Syracuse University Pesticide Users
Policy and Users Manual

1. Introduction
1.1. Policy Statement

2. Regulations
2.1 Federal
2.2 New York State

3. Pesticide applicator certification
3.1. Certified commercial pesticide applicator
3.2. Certified commercial pesticide technician
3.3. Certified commercial pesticide apprentice
3.4. NYS DEC certification categories
3.5. Recertification requirements

4. Notification
4.1. EHO notification requirement
4.2. Child care facility notification requirement
4.3. Lawn care notification and posting requirements

5. Environmental Considerations
5.1. Air and Pesticides
5.2. Water and Pesticides
5.3. Wildlife and Pesticides
5.4. Environmental Protection
5.5. IPM

6. Pesticide Safety
6.1.Personal Protective Equipment (PPE)
6.2. Mixing and Filling
6.3. Exposure Avoidance
6.4. Emergency Response and First Aid

7. Pesticide toxicity
7.1. Acute Vs. Chronic

7.2. Routes of entry
7.3. Toxic efects

8. Storage
8.1. Storage Facility Requirements
8.2. Pesticide Container Storage Requirement
8.3. Pesticide bulk storage

9. Labels an Equipment
9.1. Labels
9.2. Signal words
9.3. Equipment

10. Disposal
10.1. Three rinse technique
10.2. Empty pesticide container disposal

11. Recordkeeping
11.1. Application Records
11.2. Annual pesticide report
11.3. Training Records

12. Liability

13. Summary

Appendices

NYSDEC 6 NYCRR Part 325
Forms
- Record of Use
- Notification
- Child Care Facility Notification Posting
Emergency Information

1. INTRODUCTION

A pesticide is defined as any substance or mixture of substances used to control or protect from pests. These substances include: insecticides, fungicides, rodenticides, miticides, herbicides, nematocides, molluscicides, disinfectants and repellents. Pesticide types include general use (bought "off the shelf"), restricted use (requires certification to purchase and use) and banned pesticides (DDT, chlordane, etc.). The federal government (Environmental Protection Agency) has set standards for pesticide handling and use. The Department of Environmental Conservation (NYSDEC) is the agency responsible for the administration and enforcement of pesticide laws in New York State (NYS).

1.1 Policy Statement
The use and handling of pesticides at Syracuse University will be by certified pesticide applicators or technicians only. All pesticide applicators are required to understand basic safety and handling rules for pesticide use and comply with applicable regulations. EHO oversees pesticide related compliance activities including reporting requirements, maintaining copies of Material Safety Data Sheets (MSDSs) and labels for those pesticides used at the University. Each SU certified pesticide applicator will be required to maintain his/her own pesticide use records on the forms provided and to keep accurate recertification credit records. All SU pesticide use must follow guidelines set forth in the Pesticide Use Program User's Manual and must incorporate Integrated Pest Management (IPM).

2. REGULATIONS

Pesticide regulations are complex and address the necessities of law, science and public health. The Federal government and the Department of Environmental Conservation in New York State have strict regulations with regards to pesticides. It is the applicator’s responsibility to know and understand these laws.

2.1 Federal
The United States government, mainly through the Environmental Protection Agency, has established rules and regulations for pesticide use and handling. Individual states have the right to develop laws that are as strict or stricter than the federal laws. The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) gives the Environmental Protection Agency (EPA) the authority to develop regulations for pesticide use. FIFRA governs the licensing and registration of pesticides. No pesticide may be sold in the United States until it has been reviewed by the EPA and assigned an EPA registration number.

FIFRA provides for the following:

Requires that EPA register all pesticides and approve the product label
Requires all pesticides be classified as "general use" or "restricted use"
Requires users of "restricted use" pesticides to be certified or working under the direct supervision of a certified user
Establishes tolerance levels for residues on food/feed products
Provides for penalties for "use inconsistent with labeling" of a pesticide
Makes it illegal to store or dispose of a pesticide or container other than as directed by regulation
Permits states to have stricter pesticide use standards

The Department of Labor administers regulations pertinent to pesticide users through the Occupational Health and Safety Administration (OSHA) and the Hazard Communication Standard (HCS). These rules cover work-related injuries or illness and require investigations of worksite complaints. The HCS requires employers to inform employees of workplace hazards and provide trainingwhen appropriate. EPA regulates hazardous waste through the Resource Conservation and Recovery Act (RCRA) which requires proper disposal of pesticide wastes. Department of Transportation (DOT) regulations are used to enforce the proper packing, transport, handling and labeling of pesticides.

2.2. New York State
NYS laws governing the use of pesticides are stricter than those promulgated by the Federal government. The NYS Department of Environmental Conservation (DEC) is the agency responsible for administration and enforcement of state pesticide laws. These regulations can be found in the NYS Code (6 NYCRR Parts 320-329).

