EFM Policy Structure

From Beyond Pesticides

Tools for Change

Model Program

Resources to Organize an IPM Policy

EFM Policies

Poison Free Malibu EFM Policy – Long Version

Poison Free Malibu EFM Policy – Draft Condensed Version

Policy 50

StepUp!

EFM List of Terms

1. EFM Advisory Committee

This is a citizen-based committee formed to assist in the implementation of the EFM policy. They formulate an allowed Pesticide Use list, oversee emergency use waivers, and assist departments in understanding the policy and report directly to the city council.

2. EFM

Earth Friendly Management, EFM, is a problem-solving strategy that prioritizes an organic, regenerative approach without the use of toxic pesticides. It mandates the use of preventative practices and enrichment strategies that promote healthy soil, plant life, wildlife and safeguarding of structures.

A site-specific Best Management Practices (BMP) plan called STEP UP! emphasizes:

S – Sanitation, T – Teaching, E – Environmental Enrichment, P – Preventative actions, U – Universal, P-Policy – the Precautionary Principle.

The goal is to put a series of preventative steps in place that can naturally attenuate issues before they become a significant concern. 

Careful monitoring and the threshold levels will allow for easier control of issues, if they do arise.

The protocol utilizes an understanding of seeing RED, Repel, Exclude and Deter tactics to establish the proper procedures for maximizing the health of the landscape.

This should mitigate the most serious issues.

Least toxic pesticides may be selected only after all other reasonable non-chemical methods have been exhausted. 

The use of even allowed pest control products should be used on an EMERGENCY basis as opposed to incorporation into routine management programs.

It will also mitigate the potentially negative impact of landscape management on local waterways, air quality, and ecosystems.

When an issue has not been satisfactorily controlled by the above strategies, the emergency approach follows the path to the use of the least toxic pesticides. 

An allowed Organic Pesticide Use list will mitigate issues concerning the pesticide choice. It shall be developed by a citizen-based Environmental Oversight Committee. This body will also oversee emergency use waivers and assist departments in achieving successful implementation of the policy.

Organic choices can be made from the EPA eco-exempt list, OMRI (Organic Material Research Institute) list or similar lists from other organizations that compile organic alternatives.

Limited use emergency exemption materials that do not meet the EFM Policy criteria for use, but are considered critical to the protection of public health and safety as declared by a public health department.

Building blocks of EFM

a) statement of purpose
b) citizen oversight committee
c) selection of emergency organic pesticides
d) The precautionary principle

Education

a) Consumer educational brochures. Available at City Hall, the library, hardware stores, etc.
b) Website exposure
c) Send out yearly letter to businesses, HOA’s to not use poisons

IPM

IPM promotes the use of non-chemical methods for prevention and management of issues utilizing methods such as physical, mechanical, cultural, and biological controls.

IPM is the term that is used loosely with many different definitions and methods of implementation.

IPM can mean virtually anything the practitioner wants it to mean. Beware of chemical dependent programs masquerading as IPM.

Those who argue that IPM requires the ability to spray pesticides immediately after identifying a pest problem are not describing IPM. Conventional pest control tends to ignore the causes of pest infestations and instead rely on routine, scheduled pesticide applications.

Here is a brief history of IPM – https://landscapeipm.tamu.edu/what-is-ipm/history-of-ipm/

3. Eco-Exempt Products

Recommendations are for the use of Federal Insecticide Fungicide and Rodenticide Act (FIFRA) Section 25 (b) Minimum Risk Pesticides established by the US Environmental Protection Agency. Also, materials that are organic in nature are allowed. Materials recommended by the Organic Materials Review Institute (OMRI) or an equivalent certifying body may be used. The California Department of Pesticide Regulation website has a graphic illustrating the Federal guidelines.

4. Precautionary Principle

The precautionary principle (or precautionary approach) to risk management states that if an action or policy has a suspected risk of causing harm to the public, or to the environment, in the absence of scientific consensus (that the action or policy is not harmful), the burden of proof that it is not harmful falls on those taking an action that may or may not be a risk.

The principle is used by policy makers to justify discretionary decisions in situations where there is the possibility of harm from making a certain decision (e.g. taking a particular course of action) when extensive scientific knowledge on the matter is lacking. The principle implies that there is a social responsibility to protect the public from exposure to harm, when scientific investigation has found a plausible risk. These protections can be relaxed only if further scientific findings emerge that provide sound evidence that no harm will result.

The key elements of the Precautionary Principle approach to decision-making include:

  • Anticipatory Action: There is a duty to take anticipatory action to prevent harm. Government, business, and community groups, as well as the general public, share this responsibility.
  • Right to Know: The community has a right to know complete and accurate information on potential human health and environmental impacts associated with the selection of products, services, operations or plans. The burden to supply this information lies with the proponent, not with the general public.
  • Alternatives Assessment: An obligation exists to examine a full range of alternatives and select the alternative with the least potential impact on human health and the environment including the alternative of doing nothing.
  • Full Cost Accounting: When evaluating potential alternatives, there is a duty to consider all the reasonably foreseeable costs, including raw materials, manufacturing, transportation, use, cleanup, eventual disposal, and health costs even if such costs are not reflected in the initial price. Short- and long-term benefits and time thresholds should be considered when making decisions.
  • Participatory Decision Process: Decisions applying the Precautionary Principle must be transparent, participatory, and informed by the best available science and other relevant information.

