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



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

NCAP Tips for Indoor & Outdoor Pests

Pesticide Action Network pesticide database

Cost comparison of chemical versus organic turf management

Ojai Pest Management

Pesticide Free Localities

In addition, here are some pesticide free cities in the United Kingdom and Europehttp://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.

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.

2. EFM / IPM

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

It utilizes a site specific STEP UP! plan emphasizing:

S – Sanitation, T – Teaching, E – Environmental Enrichment, P – Preventative actions, – 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 cultural practices, soil dynamics, grass biology, natural deterrents, repelling and exclusion tactics to establish the proper procedures for maximizing the health of the landscape. This should mitigate the most serious issues.

The US EPA, California Department of Pesticide Regulation, the Center for Disease Control, and the California Healthy School Act recommend the use of an Integrated Pest Management (IPM) program for local governments and schools.

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

This approach will eliminate or significantly reduce the use of, and exposure to, pesticides in the management of lawn areas, playing fields, landscapes, and structures.

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.

Special Use Pesticides are 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.

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. Pest

A pest may be known as undesirable plants, insects, fungi, bacteria, rodents, birds, and other animals. Common examples in turfgrass and the landscape are crabgrass, knotweed, poison ivy.

5. 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.

Ventura County Statement of Precautionary Principle

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

a. 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.

b. 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.

c. 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.

c. 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.

e. Participatory Decision Process: Decisions applying the Precautionary Principle must be transparent, participatory, and informed by the best available science and other relevant information.


A site-specific program to protect citizens, pets and wildlife


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

7. 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.