Pesticides must be registered by NYSDEC prior to sale, distribution, use or transport in NYS. An unregistered pesticide may not be used in NYS. NYSDEC also certifies pesticide applicators as commercial and private applicators and requires a pesticide business to register with the Department. NYSDEC regulations also provide detailed requirements for pesticide disposal, labeling, notification, etc.

3. PESTICIDE APPLICATOR CERTIFICATION

Syracuse University is a NYS Registered Pesticide Business/Agency. The registration is maintained by the Environmental Health Office and renewed every three years with the NYS Department of Environmental Conservation (NYSDEC). Any pesticide applied on campus is considered a commercial pesticide application and must be made by individuals certified to do so in NYS. This includes University employees and outside contractors.

NYSDEC has three levels of certification for commercial pesticide applicators: Applicator, Technician and Apprentice. The level of supervisory responsibility and type of pesticide(s) to be applied (general use or restricted use) will determine the level of certification required by an individual. A restricted pesticide is a pesticide classified for restricted use by the NYSDEC (ECL 33) or federally by the US Environmental Protection Agency (FIFRA section 3.d.1.c). A general use pesticide is any pesticide that does not meet the criteria for restricted use pesticide.

EHO must be notified of all certified University employees applying pesticides at the University. Any Syracuse University employee required to obtain certification to complete their employment duties may contact EHO (3-4132) to obtain a pesticide information packet including a list of available training courses.

3.1 Certified Commercial Pesticide Applicator
A certified Commercial Pesticide Applicator is certified by NYSDEC to apply or supervise the application of restricted and general use pesticides. A Commercial Pesticide Applicator may only apply or supervise the application of pesticides in a category or subcategory for which that individual is certified (see categories in Section 3.4) and such category certification must be specified on the individual’s certification identification card.

If a certified applicator is supervising a pesticide application that requires on-site direct supervision, the certified pesticide applicator must be physically present at the application site and within voice contact of the individual being supervised. During pesticide applications that allow off-site supervision, the certified applicator must ensure that the individual being supervised has a means to contact and is able to contact the certified applicator within a reasonable time (not to exceed 30 minutes).

Eligibility Criteria: At Syracuse University based on NYSDEC requirements, an individual is eligible for commercial pesticide applicator certification in a specific category(s) or sub-category(s) if that individual:

is at least 17 years of age
completed a NYSDEC approved 30 hour ("core" and category/subcategory specific) training course
has at least 1 year verifiable experience as a technician and an additional 12 hours of category specific re-certification training or 2 years experience as a technician

Certification must be obtained from the NYSDEC. Individuals seeking commercial pesticide applicator certification must demonstrate competency to NYSDEC by taking the core and category/subcategory specific examinations. The core exam is identical for all applicants and covers pesticide regulations, safety, handling and use issues.

3.2 Certified Commercial Pesticide Technician
A certified commercial pesticide technician is certified by NYSDEC to apply general use pesticides without supervision in a category of use covered by the individual’s certification. A certified technician is also certified by NYSDEC to apply restricted use pesticides under the direct supervision of a certified commercial pesticide applicator in a category of use covered by both the individual’s and certified applicator’s certification.

A certified technician must have on-site direct supervision by a certified application when, but not limited to, the technician applies a fumigant, applies a pesticide with a label requiring on-site supervision, or applies an aquatic pesticide to surface waters of NYS. If on-site supervision in required the certified pesticide applicator must be physically present at the application site and within voice contact of the individual being supervised. Off-site supervision is allowed when a technician applies restricted use pesticide that does not specifically require on-site supervision. No supervision is needed for the application of general use pesticides except for those applications requiring on-site supervision as indicated above.

Eligibility Criteria: At Syracuse University, based on NYSDEC requirements, an individual is eligible for commercial pesticide technician certification in a specific category(s) or sub-category(s) if that individual:

is at least 17 years of age
completed a NYSDEC approved 30 hour ("core: and category specific training course.

Certification must be obtained from the NYSDEC. Individuals seeking commercial pesticide technician certification must demonstrate competency to NYSDEC by taking the core and category/subcategory specific examinations. The core exam is identical for all applicants and covers pesticide regulations, safety, handling and use issues.

3.3 Certified Commercial Pesticide Apprentice A certified commercial pesticide apprentice is certified to apply pesticides under the direct supervision of a certified commercial pesticide applicator only. Supervision is necessary for both general and restricted use pesticides.

Eligibility Criteria:Syracuse University employees may not apply pesticides at the University as a certified commercial pesticide apprentice.

3.4 NYSDEC Certification Categories
The following commercial categories/subcategories of pesticide applications have been established by the NYSDEC.

