9 - Responsible Pesticide Management
Pesticides contain active ingredients (the component that targets the pest) and inert ingredients such as solvents, surfactants, and carriers. Both the active and inert ingredients are regulated by federal, state, and local laws because of environmental and health concerns.
When a pesticide application is deemed necessary, its selection should be based on:
Effectiveness
Method and frequency of application
Potential toxicity to non-target species
Cost
Site characteristics
Pesticide solubility
Persistence
Packaging and labeled for the site it will be used at
Safety of the applicator
Equipment available for application
Pesticides may be used as one element in an integrated pest management (IPM) strategy, alongside biological controls, cultural methods, pest monitoring, and other applicable practice.
Wisconsin Pesticide Regulations
A restricted use pesticide (RUP) is a pesticide that is designated as such due to potential adverse effects on the environment, the applicator, or bystanders, which warrants added restrictions. Anyone who wants to purchase and use a RUP must be a certified applicator.
In addition, in Wisconsin, no person may distribute, sell, offer for sale or use any pesticide product containing any of the following active ingredients:
2,4,5-trichlorophenoxyacetic acid (2,4,5-T)
2-(2,4,5-trichlorophenoxy) propionic acid (Silvex)
Aldrin
Chlordane
Dieldrin
Heptachlor
It is the joint responsibility of the person in control of golf course maintenance and the applicator to ensure the application complies with regulations and that correct recordkeeping is maintained.
There are also regulations concerning the required signage and communications when pesticides are used in golf course settings. All pesticide applications on golf courses must be posted. Permanent warning signs may be used, but golf course superintendents must also post restricted entry interval (REI) warning signs when a defined REI time is listed on the pesticide label. Note that an REI of ‘when dry’ is not considered a defined interval and does not require an REI warning sign.
Permanent warning signs must be conspicuously posted at each of the following locations:
At or near the place where golfers register to play the course
At or near the first tee of every nine holes
At every point on the golf course boundary at which the non-golfing public is permitted to enter the golf course by means of a road, sidewalk, path or other established thoroughfare
Best Management Practices
Comply with all Federal, Environmental Protection Agency (EPA) and Wisconsin State laws and regulations
Select the least toxic pesticide with the lowest exposure potential and use reduced risk pesticides where appropriate
Follow all directions on pesticide’s labeling
Follow all instructions on the pesticide label – including sprayer calibration, mixing, and use of Personal Protective Equipment (PPE)
Ensure facilities for storing, handling and mixing are properly sited, designed, constructed, and operated
Develop an emergency response plan including procedures to control, contain, collect, and store spilled materials
Create a record for each application of a RUP; maintain record for two years
More information specific to golf courses:
https://datcp.wi.gov/Documents/HTCLandscapeApplications.pdf
A full list of pesticides registered in Wisconsin, including RUPs:
http://www.kellysolutions.com/wi/
In the case of a pest control treatment project with a pollutant discharge to a water of the state specific permits are required from the WDNR. More information:
https://dnr.wisconsin.gov/topic/Wastewater/AquaticPesticides.html
Wisconsin State Legislature on pesticide use:
https://docs.legis.wisconsin.gov/statutes/statutes/94/68
https://docs.legis.wisconsin.gov/code/admin_code/atcp/020/29.pdf
Personal Protective Equipment (PPE) & Human Health Risk
Pesticides belong to numerous chemical classes that vary greatly in toxicity. The degree of potential risk to human health depends on both the pesticide toxicity and the level of exposure- i.e., the amount of product and length of time involved with any contact. PPE is used for protection against chemicals contacting the person loading, mixing, and spraying the chemical. The pesticide label will provide guidance on the minimum required PPE, it is important to read the label thoroughly before any use. Users must always use at least the minimum PPE required but may also choose to use more PPE than required on the label.
There are four toxicity levels, indicated by pesticide signal words that help provide indicators for what level of risk is present when applying:
Best Management Practices
Employers are legally responsible for supplying applicators with the PPE as listed on the label
Clearly post landscape warning signs when applying pesticides. Follow the landscape pesticide applications to golf courses guidance from WDATCP: https://datcp.wi.gov/Documents/HTCLandscapeApplications.pdf
Ensure that PPE is sized appropriately for each person using it
Make certain that PPE is appropriate for the chemicals used
Choose PPE based on standards, not just the least expensive
Store PPE where it is easily accessible, but not in the pesticide storage area
Employees who apply pesticides should not wear facility uniforms home where they may come into contact with children
Provide laundering facilities or uniform service for employee uniforms; employees will need to wash clothes that may have pesticide residues on them; washing requires the use of hot water with clothes that are suspected to have pesticide residues; run another empty load once the clothes are washed
The federal Occupational Safety and Health Administration (OSHA) requires employers to fit-test workers annually who must wear tight-fitting respirators
When using respiratory protects ensure compliance with Occupational Safety and Health Administration (OSHA) 1910.134 Respiratory Protection Program
Provide employees access to Safety Data Sheets (SDS) of the products being used
Application, Storage & Transport, Emergency Response, Record-Keeping
Responsibilities of Pesticide Owners, Users, or Handlers
Pesticide owners, users and handlers all have a responsibility to fully understand the risks and guidance around any pesticide being used. It is important that anybody involved with pesticide use or management is appropriately trained and certified where required. The Wisconsin Pesticide Law mandates that any person using RUPs, and all commercial applicators, complete training and certification through the UW-Pesticide Applicator Training (PAT) program.
