Environmental, Health and Safety Services

Pesticides

Preface

The Commonwealth of Virginia has developed and implemented a detailed program for applicator training, certification, and pesticide use in compliance with applicable state and federal regulations. Virginia Tech faculty and other personnel work closely with state representatives to ensure the programs are current, functional, and implemented properly. Protocols used on campus will not replace or supersede any requirements mandated by the Virginia Department of Agriculture and Consumer Services, Office of Pesticide Services (VDACS, OPS).

Scope

Pesticide use on university property and/or by Virginia Tech personnel is designated as commercial use by definition and scope of work. State law requires that individuals be trained and certified within 90 days of employment.

Responsibilities

Departments with individuals (faculty, staff, and students) using pesticides, either in research or as part of their position responsibilities must follow requirements defined by the Virginia Tech Pesticide Programs (VTPP) for training, certification, supervision, etc.

Supervisors of pesticide operations must be appropriately trained and certified according to VDACS OPS guidelines, and must provide for the safe and appropriate use of all pesticides used in work applications. Please refer to the Pesticide Applicator Overview developed by VTPP. This includes:

  • Training (within 90 days of employment) and certification of all individuals using pesticides,
  • Availability and use of appropriate personal protective equipment (as documented on the Hazard Assessment Form,
  • Proper storage, handling, and disposal of pesticides, and
  • Recordkeeping and postings.

If a research project is involved, a responsible person must be designated before pesticides are used. Experimental products must be handled in such a manner as to minimize potential risks to university personnel and property. All experimental products must be obtained through appropriate procurement procedures, which includes registering the products, reporting quantities, and coordinating the return of any materials not used during the trial period.

Employees working with pesticides are responsible for:

  • Attending and obtaining necessary training and certification,
  • Wearing assigned personal protective equipment, and
  • Handling the products in a safe manner and according to label requirements.

Contractors using pesticides as part of a project with the university must follow requirements mandated by the Commonwealth of Virginia. Please refer to the VTPP site for Commercial Applicator Overview compliance details.

Environmental, Health and Safety (EHS) works to ensure safe work practices, compliance, and serves as liaison between regulatory officials and university administration. Personnel will use guidelines given through VTPP, and in other applicable parts of the Hazardous Chemical Management Program when conducting audits, evaluations, consultations, and when reviewing site assessments for proposed pesticide storage/mixing facilities.

The University Chemical Hygiene Officer (UCHO) is responsible for coordinating the requirements of this program, which include:

  • Evaluation of pesticide storage and security practices,
  • Ensuring proper site development and postings,
  • Reviewing training documentation and product application records, and
  • Consulting, as needed.

Storage Requirements

Proper storage of pesticides is just as critical and specific as with any other chemical product. Recommendations for storage and handling contained elsewhere within this document are also applicable to pesticides, including maintaining a "Chemical Inventory"; however, this inventory should be kept at a separate location in the event of an emergency at the storage facility that impacts access or presents loss risk.

Each pesticide container should be marked with the date of purchase before it is placed in storage. Since many pesticides have a "shelf-life", older products should be used first. Additionally, only purchase quantities that will be used up within one year or the duration of the project.

Empty waste containers and pesticide products for disposal should be kept in a separate part of the facility. Ensure that waste materials are easily identifiable as waste in order to minimize confusion.

Remember to always follow the product label for storage requirements.

Storage Facilities

An appropriate storage facility must be provided that is environmentally acceptable and secure. The area must be kept clean, dry, and at the appropriate temperature in order to maintain the integrity of the product. Product labels will help identify specific segregation criteria. Site postings must be included to protect users, the public, and emergency response personnel. Refer to VCE or VTPP info for futher details.

Site assessments are recommended for all pesticide storage areas. Human and environmental safety issues must be considered before constructing new facilities and when evaluating current operations. First, determine the proximity of the proposed site to sensitive places, such as residential lots, ground and surface water sources, livestock areas, fertilizer storage facilities, etc. In addition, the location with regard to prevailing winds, traffic patterns, and security in the event of an emergency, must be evaluated. Before new site construction begins, baseline environmental information must be obtained for review as part of the assessment. This data is obtained from soil, surface, and groundwater sample analyses, available historical information, and visual observations. Copies of all assessment data collected must be forwarded to EHS for environmental review. For assistance, contact EHS at 231-2510.