1A Agricultural Plant	5A Aquatic Veg. Treatments	7D Lumber & Wood
1B Agricultural Animal	5B Aquatic Insect Control	7F Food Processing
1C Companion Animal	5C Aquatic Fish	7G Cooling Towers
1D Soil & Ag. Fumigation	5D Aquatic Anti-fouling paints	8 Public Health
2 Forest	6A Rights-of Way Veg.	9 Regulatory
3A Ornamental and Turf	6B Rights-of Way Pole	10 Demon. &Research
3B Turf	7A Structural Rodent	11 Aerial Pilot
3C Interior Plant Maint.	7B Fumigation	12 Sales of Restricted Use Products
4 Seed Treatment	7C Termite Control	12 Sales of Restricted Use Products

A certified applicator will only be allowed to apply or supervise the application of pesticides appropriate to their certification. An applicator may be certified in more than one category.

3.5 Re-Certification
Certified pesticide applicators must be recertified in each category or subcategory they are certified in every six years. Recertification must be obtained no later than 90 days following the applicators certification expiration date. To obtain recertification, a certified applicator must:

Have a history of satisfactory performance in each category or subcategory
Pay a recertification fee
Pass a recertification examination or accumulate continuing education credits as indicated in the table below. Continuing education credits must be obtained in more than one calendar year and consist of at least 25% category specific training.

Commercial Pesticide Applicator Recertification Credit Hour Requirements

Note: this is only a partial list. Complete list found at 6 NYCRR 325.21

Category	Credit Hours
Agricultural Plant	16
Agricultural Animal	12
Ornamental & Turf	20
Seed Treatment	10
Structural & Rodent	24
Cooling Towers	10

A Certified Technician must recertify every 6 years by paying the recertification fee to NYSDEC.

4. NOTIFICATION

4.1 Environmental Health Office Notification Requirement The SU Environmental Health Office (EHO) must be provided with 72 hour notice prior to any pesticide application made on University owned or operated property. This includes applications made by certified University employees and outside contractors. Notification may be made by telephone, fax, or through the use of EHO’s on-line Pesticide application notification form
Notification must include:

Applicator’s name
Date and time the application will occur
Purpose of the application
Exact location the application will be made (address,building, room, description)
Name of the pesticide
Method of application

A MSDS and product label must be on file with EHO for all pesticides applied at the University. If pesticides are applied inside a University building, occupants have the right to ask for and receive a copy of the label and/or MSDS.

Exemptions to the 72 hour notification requirement may be granted by EHO on a case by case basis.If a 72 hour notification waiver is granted by EHO, EHO must still be provided with all the necessary notification information.

4.2 Child Care Facility Notification Requirements
New York State's Pesticide Neighbor Notification Law requires all licensed childcare facilities to provide notice to parents 48 hours in advance of each pesticide application made at the childcare facility. The required notice for each pestic ide application must consist of a posting placed in a common area(s) of the facility which is conspicuously visible to persons dropping off or picking up children from the facility. The posting must indicate specific notification wording and information regarding the pesticide application to be made including the name and phone number of a representative of the childcare facility to be contacted for additional information.

Syracuse University currently operates two childcare facilities, the SU Day Care Center (M0/M1) and the Bernice M. Wright Nursery School (M17). EHO and the affected childcare facility must be provided with 72 hours notice prior to the application of a pesticide at any child care facility or within 150 feet of a building housing a childcare facility. Such notice must include:

Name and phone number of the responsible party applying the pesticide.
Scheduleddate and time of the pesticide application (and an alternative date if the scheduled application can’t be made due to weather conditions, if applicable)
Location of the application
USEPA pesticide registration number

Upon notice, the childcare facility must complete Syracuse University’s Childcare Facility Pesticide Notification form (See Appendix B) and conspicuously post the Notification form at least 48 hours prior to the application. If a posting other than SU’s Childcare Facility Pesticide Notification form is used, the alternative posting must include all of the above application information and the following wording:

This notice is to inform you of a pending pesticide application at this facility. You may wish to discuss with a representative of the daycare facility what precautions are being taken to protect your child from exposure to these pesticides. Further information about the product or products being applied, including any warnings that appear on the label of the pesticide or pesticides that are pertinent to the protection of humans, animals or the environment, can be obtained by calling the National Pesticide Telecommunications Network Information at 1-800-858-7378 or the New York State Department of Health Center for Environmental Health Info line at 1-800-458-1158.

Exemptions
New York State’s Childcare Facility Notification requirement provide exemptions from the 48 hour notification (posting) requirements for certain pesticide applications made at or around a childcare facility. EHO and the affected Childcare facility must still receive prior notice of any pesticide application to be made under one of these exemptions. The exemptions include, (but are not limited to):

The use of an aerosol product with a directed spray in an 18 fluid ounce container or smaller used to protect individuals from imminent threat from stinging and biting insects,
Applications made where the childcare facility will remain unoccupied for 72 hours following the application,
The use of non-volatile rodenticides and insecticidal baits in tamper resistance bait stations or in areas inaccessible to children and
Applications of US EPA classified exempt material and reduced risk pesticides. Seventy-two hour advanced notice to the childcare facility for these exempted applications is not necessary.