Training and certification are separate and different entities are involved. The PAT program provides training and educational materials for people to become certified: https://fyi.extension.wisc.edu/pat/
Certification (passing an exam) is overseen and regulated by the DATCP.
There are several different certification categories, including Turf and Landscape.
Applicators need to complete this WDATCP license application: https://datcp.wi.gov/Documents/ComPestAppLicense.pdf
Additional license requirements and information: https://datcp.wi.gov/Documents2/PesticideLicensingFactSheet.pdf
https://datcp.wi.gov/Pages/Licenses_Permits/CommercialApplicator.aspx
Also reference the Pesticides Applications Compliance Checklist: https://datcp.wi.gov/Documents/HTCLandscape.pdf
Information on EPA Federal Worker Protection Standards, communications, and training: https://www.epa.gov/pesticide-worker-safety
Sprayer Calibration
Calibration of sprayer equipment is critical to good pesticide management. Pesticide application equipment must be properly calibrated to mitigate environmental and human health risks relating to pesticide use and spray technicians must always be experienced, licensed, and properly trained.
Best Management Practices
Use an appropriately sized applicator for the size of area being treated
Minimize off-target movement by using properly configured application equipment
Calibrate all application equipment at the beginning of each season (at a minimum) or after equipment modifications
Check equipment daily when in use
Walk-behind applicators should be re-calibrated for each person making the application to take into consideration their walking speed, etc.
Always use recommended spray volumes for the targeted pest to maximize efficacy
Keep pressure at the setting recommended by the nozzle manufacturer
Use low-volatility herbicides when possible
Environmental Fate and Transport
‘Environmental fate’ refers to the destiny of any chemical, biological substance or pollutant after release into the environment. Pesticides, wherever they are applied, have the potential to interact with wildlife or migrate into surface and subsurface waters. Environmental fate information is included on pesticide labels and indicates where a pesticide travels following introduction and likely exposure levels for non-target organisms (soil, water, air, plants, and animals).
A key environmental consideration concerns the runoff and leaching potential of a selected pesticide – i.e., the extent and direction of any likely cross contamination from the application site to nearby areas. Prior to application, it is therefore important to consider the specific characteristics of each site.
Key issues include:
Proximity to surface water
The water table and well-heads
Soil type
Prevailing winds
Presence of endangered species
Environmental hazards related to a pesticide are listed on pesticide product labels. “Environmental Hazards” are found under the general heading “Precautionary Statements,” which provides language advising the user of the potential hazards to the environment and off target organisms – found under three headings: general environmental hazards, non-target toxicity, and endangered species protection.
Best Management Practices
Select pesticides that have a low drift, runoff, and leaching potential; labels provide warnings about these potential issues with each product
Before applying a pesticide, evaluate site-specific characteristics, particularly relating to water sources, surface water, water table, and well-heads, soil type and wind direction
Understand site characteristics that are prone to leaching losses (for example, sand-based putting greens, coarse-textured soils, shallow water tables)
Select pesticides with reduced impact on pollinators and natural pest predators
Select pesticides that, when applied according to the label, have no known effect on endangered species present on the facility
Wisconsin’s Groundwater law (ATCP 31) created two guidelines to limit pesticides in groundwater which include enforcement standards (maximum chemical levels allowed in groundwater) and preventive action limits (set as a percentage of the enforcement standard). The DATCP provides monitoring for pesticides including groundwater from private wells and surface water.
Additional information: https://datcp.wi.gov/Pages/Programs_Services/SurfaceGroundwaterMonitoring.aspx
Pesticide Transportation, Storage, and Handling
As pesticides pose their greatest risk when in concentrated form it is essential to follow all storage, transportation, and handling guidance on product labels. The location, design and operation of storage facilities all have a role in minimizing risks related to pesticides. Improper storage of pesticides is a form of misuse and it is therefore important to carefully review and comply with storage information on labels.
The key risks to human health and the environment when considering pesticide storage and transportation are focused on potential spills, contaminated run off or fire. Storage facilities must be properly sited, designed, constructed, and operated in order to minimize these risks. To mitigate water contamination risks pesticide storage facilities should be at least 400 feet downhill from drinking water supplies; 200 feet from surface water and should not be placed within the 100-year floodplain.