  • Facility Site Plans are an essential part of the site assessment. This plan is critical for compliance with Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), Resource Conservation and Recovery Act (RCRA), Superfund Amendments and Reauthorization Act (SARA) and other associated regulations. In addition to the previously mentioned observations, the site plan should include:
    • Soil type and topography
    • Water table, depth to groundwater, and flood plain delineations
    • Watershed and associated drainage information
    • Location in relation to other material storage areas (e.g. fertilizer, fuels, feed, equipment)

Design issues for setting up the storage facility should also be considered. Construction materials, security features, segregation requirements, size, and environmental controls must also be taken into account.

  • Interior floor and wall surfaces must be chemically impervious and easily cleaned. Examples include plastic, vinyl, and some coated/painted metals. Concrete is porous and must be treated with appropriate protective coatings in order to prevent absorption. Wood is permeable and difficult to seal, and should not be used for permanent flooring. Individual wood units (e.g. pallets) can be used in certain circumstances since they can be easily disposed of in the event of a spill.
  • Appropriate secondary containment systems must be used inside the facility. Such systems include raised floor sills and ramps, open grate trenches with sumps, and tubs for smaller containers. Outside, the use of constructed curbs, pads, and grate drains can help contain accidental spills and water run-off in the event of a fire.
  • Do not connect drains or sumps to a sewer or septic system or other open discharge.
  • Shelving, like floors, must also be chemically impervious. Shelves must be constructed with lips, sills, or secondary containers used in order to prevent spills and contamination from shelf to shelf. Do not exceed the load limits of the cabinets or shelves.
  • Pesticide storage buildings must meet all applicable fire and electrical code requirements. Related issues include storage criteria for flammable and combustible materials and explosive venting. Suppressant fire systems utilizing dry chemical are the preferred fire control method due to water run-off and contamination issues. placard
  • Storage areas must be placarded or labeled to show pesticide storage and "No Smoking".
  • Ventilation is critical to minimizing fire, explosion, and health risks. Warm weather ventilation reduces temperature extremes and vapor accumulation. In unheated storage spaces, natural ventilation may be the best alternative. Wall vents are most effective at floor level (within 12 inches) since most flammable vapors are heavier than air. In large storage facilities, mechanical ventilation is much more effective. Generally, systems should provide approximately six air changes per hour. Fans and ducts should be designed to move the entire air volume from the room involved to ensure heavier air vapors are removed. Systems must also be explosion -proof when Class I liquids are involved.
  • Do not store pesticides in basements or below grade level where vapors may accumulate.

In summary, all pesticide storage areas must be designed to provide a secure, stable environment with adequate ventilation, and must meet all applicable fire and electrical code requirements. Storage guidelines put forth by VTPP are used by EHS personnel for evaluation criteria.

 

Security

Pesticide storage areas must be constructed to prevent unauthorized individuals from gaining access. If pesticides are kept in a general use area or laboratory, then precautions must be implemented to restrict access. Perimeter fencing, buildings, and/or cabinets with locks are all examples of secure storage areas.

Spill Response

Spill response supplies must be maintained at the storage facility. Extra sets of personal protective equipment (i.e. gloves, boots, Tyvek® suits, etc.) should be available, as well as a non-sparking shovel and some type of absorbent material (ex. kitty litter). Other items that may be needed depending on the materials involved are respirators, coveralls, and chemical absorbent pads ("pigs"). A careful review of all pesticides in storage must be performed to identify risks involved and to determine the items required to contain and control small spills.

Pesticide containers should be routinely inspected to verify the integrity of containers and labels. Look for leaks, damaged bottles, faulty aerosols, tears/splits in bags, etc. If a material is found leaking or the container is damaged, there are several options:

  • Try to use the pesticide immediately at a site and rate allowed by the label.
  • Transfer the material into another container that originally held the same product.
  • Transfer the contents to an appropriate container that can be closed. If possible, remove the label from the damaged container and place it on the new one. Otherwise, label the secondary container with the product name and registration number and request another copy of the label from the dealer or manufacturer.
  • Place the entire damaged original container into a suitable larger secondary container. If the label is no longer legible, use the name and registration number to request another copy as noted above.
  • Never put pesticides in unlabeled or unsuitable containers.

Pesticide Application

Pesticide use for the university primarily revolves around three types of applications:

  • Research and development, specifically experimental products - some may be registered and some may be going through further studies under the direction of university personnel. In these cases, application rates and size of test areas may vary significantly. Production methods may be appropriate while at other times a smaller scale approach may be required.
  • Grounds maintenance, including the use of herbicides, insecticides, rodenticides - these cases are almost entirely small scale and involves travel distance and time between applications.
  • Production, including field crops, forest, pasture, and orchard management, marine anti-foulant painting, and livestock health - this application typically involves larger target areas and increased volume of product. In addition, the location of target areas may involve some travel distance between storage areas and sites of application. This can include moving pesticides on public highways, in proximity to private property, and/or near environmentally sensitive areas, such as private water sources, creeks, and ponds.