5. Toxicity Categories – I, II, III, IV

Pesticides, as defined in this section, meeting the appropriate toxicity categories and bearing on the front label panel the word Danger, Warning, or Caution, as specified in Section 156.10 of Title 40 of the Code of Federal Regulations.

6. Trap and release

Prohibits animal trapping with the exception of live trapping animals for immediate release to the surrounding appropriate area.

References

Beyond Pesticides

Beyond Pesticides gateway information

Pesticide Action Network

PAN information database

NCAP Tips for Indoor & Outdoor Pests – Northwest Center for Alternatives to Pesticides

The Rodale Institute

Center for Biological Diversity

Natural Resources Defense Council

Californians for Pesticide Reform

Pesticide Watch

California Public Interest Research Group

California Healthy Schools Act

Our Children at Risk from the Natural Resources Defense Council

Testimony of two UC Irvine professors

Wide Range of Diseases Linked to Pesticides

Code of Federal Regulations for Eco-Exempt Products

OMRI Product List

National Organic Program

Cost comparison of chemical versus organic turf management

PesticideFreeLocalities

In addition, here are some pesticide free cities in the United Kingdom and Europe – http://www.pan-uk.org/pesticide-free/

The Four Laws of Ecology (Barry Commoner, 1917-2012)

Dr. Barry Commoner is known to many general readers as the formulator of “The Four Laws of Ecology.”  A cellular biologist and college professor, in 1970 TIME magazine featured him as “the Paul Revere of Ecology” in a cover story.  Some today regard him as the greatest environmentalist of the 20th century.  His books include The Closing Circle: Nature, Man and Technology (1971) and Making Peace With the Planet (1990).

The “Four Laws of Ecology,” with various simple explanations given on different web sites, and which can be applied to ones daily life, are:

  1. Everything Is Connected To Everything Else. There is one ecosphere for all living organisms and what affects one, affects all.  Humans and other species are connected/dependent on other species.  With this in mind it becomes hard to practice anything other than compassion and harmlessness.
  2. Everything Must Go Somewhere. There is no “waste” in nature, and there is no “away” to which things can be thrown.  Everything, such as wood smoke, nuclear waste, carbon emissions, etc., must go somewhere.
  3. Nature Knows Best. Humankind has fashioned technology to improve upon nature, but such change in a natural system is, says Commoner, “likely to be detrimental to that system.”  The Creation, one can argue, has an intelligence, and to tinker with that “unintellectually” we get global warming, pollution, etc.
  4. There Is No Such Thing As A Free Lunch. Exploitation of nature will inevitably involve the conversion of resources from useful to useless forms.  In nature, both sides of the equation must balance, for every gain there is a cost, and all debts are eventually paid.

What Is Integrated Pest Management? from Beyond Pesticides

A well-defined Integrated Pest Management (IPM) is a program that should be based on prevention, monitoring, and control which offers the opportunity to eliminate or drastically reduce the use of pesticides, and to minimize the toxicity of and exposure to any products which are used. IPM does this by utilizing a variety of methods and techniques, including cultural, biological and structural strategies to control a multitude of pest problems.

IPM is a term that is used loosely with many different definitions and methods of implementation. IPM can mean virtually anything the practitioner wants it to mean. Beware of chemical dependent programs masquerading as IPM.

Those who argue that IPM requires the ability to spray pesticides immediately after identifying a pest problem are not describing IPM. Conventional pest control tends to ignore the causes of pest infestations and instead rely on routine, scheduled pesticide applications. Pesticides are often temporary fixes, ineffective over the long term.

Non-toxic and least toxic control products are a major growth area and new materials and devices are increasingly available in the marketplace.

The Six IPM Program Essentials

Monitoring. This includes regular site inspections and trapping to determine the types and infestation levels of pests at each site.

Record-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.

Action Levels. Pests are virtually never eradicated. An action level is the population size which requires remedial action for human health, economic, or aesthetic reasons.

Prevention. Preventive measures must be incorporated into the existing structures and designs for new structures. Prevention is and should be the primary means of pest control in an IPM program.

Tactics Criteria. Under IPM, chemicals should be used only as a last resort only, but when used, the least-toxic materials should be chosen, and applied to minimize exposure to humans and all non-target organisms.

Evaluation. A regular evaluation program is essential to determine the success of the pest management strategies.

Integrated Pest Management (as defined by Beyond Pesticides)

IPM is a managed pest management system that:

  • eliminates or mitigates economic and health damage caused by pests; 
  • minimizes the use of pesticides and the risk to human health and the environment associated with pesticide applications; and
  • uses integrated methods, site or pest inspections, pest population monitoring, an evaluation of the need for pest control, and one or more pest control methods, including sanitation, structural repairs, mechanical and living biological controls, other non-chemical methods, and, if nontoxic options are unreasonable and have been exhausted, least toxic pesticides. 

Least Toxic Pesticides (as defined by Beyond Pesticides)

Least toxic pesticides include:

The term ‘least toxic pesticides’ does not include a pesticide that is:

  • determined by EPA to be a possible, probable, or known carcinogen, mutagen, teratogen, reproductive toxin, developmental neurotoxin, endocrine disruptor, or immune system toxin; 
  • a pesticide in EPA’s toxicity category I, II or III; and
  • any application of the pesticide using a broadcast spray, dust, tenting, fogging, or baseboard spray application.