Best Management Practices
Storage facilities should be a lockable concrete or metal building with sufficient access to allow fire department approach
Storage facilities should facilitate the secure, dry, and temperature-controlled storage of pesticides, in line with label guidance
Personnel should have easy access to PPE, stored outside of the pesticide area
Snow cover in storage areas should be considered in terms of run-off risk
Store, mix, and load pesticides away from sites that directly link to surface water or groundwater
Storage facility floors should be watertight and sealed with a chemical resistant paint; the floors should have a continuous sill to retain spilled materials and no drains, although a sump may be included
Sloped ramps should be provided at the entrance of storage facilities to allow the use of wheeled handcarts for moving material in and out of the storage area safely
Shelving and surfaces in the pesticide storage and transportation should never be made of wood as wood surfaces can absorb spilled pesticides; all shelving should be made of sturdy plastic or reinforced metal, painted to avoid corrosion
Automatic exhaust fans and an emergency wash area are recommended
Light and fan switches should be located outside the building, so that both can be turned on before staff enter the building and turned off after they leave the building
Avoid temperatures less than 40°F or greater than 100°F inside the pesticide storage facility
Do not transport pesticides in the passenger section of a vehicle and never leave pesticides unattended during transport
Place a spill containment kit in the storage area, in the mix/load area, and on the spray rig
Fire extinguishers suitable for chemical fires should be readily available
The local fire department should be informed about the storage unit, what it contains, and where it is located
Pesticide Inventory
Pesticides degrade over time, so it is important to only mix the amount required for use at any time and to avoid storing large quantities of pesticides for long periods. When bringing in new product, date the labels to be able to identify the oldest in inventory. Adopt the “first in–first out” principle, using the oldest products first to ensure that the product shelf life does not expire. This will reduce the amount of pesticide waste product which needs to be disposed of.
Best Management Practices
Do not purchase pesticides in greater quantities than needed and avoid purchasing large quantities of pesticides that require storage for greater than six months
Following the “first in–first out” principle to ensure oldest products are used first and minimize quantities of expired stock
Utilize computer software systems to record inventory and use, when possible
Consult inventory when planning and before making purchases
Store flammable pesticides separate from those that are non-flammable
Store liquid materials below dry materials to prevent leaks from contaminating dry products
SDS and copies of labels for all pesticides on hand should be kept in an easily identifiable location, outside the pesticide storage facility
Make sure all containers are labelled correctly and arranged so the labels are clearly visible Immediately replace any damaged or missing labels
Maintain inventory copies off site for review in case of fire to help containment issues
Pesticide Mixing/Loading/Washing
Handling open pesticide containers, measuring pesticide materials, or working with pesticide application equipment presents an exposure risk to the handlers and the environment. PPE is an important part of minimizing this risk and must be worn, in line with label guidance, prior to opening of pesticide packages.
Pesticide leaks or spills, if contained, will not percolate down through the soil into groundwater or run off the surface to contaminate streams, ditches, ponds, and other waterbodies. One of the best ways to manage this issue is to ensure the chemical mixing center (CMC) is properly designed and constructed.
Mixing is an important part of proper spraying application. It is essential that all staff involved fully understand what is being sprayed and which chemicals can be mixed. The specific mixing and sequence of mixing instructions on the label should be followed - the most common accidents occur due to staff misunderstanding mixing rates, becoming distracted and/or mixing the wrong materials. If uncertain, a jar test should be prepared to make sure the chemicals are compatible. A jar test is a simple method of using small samples of the mixture and mixing in a small jar. This will allow observation of the reaction and make sure a complete mixture can be achieved.
Best Management Practices
Loading pesticidesand mixing them with water or oil diluents is recommended over an impermeable (watertight) surface, so that spills can be collected and managed
The mixing station surface should offer easy cleaning and the recovery of spilled materials
Mixing and loading sites should have secondary containment
Pump the sump dry and clean it at the end of each day
Liquids and sediments should be removed from the sump and properly managed and disposed of
Apply liquids and sediments from the sump the same as a pesticide, strictly following label instructions
Sweep up solid materials and use as intended
Rinsate may be applied as a pesticide (preferred) or stored for use as makeup water for the next compatible application - caution: do not mix herbicide rinsate with other products
Collect wash water (from both inside and outside the application equipment) and use it as a pesticide in accordance with the label instructions
Pesticide Container Disposal
Pesticide containers, if not rinsed and disposed of properly, can cause a risk to human health and environment. As such federal law (FIFRA) considers that a pesticide container is not legally empty until properly triple rinsed and requires pesticide applicators to rinse all empty pesticide containers before taking other container disposal steps. Containers for non-liquid pesticides (bags, drums, bottles) need to be triple-rinsed or have the ends removed and all product removed from the container before disposal. Unrinsed pesticide containers are considered hazardous waste and improper disposal can result in fines and/or criminal penalties. Once properly rinsed, however, pesticide containers can be handled and disposed of as non-hazardous waste.