The scale of the operation and the expected or desired outcome are also factors to consider when planning an application. In general, the outcome or objective must be clearly defined and the least toxic product possible must be selected. In addition to following label directions and precautions, pay special attention to weather conditions, proximity of non-target flora and fauna, and human activities within or near the area. The differences in the groups mentioned above further dictate options available to the applicator.

Mixing

There are two primary methods of mixing pesticides for applications considered within the scope of this program. They are "in-house" (or other designated area) and "in-field". The operation or application process will dictate which process is most applicable.

In-house Preparation

For smaller scale operations involving experimental products, grounds, or veterinary applications, the ability to prepare materials inside a shop or lab is advantageous due to availability of clean water, spill containment, and personal protective equipment. The water source must be protected from product contamination by work practices, such as keeping water hoses above levels of pesticides when mixing, and through the use of devices designed to prevent back siphoning. Special precautions must be taken to prevent spills or waste products from entering the wastewater system. Avoid using sinks directly connected to wastewater lines.

  • If floor drains are present, verify that they are not connected to a septic tank or wastewater discharge line before allowing any spill or cleanup water to enter. All affected drains and lines should be connected to a separate holding tank with a sump. After each mixing, any liquid collected into the reservoir can be removed and applied to the target area as rinsate.
  • In the absence of a holding tank, secondary containment should be used to control spills. Use large tubs to hold small portable sprayers while mixing product and rinsing containers. Any material collected in the secondary container can then be placed into the sprayer for application as with rinsates.
  • In rare cases, rinsates are not suitable for adding to tanks and applying on target areas. Special care must be taken to collect rinsates and dispose of them as waste pesticide products. Specific examples include:
    • The product labeling restricts rinsate use as a dilute, as in the case of strongly acidic or alkaline agents.
    • The rinsate contains strong cleaning agents that may harm the target organism.
    • The rinsate solution may not be compatible with or may make a mixture unstable.
    • The original product was used in an animal dose case (e.g. pour-ons for livestock).

In-field Preparation

Large scale applications usually involve production operations. The repeated draining of pesticide residuals (product and rinsates) onto a small area increases the risk of groundwater contamination. Providing a system to mix chemicals and rinse equipment in the field helps to reduce some of the risks associated with handling and wash-down facilities. Some advantages to on-site or in-field mixing include:

  • Minimization of bio-accumulation from repeated spills or leaks in the same small mixing area.
  • Prevention of buildup of waste mixtures of different pesticides by eliminating the use of a holding tank for spill cleanup.
  • Reduced costs by eliminating the need for above mentioned holding tanks, sumps, and increased waste disposal costs.
  • Reduced risk of spills while in transit; less impact on non-target plants, animals, and surrounding environment.
  • Simplification of the preferred practice of applying tank tailings and rinsates on labeled crops.

There are equipment requirements for successful in-field preparation.

  • A nurse tank with hoses and pump to provide a clean, adequate water supply is imperative. It can also be used for emergency showering, if properly plumbed and potable.
    • Permanently mark the nurse tank (i.e. clean water tank) so that it is used only for clean, potable water.
  • An anti-siphoning device or hose supports to prevent contamination of the water supply.
  • Secondary containment is useful for the transportation of concentrated product from storage to field site for mixing. (This containment should be adequate to contain a leaking or damaged container and all contents.)
  • Appropriate personal protective equipment.
  • Emergency eyewash treatments, such as closed containers of clean water.
    • Containers must be kept clean.
    • The water must be changed routinely to prevent the growth of bacteria.
    • Treatments must be stored separately from chemical products.
    • Containers must be clearly labeled.
    • Must be able to provide 15 minutes flushing capacity.

Any system for field mixing and rinsing should be developed with ease and effectiveness in mind. The key to any design is an adequately sized portable source for clean water.

Closed Mixing Systems

The use of closed systems require that mixing operations be conducted in the area of the equipment. These systems are used to minimize the risk of exposure to product materials during mixing operations and are designed to prevent contact with the pesticide product. There are two major types of closed systems - mechanical and soluble packaging. While some pesticides require closed systems for handling, and some states may require their use through legislation, they are generally only used when working with products of high acute toxicity.

If a closed system is implemented, special care must be taken to ensure that spills and leaks are contained in an appropriate manner and held for disposal. Mixing of pesticide products in containment vessels can complicate disposal procedures and change classifications of materials involved.

