EBOM 2009 IEQc3.6: Green Cleaning—Indoor Integrated Pest Management

Hi Taryn,
You are correct that rodent baits are considered highly toxic and not considered least toxic under any circumstances. Therefore, you will need to provide universal notificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do. to tenants each time the baits are refilled. Even though the tenants do not have access to these locked rooms, I would err on the side of caution and provide more notification than less. I also suggest trying less toxic pest management approaches, such as structural/building repairs or changes to cleaning procedures, to address the underlying cause of the rodent problem.

I agree with Megan's suggestion to explore the root cause of the problem, such as structural issues that are allowing the rodents in, or attractive conditions that are luring them (water and food sources).

For meeting the universal notificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do. criteria, in this instance I've seen teams use posted signs so those in and around the area are alerted.

Hi Samantha

Yes, while glue traps aren't the most desirable approach for pest management, they are a compliant strategy for rodent control. The ultimate goal is to avoid the use of pesticides that may harm the building occupants.

And in terms of the log, I would include all pest management activities, including cleaning/replacing traps and monitoring tools, or even just general pest inspections. A pest management vendor should be able to easily capture every pest management activity in a log - and this is a great strategy for building managers to monitor their vendor and make sure they aren't applying non least-toxic pesticides without their knowledge!

Thank you, that is exactly what I needed to know.

Hi

There is no minimum required frequency for pest management and based on your building's individual pest management needs. That said, the intent is for the program to be proactive - utilizing integrated pest managementIntegrated pest management (IPM) is the coordinated use of knowledge about pests, the environment, and pest prevention and control methods to minimize pest infestation and damage by the most economical means while minimizing hazards to people, property, and the environment. practices before-hand in order to avoid the future need for pesticides. Often, a pest management log will include inspections, cleaning, maintenance and monitoring activities, as well as logging any pesticide applications.

I hope this helps,

Hannah

Chris, have you followed up and/or had any more insight into these review comments?

The first part is clear enough but what do they mean by #2? Are the reviewers saying that referencing the LEED EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. criteria for green cleaning products is insufficient? They really want the plan to have a copy and paste of the criteria, instead of a reference?

We also received the same comment #1 regarding referencing the San Francisco Reduced-Risk Pesticide List rather than San Francisco Pesticide Hazard Screening List. We also followed the template provided in LEED user and notice that you reference the "San Francisco Reduced-Risk Pesticide List " in both the Birds Eye View and Checklists sections above. It's an easy enough change for us to make to our plan, but it was a little confusing since it's referenced all throughout the LEED user guidance as the "San Francisco Reduced-Risk Pesticide List". It would be helpful if this guidance was updated! Thanks.

Hi Kim - There might be resistance from your vendors, but really the only way is to get them to provide the materials costs for the products they are using. Hopefully they will be willing to break this out for you. Good luck!

Jenny, I have material costs for one of the vendors but have not asked the others (I will). If I do not get material costs, how do I figure the cost in, since we pay for a service? Do I figure a percentage as material costs or is it all counted? I apprecieate your help! Kim

John - the 20% piece in SSc3 is generally limited to the fertilizer and landscape waste components. Because IPM is a process that doesn't really lend itself to a percent implementation evaluation, the expectation is that the _process_ will always be followed, whether that leads to using non-least toxic pesticides some of the time, all of the time, or they aren't necessary because the prevention tactics were so successful.

In my experience, the reviewers will be most concerned with seeing that any toxic pesticides used were correctly classified as such, were accompanied by proper notification to occupants, and were not used on a routine (e.g., every month) basis, but only in response to specific pest in specific locales that could not be addressed through non-toxic means.

Jason, the best thing to do is to compare the active ingredients of your products to those listed on the SF Reduced Risk list. Brand availability is going to vary around the world, so that isn't the most effective way to monitor these products. Check the active ingredient and concentration to determine which tier the product would fall under.

The solution you propose for your second question is exactly right. Try to find least-toxic alternatives that fall under the Tier 3 criteria for as many situations as you can. When Tier 3 product are unavailable or ineffective for a particular pest problem, use a Tier 1 or Tier 2 product after providing at least 72 hours notice to your building occupants via the universal notificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do. procedures outlined in your IPM Plan.

thanks Jason, i have 2 more question.

i do agree with your statement that i should look at the active ingredient rather than the product listed on the SF env because there are different brand around the globe., but i encounter one problem , there aren;t any specific w/w (limit of use) of these active ingredient inside the SF checklist.

Q1 : if i'm currently using a smaller percentage of tier 1 active ingredient compare with those on SF checklist, can i still continue to use it?

Q2: i found out that, our pest controller is using permethrin, which listed as " Pesticide Banned in Habitat Area Full List" due to the effect onto California Red Legged Frog. But our project are not at California, can we still use this chemical?

thanks

The key thing to remember is that IPM does not ban the use of Tier 1 or Tier 2 pesticides. The intent of IPM is to promote the use of least toxic methods, or Tier 3 pesticides, whenever possible. If those products aren't available or effective, you are allowed to use Tier 1 and Tier 2 products, but you MUST fulfill the requirements of universal notificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do.. Building occupants must be notified at least 72 hours in advance of application or within 24 hours after an emergency application. Emergency conditions are usually defined as "immediate threat to health and/or safety of building occupants.", like a swarm of bees or something like that.

