and disodium octobrate tetrahydrate; silica gels; diatomaceous earth; nonvolatile insect and rodent baits in tamper resistant containers or for crack and crevice treatment only; microbe-based insecticides; botanical insecticides that do not contain synthetic pyrethroids or toxic synergists; biological, living control agents, such as parasites and predators; soap based products; use of liquid nitrogen for cold treatments; and exempt natural pesticides listed under section 25(b) of the Federal Insecticide, Fungicide and Rodenticide Act [ like corn gluten meal.
It is critical to weigh the risks associated with the use of a pesticide against the problems caused by the pest. Options must be considered carefully, keeping in mind that a chemical solution may have short term or long term health and environmental risks.
1.3.6Prohibition of the most toxic products and practices, as follows:
a)Pesticides classified as acute toxicity Category I and II by the U.S. EPA;
b)Pesticides linked to cancer - U.S. EPA Class A, B, C carcinogens ( and chemicals known to the state of California to cause cancer under Proposition 65 (
c) Pesticides that interfere with human hormones, cause birth defects, reproductive or developmental harm - i.e. those identified as reproductive or developmental toxins ( or chemicals known to California to be reproductive toxins under Proposition 65 (
d) Pesticides in the carbamate (carbaryl, bendiocarb, etc.), organophosphate (diazinon, acephate, etc.) or pyrethroid (cyfluthrin, permethrin, etc.) chemical family or phenoxy herbicides (2,4-D, mecoprop, etc.);
e) Pesticide products that contain inert ingredients categorized by the U.S. EPA as "List 1: Inerts of Toxicological Concern" (dioctyl phthalate, formaldehyde, hydroquinone, isophorone, nonylphenol, phenol, and rhodamine B);
f) Pesticides applied by fogging, bombs, or tenting or by space, broadcast or baseboard sprays;
g) Pest management decisions based on aesthetics alone;
h) Application of pesticides on a routine basis, regardless of the presence of pests;
i) Application of pesticides while the area is occupied or may become occupied during the 24 hours following the application.
1.3.7Providing notice if pesticide application becomes necessary.
With the exception of clear emergencies, hospitals should provide notification to staff and patients at least 72 hours in advance of a pesticide application. Notification may contain the following information: time/date of application; application site, name of pesticide product and active ingredient; and phone number of IPM Coordinator or other person to contact for additional information.
1.4The person responsible for the IPM program (IPM Coordinator) may allow trained staff or the pest control contractor to apply a pesticide listed in 1.3.6(a)-(e) or administer a product by spraying if the Coordinator determines that a pest poses a threat to human health and other least toxic alternatives have been considered but determined to be ineffective. This exemption from prohibition shall be granted on a case-by-case basis only and shall apply to a specific pest problem for a limited time.
1.5IPM Communication. IPM personnel will meet as needed to communicate any discrepancies/ deficiencies identified by the pest control provider, address all discrepancies/deficiencies noted in written reports in a timely manner. This committee will be chaired by the IPM Coordinator and will enlist the support of Facilities Management, Housekeeping, Nurse personnel and other appropriate departments. Quality assurance, request for exemptions, etc. will be agenda items to be discussed during IPM meetings. The IPM personnel will work closely with the Pest Control contractor or provider, if any, in support of an aggressive and effective Integrated Pest Management Program throughout Kaiser Permanente indoor and outdoor property. Request for corrective actions will be forwarded to the appropriate support service/department for expeditious corrective action.
2.0PERSONNEL RESPONSIBILITIES
Responsibilities are assigned to personnel with Integrated Pest Management responsibilities.
2.1Integrated Pest Management (IPM) Coordinators
An IPM Coordinator will be designated for each Kaiser Permanente facility or site and shall be responsible for development and oversight of the IPM program as follows:
2.1.1Act as the facility contact person when pest problems arise
2.1.2Receive annual IPM training.
2.1.3Disseminate information to Kaiser Permanente staff, patients, and the community regarding Kaiser Permanente’s IPM policy and least toxic approach to pest control.
2.1.4Every six months, facilitate IPM training for all environmental services/housekeeping and facilities staff and any other staff who are involved in pest control at a Kaiser Permanente site. Facilitate training for all other staff at least once/year.
2.1.5Meet with pest control service providers to discuss the expectations of the program for communication, application, monitoring and appropriate documentation.
2.1.6Enlist the support of facilities management personnel for timely repairs, pest exclusion projects, etc.
2.1.7Maintain an Approved Pesticides list* along with their labels and MSDS. These documents will be made available for review by staff, employee representative or the public. (*List to be created, identified or adopted by appropriate staff.)