New York Sate has also made an exemption for emergency applications of pesticides made when necessary to protect against imminent threat to human health. However, this emergency application exemption requires that the applicator make a good faith effort to provide the necessary notice to the childcare facility and then following the emergency application, notify the Commissioner of the NYS Department of Health that an emergency pesticide application has occurred. Approval of such emergency applications must be obtained from EHO prior to the application. A copy of the applicator’s notification to the Commissioner of NYS DOH must be provided to EHO.

4.3 Lawn Care Notification/Posting Requirements
A commercial lawn care pesticide application is defined by NYS DEC as the application of a pesticide to ground, trees, shrubs on public or private outdoor property. As a registered pesticide agency, Syracuse University is exempt from most of the requirements for commercial lawn application with the exception of the visual notification requirements. These requirements dictate that a visual notification marker must be posted by any pesticide applicator performing a commercial lawn application.

Visual Notification Appearance Specification
The notification marker must be yellow with black lettering and constructed of a rigid material. The marker must be at least 4 inches by 5 inches in size with lettering that is at least 3/8 inch in height. The notification marker must indicate:

"Pesticide Application", "Pesticide Treatment" or "Pesticide Applied"
Specific date and time of the actual application
The phrase "Do Not Enter"
The phrase "Do Not Remove Sign for 24 Hours"
A prominent visual warning symbol at least 1.5 inches in diameter.

No other text or images, aside from those indicated above and the applicators name and contact number, are allowed on the front of the notification marker. Any other text and/or images must be placed on the back of the marker.

Visual Notification Posting Specifications
The pesticide applicator making the commercial lawn pesticide application is required to post the visual notification marker prior to the application and the notification must remain posted for 24 hours following the application. At least two (or more depending on the size of the treated area) visual notification markers must be placed at every treated area except for only one visual notification marker is required when an individual tree of shrub is treated which can only be approached from one direction.

The notification markers must be placed:

With the top of the marker at least 12 inches above the ground
With the front of the marker clearly visible from outside the treated area
Not more than 50 feet apart along the perimeter of the treated area
At common entry points adjacent to treated area (i.e. driveways, walkways, etc.)

5. ENVIRONMENTAL CONSIDERATIONS

Pesticides can be both useful and threatening to the environment. Their use allows the population to live with abundant agricultural products and with less fear of health hazards associated with insects, fungi and other pests. Pesticides do, however, present a danger by their presence off target and have been identified as a non-point source of water pollution. As certified pesticide applicators at SU, it is important to do the job carefully to prevent contamination of the environment.

5.1. Air and Pesticides
Controlling pesticide drift is critical to prevent the deposition of poisons in waterways, buildings, lawns, etc. Air currents can carry vapor drift from the treated area. Therefore, volatile pesticides should be applied only when conditions are favorable.

The following steps should be taken to minimize drift:

Ensure that the appropriate particle or droplet size is used. Choose the largest effective size available with equipment and maintain the appropriate pressure (i.e. the lower the pressure the larger the droplet size).
Maintain an appropriate target. Positioning the nozzle too high could disperse the spray over too great an area.
Avoid applications when the temperature is high as vapors may injure susceptible plants and animals.
Avoid application when winds are gusty.
Do not apply near building air intakes or air handling units

Prior to application of a pesticide in or near a building, all air handling units must be identified. Do not spray a pesticide near any air intakes. This type of drift can contaminate entire buildings and expose numerous people. Any questions about building air systems should be directed to the Physical Plant Zone office or the Office of Design and Construction before work commences.

5.2. Water and Pesticides
Pesticides may enter the groundwater by rainwater runoff from treated areas, pesticide leaching, a pesticide spill, etc. Actions must be taken to prevent and/or minimize pesticides from entering groundwater. Consult weather forecasts to determine predicted rainfall and avoid application when heavy rains are imminent. The Soil Conservation Service is a good source of information about soil types to determine if pesticide leaching could be a problem. Always follow label instructions and take steps to prevent groundwater contamination.

5.3. Wildlife and Pesticides
Use extreme caution to avoid applications to non-target areas. Certain animals and plants have been classified as endangered or threatened and efforts must be made to avoid causing harm to these organisms. Honeybees, although not endangered, are particularly susceptible to chemicals. Select pesticides that will be the least harmful to foraging bees.

5.4. Environmental Protection
Minimize the impact of pesticides on the environment by adhering to the following:

Evaluate the need, method and frequency of pesticide use.
Read the label for warnings and use a less toxic pesticide if appropriate.
Consider the location where the pesticide will be applied in relation to surface water, sewers and air handlers and make necessary modifications to prevent pesticide infiltration.
Read and follow label directions.
Prevent spills or back siphoning.
Apply pesticides at the appropriate time and direct the application accurately at the target.
Mix, store and dispose of pesticides properly.
Maintain all pesticide use records.