DATCP manages an annual grant program for counties and municipalities wishing to collect unwanted pesticides. Businesses with agricultural pesticides may be eligible for up to 50 percent subsidy on disposal costs. More information: https://datcp.wi.gov/Pages/Programs_Services/CleanSweep.aspx
Best Management Practices
It is illegal to dispose of excess pesticides by dumping them on the ground; while pesticides are broken down to non-toxic compounds by microorganisms, excessive amounts applied to the soil can “overload” this natural system and contaminate drinking water
Refer to the label for disposal requirements
Rinse containers during the mixing and loading process and add rinsate water to the finished spray mix
When a pesticide container is empty fill it up with water three times, each time pouring the rinse water into the spray tank when preparing the solution for final application; this is called triple rinsing and is important to remove chemical residues
Puncture or crush empty and rinsed pesticide containers and dispose of according to the label
It is against the law to use empty pesticide containers for another function
Emergency Preparedness and Spill Response
It is essential to have an emergency preparedness plan in place to ensure that if an accident occurs it is clear which steps to take to mitigate human health effects and environmental impact. Emergency preparedness plans should have copies stored close to pesticide storage facilities and should be shared with local police and fire departments.
Anyone who spills fertilizers or pesticides is legally responsible for cleaning up the spill if it harms or threatens to harm public health or the environment, regardless of the amount of the spill.
Report pesticide or fertilizer spills immediately to the WDATCP Spills Hotline if the amount is:
250 pounds or more of dry fertilizer
25 gallons or more of liquid fertilizer
Enough pesticide to cover one acre or more if applied at label rates
Additional information on spills and the Wisconsin Spill Law: https://cdn.shopify.com/s/files/1/0145/8808/4272/files/A3714.pdf
Contact the DATCP Agricultural Chemical Cleanup Council at (608) 224-4500 or email datcpaccp@wisconsin.gov.
Best Management Practices
Develop a golf course facility emergency preparedness plan that includes procedures to control, contain, collect, and store spilled materials
Maintain copies in English and any other language commonly used by employees
Ensure an adequately sized spill containment kit is readily available
Designate a spokesperson who will speak on behalf of the facility should an emergency occur
Seek advice from local authorities – policy and fire departments - on ways to improve the plan
Have emergency contact information clearly visible at the storage facility and offsite
Pesticide Record-Keeping
Pesticide-specific record-keeping can be required by Federal or state rule, in addition to the pesticide label. Pesticide applicators who have a private applicator license or certificate are required to maintain records of their applications of RUPs under the Food, Agriculture, Conservation and Trade Act of 1990: https://www.ams.usda.gov/rules-regulations/pesticide-records/understanding.
Anyone using a RUP, or anyone required to be licensed as a commercial applicator must maintain records of their pesticide applications under Wisconsin State Law ATCP 29.
Records must contain:
Product name
EPA registration number
Concentration or amount applied per area and total quantity applied
Date and time of application (time application began, and time application ended)
Location of land/legal property description
Site treated
Total acres or volume of area treated
Location of mix/load site
Applicator name and license number and/or person supervising the application
Who the application was made on behalf of (if applicable)
Records should also contain:
Pest treated
Wind direction and velocity and air temperature
ID number of application equipment
Spray permit number for regulated herbicides applied in a regulated county
Documentation to verify training of persons working under the supervision of a licensed pesticide applicator
A Wisconsin record-keeping form may be accessed at: https://fyi.extension.wisc.edu/pat/files/2018/01/recordkeeping-form.pdf
Additional information:
https://fyi.extension.wisc.edu/pat/pat-tools/
https://datcp.wi.gov/Documents/HTCLandscape.pdf
Best Management Practices
Records must be recorded within 14 days of application and maintained for two years for RUP applications per Federal requirements
Records must be kept accessible and available for copying and must be maintained at the applicator’s primary place of business as designated on the applicator’s pesticide license
Records of application must be made available for inspection upon request
Keep a backup set of records in a safe, but separate storage area
Use records to monitor pest control efforts and to plan future management actions
There are several resources available to assist with record-keeping, covering everything from inventory through to planning and reporting. Examples include:
GreenKeeper https://www.greenkeeperapp.com/marketing/
OnLink https://onlink.com/
PeRK https://cropwatch.unl.edu/unl-releases-perk-20-pesticide-recordkeeping-app
Playbooks for Golf https://goplaybooks.com/coverage.html
Sparks https://sparks2.com/