2.1.8Be responsible for ensuring that the pest control contractor reports all pesticide use as required by law to the Department of the Agriculture Commissioner Office.
2.1.9It is the responsibility of IPM Coordinator/Designee to make timely arrangements of appointments for any applications and for timely notification to staff and patients of pesticide application in compliance with sec. 1.3.7, and of the level or extent of evacuation if needed.
2.1.10Ensure that all indoor and outdoor pesticide notification signs are posted at each site in appropriate and visible locations.
2.1.11Review inspection and Quality Assurance forms submitted by the pest control service provider.
2.1.12Work with appropriate personnel to select the Pest Control Contractor.
2.1.13Review and/or revise the IPM plan at least every two years.
2.1.14Consult with the IPM committee when considering any emergency application.
2.1.15Maintain a site-specific notebook in a central location that will contain copies of all quality assurance forms or service record forms submitted by the pest control contractor at each visit. The notebook will also contain a pest sighting log and reporting forms that all appropriate personnel will be trained on filling out. The Pest Sighting Log shall be made available to the pest control contractor at each visit.
2.1.16Maintain direct contact with the pest control service provider and communicate any discrepancies/deficiencies identified by the pest control provider to the appropriate support services department to ensure appropriate follow-up.
2.2Pest Control Provider
Pest Control Providers, both structural and landscape, are selected to safely and appropriately implement the Kaiser Permanente IPM Policy. As a condition of hire, they must demonstrate sufficient knowledge and experience with the least toxic IPM approach to pest management. They are responsible for the following:
2.2.1Adhere to the requirements of Kaiser Permanente’s IPM Policy. The contractor shall notify the IPM Coordinator immediately if any part of the pest management program is out of compliance with the IPM Policy.
2.2.2Work directly with facility IPM Coordinator or his/her Designee to ensure an effective IPM program is implemented at the site.
2.2.3Communicate any discrepancies/deficiencies noted during site visits; this information must be provided in writing.
2.2.4Submit documentation of pesticide usage as required to the Department of Agriculture Commissioner. IPM coordinators may request a copy for site usage records.
2.2.5Make recommendations regarding prevention and remediation in keeping with IPM’s preference for least toxic methods.
2.4Facility Support Services (Plant Services, Building and Grounds, Environmental Services/Housekeeping)
Support Services and Department Head personnel shall report pest sightings, address and complete request for repairs and pest exclusion projects in a timely manner.
3.0EDUCATION, TRAINING AND COMMUNICATION
3.1Education and Training
3.1.1In addition to good structural maintenance, IPM is a preventive approach to pest management that requires knowledge on the part of staff whose responsibilities include pest management, as well as other staff not directly involved in pest control services or practices.
3.1.2At least one time per year, all staff shall receive information and education regarding IPM at Kaiser Permanente facilities. At the inception of this policy and at the time of employment, every staff person shall receive a fact sheet regarding IPM and the part that each staff person plays in its successful implementation.
a)Pests are found in areas where they're getting something they need such as food, moisture, or shelter.
b)The less of these things they can find, the fewer pests there will be.
c)Good sanitation (i.e. eliminating food and other pest attracters) must be observed throughout the medical facilities.
3.1.3Site staff will receive regular Kaiser Permanente IPM educational updates, notices of revision, etc.
4.0PEST SIGHTING, REPORTING, AND MONITORING
4.1 General practices for pest reporting are:
a)Every staff is responsible for reporting pest(s) sightings on the hospital premises to his or her immediate Supervisor.
b)Supervisors and/or Managers will complete "Pest Sighting and Request for Service Form” and forward it to the IPM Coordinator.
c)The IPM Coordinator will log the Sighting Form into the Pest Sightings & Request for Service Log.
d)Upon the Pest Control Contractor visit to Kaiser Permanente locations (three times a week (3x/wk)), Pest control contractor technician reviews sightings/request log, investigates, treats and make technical recommendations as needed. (In writing and orally to IPM Coordinator).
e)It is the responsibility of the IPM Coordinator to contact the Pest Control Contractor for scheduling of Pest Control Services.
4.2Information regarding initial sightings of pests include size; number, time and frequency, and are recorded onto a Pesticide Sighting and Request for Service Form. Housekeeping, Department Heads and Supervisors submit these Forms to the IPM Coordinator.
4.3The IPM Coordinator enters the information from Sighting Form into a facility log maintained by the IPM coordinator, site manager or designee.
4.4The Pest Control contractor will review log upon each visit to the facility.