5.5. Integrated Pest Management
The use of integrated pest management is required at Syracuse University. Integrated Pest Management (IPM) is a holistic approach to pest control that employs a variety of pest control methods to minimize the potential for adverse effects on health and the environment. IPM requires knowledge of the specific situation and accurate identification of the pest. Using an IPM approach, initial actions for pest problems should involve the use of mechanical (traps), physical (sealing cracks) and biological (eliminate habitat or food source) controls. Chemical controls (pesticides) should be used as a last resort. If pesticides are to be used, they must be chosen and used carefully. The potential impact on area occupants, non-target species, and natural resources must be taken into consideration when deciding if a pesticide should be used.

6. PESTICIDE SAFETY

Proper safety precautions must be taken before, during and after all pesticide applications. Good preparation including pest identification, pesticide selection, proper notification and a thorough knowledge of the proper use of all personal protective equipment (PPE) is crucial to a safe application. Proper clean-up and disposal of pesticide wastes is critical also. It is important to pay close attention during all phases of a pesticide operation.

6.1. Personal Protective Equipment (PPE)
Before using any pesticide, check the label to identify what PPE, if any, is needed. If a label lists specific PPE, it must be used for all pesticide applications. Use of a respirator requires participation in SU's Respiratory Protection Program (RPP), which includes medical surveillance and appropriate training prior to respirator use. Contact EHO for more information on the RPP and selection and purchase of proper PPE. Lower toxicity pesticides typically require only long sleeves and pants. Moderate and higher toxicity pesticides typically require another layer of clothes or chemical resistant suit. Various types of protective gloves are available and may be specified on the label. Because of varying break-through properties, use only the gloves listed. Cotton gloves can absorb and hold pesticides close to the skin so are not usually recommended. Boots, goggles, face shields, aprons and safety glasses may also be required as PPE.

6.2. Mixing and Filling
Concentrated pesticides are most often encountered during the mixing and filling phase. Areas used for mixing of concentrated pesticides should be equipped with vent hoods, fans or other removal equipment. A first aid kit and spill clean-up supplies must also be on hand in mixing areas.

PPE is very important for protection against inhalation of dry, undiluted pesticides and absorption of concentrated liquid through the hands. Read the label to ensure that appropriate PPE is used during the mixing phase.

6.3. Exposure Avoidance
During the application of pesticides, care must be taken to avoid unnecessary exposure. The following steps will help to ensure that unnecessary exposures are avoided:

Always use appropriate PPE
Avoid working in drift, spray or runoff areas
Keep all equipment in good working order
Use integrated pest management techniques and avoid treating occupied areas
Identify and turn off all air handling units prior to applications in or near a building
Apply pesticides only when weather conditions are favorable
Never eat, drink or smoke during mixing, application or cleaning procedures

6.4. Emergency Response and First Aid
Prior to making a pesticide application, the applicator should read and become familiar with the symptoms of exposure associated with the pesticides that will be used. A first aid kit and emergency phone numbers should be readily available to the applicator. If an individual should become over exposed to a pesticide, present symptoms of pesticide exposure or witness or be involved in a pesticide spill or incident, Syracuse University Public Safety should be notified immediately. Appendix C provides a chemical spill procedure which outlines steps to be taken in the event of a chemical/pesticide spill. Only trained personnel, using appropriate personal protective equipment, may clean up a pesticide spill.

Basic first aid actions may be initiated as warranted for the following exposures:

Poison on the skin: Wash the skin off using a shower, hose, etc. If burns are evident, avoid the use of ointments or other drugs. Be careful not to get any of the pesticide on yourself.
Poison in the eye: Flush the eye quickly, but gently for about 15 minutes. Cover the eyes with a clean cloth.
Inhaled poison: Remove the victim to fresh air using air-supplied respirator if necessary. Loosen tight clothing and prevent chilling. If you are trained and feel comfortable, provide rescue breathing if needed.
Ingested poison: Never induce vomiting if the victim is unconscious or has swallowed a corrosive or petroleum product.

An emergency eye wash and safety shower should be immediately accessible from pesticide storage and mixing areas.

7. PESTICIDE TOXICITY

Toxicity is defined as the capacity of a substance to inflict injury on a living system. There are two types of toxicity: acute toxicity and chronic toxicity. Exposure is defined as "contact" with a substance. Exposures can also be either acute or chronic. The effects from exposure to a pesticide vary based on the pesticide's toxicity, type of exposure and route of entry (ROE). All of these issues will be discussed in this section.

7.1. Acute vs. Chronic
Acute toxicity relates to effects that manifest within 24 hours following exposure to a pesticide. Pesticide labels contain warning statements based on acute toxicity. Chronic toxicity is associated with the delayed effects that result from exposure to a pesticide. Exposures can also be referred to as acute and chronic. Acute exposure refers to a single contact with a pesticide. Chronic exposure refers to repeated contact with a pesticide. Categories of toxicity and related dose information are presented in the table below (table adopted from Northeastern Regional Pesticide Coordinators Core Manual, 2nd Edition, 1990).