The reference guide, the addenda and the database of CIRs/Interpretations/Addenda all support the following: Universal notificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do. means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do.

However, on a recent review comment, the reviewer indicated that 72 hour notification is required whether normal or emergency conditions exist. I do not find any evidence to support this comment. Unless anyone can tell me where this change can be found, I will respectfully disagree with the reviewer and provide evidence of why. Has anyone seen this change to this credit or have they received a review comment such as this in the past?

Just received a response from the review team to my message asking for clarification of when this change occurred. It advises this review comment was incorrect.

Yep, it sounds incorrect to me too. I'm glad you followed up and got things straightened out with the reviewers.

Andy,

There's a Reference Guide addenda that directs project teams to the SF Pesticide Hazard Screening List: http://www.sfenvironment.org/our_programs/interests.html?ssi=2&ti=1&ii=117

It's my understanding that this is more comprehensive than the Reduced Risk Pesticide lists (regardless of issue date).

Also, the Pesticide Hazard Screening List includes Tier 1 and 2 products in addition to Tier 3, so make sure you are zeroing in on the right Tier.

My query is related to above.

Will the LEED Review team consider chemicals on the list if concentrations/dilutions are lower than those on the list?

Hoping to hear some advise.

thanks

The Hazard Screening List will indicate that the threshold for Tier 1/Tier2/Tier 3 is sometimes based on a minimum concentration of the active ingredient (i.e. 7.9% by volume). If the product you're using isn't listed on the Hazard Screening List, but the active ingredient is listed, you'll need to show that your product has a concentration equal to or lower than the concentration for a Tier 3 product. so if the ingredient shows up as a Tier 1 pesticide with a concentration of 5.0%, it isn't enough to show that your product has a concentration of 4.9% - you need to show that your product meets Tier 3 thresholds.

Hi Robin,

Generally Universal NotificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do. is taken to mean that everyone in the building gets a heads up about the application. I haven't seen anyone try to argue that only certain occupants were affected and therefore notified, so you might want to use a CIRCredit Interpretation Ruling. Used by design team members experiencing difficulties in the application of a LEED prerequisite or credit to a project. Typically, difficulties arise when specific issues are not directly addressed by LEED information/guide if you want to try that strategy or make sure that you can really provide evidence that there is zero chance that other folks within the building might be affected.

In terms of executing the notification, we've used a strategy similar to one you propose on our projects. Namely, reaching out to a tenant contact with the pesticide application info who is then responsible for disseminating that information to all of their occupants. Ultimately though, it's still your responsibility to make sure everyone is notified, so you'll want to make sure the tenant contact is actually carrying out their obligation to spread the word.

It is also wise to post notices where people will be likely to see them such as elevator lobbies and entrances.

I assume the refill is some time later, like a few days or weeks? I would say you'd want to use notification, yes. I would err on the side of more notification, not less.

A comment on a recent project from a reviewer indicated that universal notificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do. must be given for the initial application and for refills of the pesticide.

It's always good to look into non-chemical and least toxic options prior to applying conventional pesticides; however, as long as you demonstrate that the building management issued universal notificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do. (alerting all occupants) at least 72 hour prior to pesticide applications or within 24 hours after emergency pesticide applications, you comply with the credit requirements.

All pesticides, including insecticides and herbicides, that are not classified as Tier 3 products on San Francisco's list can be used in and around a project building so long as you issue universal notificationUniversal notification means notifying building occupants not less than 72 hours before a pesticide is applied in a building or on surrounding grounds under normal conditions, and within 24 hours after application of a pesticide in emergency conditions. Use of a least toxic pesticide or self-contained nonrodent bait does not require universal notification; all other pesticide applications do. prior to applying the chemicals. However, it is always important to consider non-chemical pest management solutions prior to administering toxic pesticides.

Drew, just checking—is your question about whether the vendor's services are covered by the credit at all? (Since they are not directly under the control of building management.)

The answer to that question is YES, and hopefully you can get the companies to compete against each other to improve their practices!

Thanks for your comment Shira.

Tristan, yes I was seeking clarification as to whether or not this service was addressed by the credit at all, and hoping someone in the LEEDUser community would have dealt with this on a project. Leaning heavily on the intent of EQc3.6, my assumption was, "yes" these services and the chemicals used are indeed covered. In the reference guide, it is clear that use of pesticides in exterior landscape maintenance is to be included in Outdoor IPM (SSc3), but the requirements for EQc3.6 do not make specific mention of interior plant maintenance as a part of Indoor IPM.

Drew, I see what you're saying—although indoor plants are a common realm for application of pesticides, so for that reason I think it's pretty clear that they're covered.

Indoor plants can be a major source of Fungi's Flies (Gnats) They feed on the bacteria that forms on the soil. If the plant is overwatered this is very common. The IPM approach is to make sure that the soil is not over watered or go to a different substrate that won't let the bacteria form. In addition you can use products like DE mixed in the soil. This is a benign dust the will dissacate the flies but not harm the soil. I hope this helps.