4.5Monitoring devices such as bait stations, sticky traps, snap traps, metal boxes, glue boards, will be placed as needed in critical areas such as break rooms, rest rooms, nursing unit kitchens, resident drawers, janitors closets etc.
4.6The pest control contractor will keep the facility IPM Coordinator informed of all pest monitoring data and provide written documentation and recommendations for abatement.
5.0PEST MANAGEMENT OPTIONS -- Indoors
5.1Pests
Pests inside structures commonly include German cockroaches, ants and rodents (mice and rats).
5.2Pest Biology and Habitat
Pests will invade buildings when there is opportunity for food, water and shelter. This opportunity can be seasonal or may be triggered by the conditions and use of the building. The IPM coordinator in consultation with the Pest Control contractor will evaluate the pest problem to determine the course of action, including additional monitoring.
There are a variety of options for using least toxic chemical and non-chemical measures to reduce or eliminate pest populations at Kaiser Permanente (See 1.3.5 above re least toxic approaches). Dependent upon the level of pest infestation, the IPM coordinator, site manager/designee along with pest control provider will identify and prioritize such measures for implementation of pest remediation and education of staff.
If a pesticide is used at a facility, inside or outside, every effort is made to optimize the chemical's effectiveness, so that less can be applied. Pesticides shall be carefully chosen and applied according to label instructions
5.1German Roaches
5.1.1Sanitation: There should be no food residue in and around coffee machines, microwaves, refrigerators, trash cans, lids on trash cans, desks, cabinets and patient beds and drawers.
5.1.2Caulking: Pest control service provider will seal cracks and crevices on floors, behind walls and front baseboards where cockroaches gain entrance to nest.
5.1.3Vacuuming and Washing: Pest control service provider will vacuum cracks and crevices areas with a HEPA filter vacuum before treating with bait, and will wash surfaces with soap and water.
5.1.4Sticky Traps and Monitoring Devices: Pest control provider will place traps in locations where roaches were sighted. Inside traps will be observed by Environmental Service personnel and departmental/unit staff for early detection to guide control efforts.
5.1.5Baiting and Crack/Crevice Treatment: Apply baits indoors such as gels, paste and flowable dust. Sources of competing foods should be cleaned up and enough bait stations should be positioned close to the sources of infestation. Avoid any use of residual pesticide spray that would contaminate bait. The pest control provider will use baits listed on the Approved Pesticides List or submit an exemption request to the IPM Coordinator for use of products not listed.
5.1.6Indoor Spraying: Spray treatment will be the "last resort" pest control remediation only after the safer alternative methods have proven ineffective and only in an emergency situation where human health is at risk. The IPM Coordinator must approve any spraying after consulting with the IPM Committee and the pest control contractor. The Coordinator is responsible for ensuring proper notification and posting. (See sec. 1.3.7.) It will be followed up with the application of sticky traps to evaluate the effectiveness of the treatment.
Treatment materials used by the pest control contractor shall be from the Approved Pesticides List. Proper notification and posting before and after treatment and reentry times will be strictly enforced.
5.2Argentine Ants
5.2.1Sealing Entry Points: Pest control service provider contractor inspects and identifies nesting areas. Also check wall voids and planters for nesting ants. Seal cracks around windows, foundation, and exterior walls.
5.2.2Sanitation: Staff are educated and trained in the importance of the elimination of all food residues in and around coffee machines, microwaves, refrigerators, trashcans, etc.
5.2.3Vegetation Management: Gardeners will ensure the cutting back of trees, shrubs and ground cover away from the building sides, roofs and walls to break up the passageways for the ants to enter the building.
5.2.4Baits: The pest control service provider will use baits from the Approved List of Pesticides. The contractor's careful inspection and placement of baits close to the source are needed for control.
5.2.5Spraying: Spray treatment will be the "last resort" of pest control only after the safer alternative methods have proven ineffective. The IPM Coordinator in consultation with the IPM Committee must approve all spray applications and must approve use of pesticides prohibited under sec. 1.3.5 above . It will be followed up with the application of sticky traps to evaluate the effectiveness of the treatment
Treatment materials used by the pest control contractor shall be from the Least Toxic List. Proper notification and posting before and after treatment and reentry times will be strictly enforced
5.3Mice
5.3.1Sealing Entry Points: Seal or block utility entry points using caulk, wire mesh, steel wool or aerosol foam.
5.3.2Cleaning and Housekeeping: All food and trash should be stored in closed containers. Food residual should be removed and piled materials should be completely eliminated.
5.3.3Trapping: The pest control provider uses glue boards, snap traps and metal multiple catch traps. In kitchens, Ketch-Alls traps are used because conventional traps are not applicable.