Category	Label Signal Word	LD50 Oral (mg/kg)	LD50 Dermal (mg/kg)	LC50 Inhalation (mg/L)	Approx. Lethal Oral Dose
Highly Toxic	DANGER, POISON, skull & crossbones	0-50	0-200	0-0.2	a few drops to 1 tsp (or a few drops on skin)
Moderately toxic	WARNING	50-500	200-2000	0.2 -2	1 tsp to 1 ounce
Slightly Toxic	CAUTION	500-5000	2000-20,000	2.0-20	1 ounce to 1 pint or 1 pound
Relatively Non-toxic	CAUTION	More than 5000	More than 20,000	Greater than 20	Over 1 pint or 1 pound

* Not used for skin and eye irritation effects

7.1. Routes of Entry
Pesticides can enter the body in several ways. Recommendations for personal protective equipment (PPE) which appears on pesticide labels address the route of entry associated with that pesticide. Effects of exposure to pesticides vary based on the route of entry.

The three main routes of entry are listed below:

Absorption: Liquid, dry and gaseous pesticides can all be absorbed through the skin. The eyes, ears, scalp and groin areas tend to absorb pesticides more quickly than other areas of the body.

Inhalation: Dust, mist and spray pesticides can all be drawn into the lungs during normal breathing. When pesticides make contact with the lung surfaces they are absorbed directly into the blood and transported throughout the body.

Ingestion: Pesticide ingestion typically results from carelessness. To minimize the risk of ingestion never smoke, drink or eat while using pesticides and always wash thoroughly before engaging in these activities following pesticide applications.

7.2. Toxic Effects
The extent and nature of pesticide poisoning in an individual will vary based on several factors. Examples of these factors are:

Health Condition: heredity, general health, habits (i.e. smoking)
Age: the youngest and oldest may be most affected
Gender: males and females may react differently
Environment: exposure to other chemicals in the air, water and food
Body Size: effects are proportional to body weight

Toxic effects may be classified as:

Local or Systemic: local effects occur at the site of contact with the pesticide and systemic effects occur remotely (i.e. a target organ)
Immediate or Delayed: immediate effects are experienced at the time of exposure (i.e. sneezing) and delayed effects occur some time after contact (i.e. tumors)
Reversible or irreversible: reversible effects are not permanent (i.e. dizziness) and irreversible effects are permanent (i.e. birth defects)
Additive, antagonistic or synergistic: additive effects occur when the combined effect of more than one pesticide is equal to the sum of the effects of each (2+2=4), antagonistic effects occur when the combined effect is less the sum of each (2+2=3) and synergistic effects occur when the combined effect is greater than the sum of each (2+2=5)

Toxic effects manifest in the following ways:

Reproductive: affects the ability to produce healthy offspring
Teratogenic: affects the unborn offspring
Carcinogenic: produces cancer in living animal tissue
Oncogenic: causes tumor growth
Mutagenic: affects genetic material
Neurotoxic: affects the nervous system, including the brain
Immunosuppressant: affects response of the body's immune system

Risk for pesticide poisoning can be expressed as:

RISK = TOXICITY x EXPOSURE

Toxicity studies are performed on animals and extrapolated to humans. Therefore, guidelines provided for pesticides are not definitive. The toxicity of a pesticide cannot be changed. Exposure to a pesticide can be restricted. Always follow the instructions on the pesticide label. Use a less toxic pesticide whenever possible. Keep PPE clean and available to help limit exposure.

8. STORAGE

Pesticide storage presents potential human health and environmental hazards. Precautions must be taken when siting, constructing, operating and maintaining pesticide storage facilities. Regulations for pesticide storage may be promulgated in the near future and the guidelines presented below are closely patterned after NYSDEC recommendations.

8.1 Storage Facility Guidance
Pesticide storage areas must be structurally separated from office and residential areas, water supply sources and food storage areas. Only certified pesticide applicators may have access to the pesticide storage area and the storage area must have:

Security and access provisions including a locked door (and/or a perimeter fence with a locked gate, if applicable). If there are windows in the storage area, they must be secured to prohibit access.
Impervious floors with all cracks and joints sealed.
Secondary containment for liquid pesticides. If an area containment system is to be used (i.e. a bermed floor, an area containment sump) the system must be capable of containing 25% of the total stored liquid volume.
Good ventilation to prevent build-up of vapors
Temperature control to prevent freezing and over-heating
Electrical fixtures and appliances approved for use in facilities that store flammable and combustible liquids
Personal protective equipment appropriate for the pesticides stored in the area
An emergency eye wash and shower immediately accessible
Emergency numbers posted near the storage area
A first aid kit and an appropriate fire extinguisher readily available in area
A readily available and accurate inventory list of all pesticides in the area. A copy of the inventory should also be stored in a secondary area accessible to emergency response personnel.
Cleanup equipment (broom, dustpan, absorbent, etc.) available