Cleaning and Storage of Equipment

Sprayers and associated equipment are the key to the effective and safe application of pesticides. It is imperative that the equipment be cleaned and maintained in such a manner as to prevent damage to lines, nozzles, tanks, and pumps. Careful rinsing after each application (by job or field) will prevent buildup in lines and nozzles and make end of season cleaning much easier. Thorough cleaning, inspection, and maintenance prior to putting items in storage at the end of the season will increase the productive life of equipment and help minimize the risk of future pesticide contamination problems.

Follow product labels and equipment operation manuals for specific guidelines on cleaning, equipment maintenance, and end of season storage.

Best Practices

Best practices are management strategies selected to address production problems in a manner that best utilizes available resources. These practices have been developed over time and are used extensively throughout the industry. The university encourages and expects applicators to use such practices whenever applicable.

  • Integrated Pest Management - is a system that combines several management policies to address pest problems. No single form of control provides optimal results. Basic principles include careful identification of all pest problems involved, using pest-resistant cultivars (if available), implementing good agronomic practices (quality seed, soil testing, etc.), use of biological controls (when available), and rotation of pesticides used.
  • Soil and water conservation best practices focus on optimizing soil fertility, controlling water runoff, preventing indiscriminant spread of chemicals, and preserving soil integrity. These include:
    • Nutrient management planning to utilize animal wastes as a source of organic material and nutrients,
    • Crop rotation,
    • Use of reduced tillage methods where macropores are not an issue,
    • Contour stripping, and
    • Use of vegetative filter strips.

Transportation

Transportation of pesticides is a concern for application operations that involve highway use and/or movement across private properties. General precautions are to be implemented in order to protect the applicators, public, and the environment.

Equipment used to move products from purchase to storage, and to site of use, should be carefully maintained to ensure proper operation. In addition to vehicle operation, there must be adequate security for containers. This would include proper ventilation, secure holding areas, and spill prevention and control. Hazardous material placarding of vehicles operating on state highways is required. The EPA Worker Protection Standard requires that drivers of vehicles transporting containers that are not factory sealed be trained as Worker Protection Standard pesticide handlers, or be certified applicators.

All containers included for transfer by vehicle must be labeled. This includes the manufacturer's label for primary containers and appropriate information for secondary or transfer containers.

Spill/Release And Reporting

In the event of any spill or unexpected release while transporting pesticides, specific strategies must be implemented.

  • The spill must be contained.
  • The area must be secured.
  • Notify EHS directly at 231-3600 for assistance and guidance with small spills/releases. After hours, call VT Police Department at 231-6411 and request EHS assistance.
      If the incident poses a threat to any person, public health or safety, or to the environment, call 911 immediately.
  • Minor spills must be cleaned up as soon as possible.
  • Spills involving ground contamination require absorbents, shovels, empty containers for contaminated soil and product.

Notification to the Virginia Department of Agriculture and Consumer Services (VDACS), Office of Pesticide Programs is required if any of the following products and quantities are stored:

  • One or more pounds of:
    • Aldicarb (Temik)
    • Chlordane
    • Coumafuryl (Fumarin)
    • Methamidophos (Monitor)
    • Paraquat (Gromoxone Super)
    • Sulfer dioxide
  • Ten or more pounds of:
    • Carbofuran (Furadan)
    • Carbon disulfide
    • Dichlorvos (DDVP, Vapona)
    • Dimethoate (Cygon, De-fend)
    • Strychnine
  • 100 or more pounds of:
    • Methyl parathion (Penncap-M)
    • Nicotine
    • Trichlorfon (Dylox, Proxol)
    • Warfarin (Co-Rax, Rodex)
  • 1000 or more pounds of:
    • Dinoseb (Premerge, Dinitro)
    • Methyl bromide
    • Sodium arsenate (Atlas "A", Penite)

Disposal

When pesticide products have expired or are no longer needed, they must be disposed of as hazardous waste, if they cannot be disposed of safely as rinsate. Contact EHS for hazardous waste removal at 231-6321.

Empty product containers require special processing and handling as well. Once empty, triple rinse and recycle or recondition metal and plastic containers. For larger volume containers, such as 30 and 55 gallon drums, check with the pesticide dealer or manufacturer for reconditioning options. Some products have special conditions regarding the disposal of containers.

For More Information

Environmental, Health and Safety
Health and Safety Building
540.231.3600

Virginia Department of Agriculture and Consumer Services
Office of Pesticide Services: General Information
804.786.3798

Virginia Department of Environmental Quality
804.698.4000

Virginia Tech Pesticide Programs
Department of Entomology
302 Agnew Hall
540.231.6543