8.2 Pesticide Container Storage Requirements
Containers of pesticides stored within the pesticide storage area must be:

Segregated by hazard class and function
- incompatible materials must be physically separated from each other
- flammable and combustibles must not be stored in a flammable cabinet
- herbicides must be separated from insecticides and fungicides
- potentially reactive materials should be separated from other materials
Stored in original containers whenever possible
Arranged so labels are clearly visible from aisle space. Adequate aisle space must be maintained (per NFPA-30)
Stored on impermeable racks, shelves or pallets, not on the floor.
Stored in tightly sealed containers
Inspected periodically (i.e. monthly) for signs of leakage or other defects. If an inspection reveals any leaks, cracks or other damage to a container, corrective action must be taken immediately.

8.3 Pesticide Bulk Storage
If pesticides are to be stored in bulk (55 to 100 gallons) or portable storage units, the following additional precautions must be followed:

Tank inlets and outlets should be lockable and remain locked when not in use.
Tank should be stored on a bermed, impermeable floor capable of containing at least 100% of the total tank volume.
Tank storage areas should be locked.
Tanks should be routinely inspected and tested to ensure proper function and the results of the inspections and tests documented.

9. LABELS AND EQUIPMENT

Pesticide labels are extremely important to all users. Information regarding application and safety, as well as important manufacturer's data are all found on the label. The label is the law. Pesticide users are forbidden to use a pesticide in a way contrary to its labeling. The label itself, not just the pesticide, must be registered by the US EPA prior to its use. The user should read the label every time a pesticide is used. Never rely on memory for information about pesticide use and always use the recommended equipment.

9.1. Labels
A label is the information printed on or attached to the pesticide container. It tells an applicator how to use the product correctly. All pesticide containers are required by law to be labeled with a label that has been registered with the US EPA. Labels vary greatly depending on what the product is used for, who manufactured it, when the label was issued, and the size of the pesticide container. The information on a pesticide label must include:

Brand, trade or product names
Classification (general or restricted use)
Ingredients (active and inert)
Chemical and common name
Type (insecticide, fungicide, etc.)
Net contents
Manufacturer (name and address)
Registration and establishment number (i.e. EPA Reg. No. 100-550 SL)
Signal word (indicating product toxicity)
Precautionary and Route of Entry Statements
PPE statement (i.e. "Do not get in eyes, wear goggles while handling")
First aid
Physical and chemical hazards (i.e. flammable, corrosive)
Entry restrictions
Directions for use (when, how and how much)
Storage and disposal

Before purchasing a pesticide, request a copy of the label to ensure the appropriate equipment, PPE and storage facilities are available. The label may also list the target pests, to aid in choosing a pesticide. Always read the entire label before using a pesticide and follow all label instructions explicitly.

9.2 Signal words
Almost every pesticide label will contain a signal word indicating how dangerous the product is to humans. The signal word will appear in large letters on the front panel of the pesticide label. For more details on signal word indications see Section Seven of this manual.

DANGER: A product that is highly toxic orally, dermally or through inhalation or causes severe eye or skin burning. (approximate lethal dose = few drops to a teaspoon)
WARNING: A product which is moderately toxic orally, dermally or through inhalation or causes moderate eye or skin burning. (approximate lethal dose = a teaspoon to a tablespoon)
CAUTION: A product that is slightly toxic orally, dermally or through inhalation or causes slight eye or skin burning. (approximate lethal dose = an ounce to a pint or more)

9.3 Equipment Labels
Large pesticide application equipment (i.e. tanks, vats, drums, etc.) must display a NYSDEC numbered sticker. The stickers must be prominently displayed on opposite sides of each piece of equipment or on opposite sides of each vehicle used in transporting such equipment. Small pieces of hand-held equipment or portable equipment (i.e. backpack sprayers) do not require such stickers. EHO must be notified of all such equipment so that the appropriate labels can be obtained from NYSDEC.

Before using any pesticide, become familiar with the operation of all equipment that will be used. Know the advantages and disadvantages associated with the equipment and inspect all parts for defects or failures. Calibrate all equipment before using to ensure proper rate of application. Clean equipment after each day's use. Learn the appropriate cleaning agent for the pesticide being used. Call the manufacturer or EHO if this information is not contained on the label.

10. DISPOSAL

The disposal of unused or unwanted pesticide must be coordinated through the Environmental Health Office (EHO). Never dispose of unused or unwanted pesticides in the trash or through sanitary or storm sewers.

Empty pesticide containers must be handled and disposed of in accordance with NYSDEC requirements. Pesticide containers may not be re-used .

10.1 Three Rinse Technique
NYSDEC requires that the three rinse technique be used prior to disposal of non-combustible pesticide containers. The technique is as follows:

Empty the pesticide container as normal
Collect remaining contents for re-use or proper disposal through EHO
Allow the container to drain in a vertical position for 30 seconds
Rinse container with water or the pesticide carrier being used. Use 1 quart of water per gallon container size
Empty rinsate, collecting it for reuse or proper disposal through EHO
Allow the container to drain in vertical position for 30 seconds
Repeat steps 3 and 4 two additional times

10.2 Empty Pesticide Container Disposal
Empty non-combustible pesticide containers must be cleansed prior to disposal using the triple rinse technique. Containers of ready-to-use pesticides that do not require dilution are exempt from the triple rinse requirement but they must still be emptied and drained for one 30 second period prior to disposal. After appropriate rinsing, empty non-combustible containers may be disposed in regular trash.

Empty, combustible pesticide containers may be disposed directly into a trash receptacle.

11. RECORDKEEPING

Pesticide Applicators must provide notice to the Environmental Health Office (EHO) 72 hours prior to any pesticide application made on University owned or operated property. Notification may be made by telephone, fax, or through the use of EHO's on-line pesticide application notification form ().

11.1. Application Records
Each certified applicator is responsible for maintaining a log record, in accordance with the NYSDEC reporting requirements, of every pesticide application they make. The applicator should keep the log form with them during pesticide applications to ensure that accurate information is recorded. These log records must be maintained by the applicator for a period of three years and must be provided to EHO annually (January) and upon request. The information required to be maintained on the pesticide application log is as follows:

EPA registration number (as it appears on the product label)
Product name
Quantity used
Units (referring to quantity used)
Date applied
County code (DEC's code for county in which application was made)
Address of application (must be a street address)
Municipality (city, village, etc. where pesticide was applied)
Zip Code

The following additional information must be kept by certified applicators and be available on request to NYSDEC staff and/or EHO for each pesticide application made.

Dosage rate
Method of application
Target organism
Place of application (i.e. front lawn, kitchen baseboards)

11.2 Annual Pesticide Report
NYSDEC requires that a record of every commercial pesticide application made in the state be provided to them on an annual basis. It is the responsibility of each applicator to ensure their application records are provided to the NYSDEC prior to February 1st of each calendar year. NYSDEC allows a Registered Pesticide Business/Agency to submit one annual report on behalf of all certified employees to satisfy the annual report requirements. Syracuse University's EHO submits this report for the University. The report includes application records for pesticide applications made at the University by certified University employees. Certified University employees are requested to provide their application records annually to the EHO prior to January 15th of each calendar year to ensure they are included on the Annual Pesticide Report. If a certified applicator does not supply his/her application records to EHO by January 15th, the individual is responsible, by law, for submitting his/her annual use report to NYSDEC on his/her own.

11.3 Training Records
Commercial applicators must obtain Continuing Certification Hours over a six-year period to stay current on pesticide issues. A specific number of these hours (see section 3) are required for each sub-category. Following each workshop, all attendees will be given a certificate showing the number of hours earned. Original training certificates must be submitted to NYSDEC at the time of recertification. Each applicator should also keep a copy of their training certificates.

12. LIABILITY

Almost all pesticides are considered hazardous. Even with careful preparation, accidents and incidents can occur during pesticide applications. It is important that applicators be knowledgeable of their liability risk and be responsible. If a pesticide related incident or emergency occurs, keep calm and act carefully and promptly and contact EHO (3-4132) immediately. Save all containers involved, keep good records and wait for assistance.

Liability-related issues can be avoided by following the guidelines found in this manual. Negligence must be proven for an applicator to be liable. Use Integrated Pest Management (IPM) techniques and less hazardous pesticides to reduce this liability risk. Always follow the pesticide label. Never leave equipment or pesticides unattended, even in the back of a truck. Use caution and care when mixing, storing or applying. Be careful not to cross contaminate a site due to improper application or drift to “non-target” sites.

13. SUMMARY

All chemical pesticides are toxic to a greater or lesser degree. Common sense and a thorough knowledge of the pesticide being used will reduce or avoid exposure. Utilize IPM techniques and consider using a non-chemical alternative to control pests. Read the product label before buying and using pesticides. Buy and use only the amount of pesticide necessary to do the job. Perform applications only when conditions are favorable. Store pesticides in a properly maintained facility. Maintain accurate records and attend training appropriate to individual certification. Follow the recommendations contained in this manual and on the pesticide label to protect people and the environment from exposure to pesticides.

APPENDICES

Appendix A: NYS DEC Pesticide Regulations

Appendix B: Pesticide Forms

Appendix C: Emergency Information

Syracuse University Pesticide Users Policy and Users Manual

Table of Contents

1. INTRODUCTION

Commercial Pesticide Applicator Recertification Credit Hour Requirements

Syracuse University Pesticide Users
Policy and Users Manual