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UCSD is committed to environmental stewardship in all aspects of facility
operations and maintenance. The purpose of this policy is to minimize the
problems arising from pests as well as minimize the risk of exposure to pesticides
by adopting an integrated pest management (IPM) approach to controlling pests.
This policy applies to all practices, operations and maintenance of the building
exterior and the surrounding landscapes in UCSD’s East and West campuses,
Scripps Institute of Oceanography (SIO), Nimitz Marine Facility, Trade Center
Warehouse and Torrey Pines Center (Please note it does not include UCSD
Health facilities).
“Integrated Pest Management” IPM is a method of pest management that uses
environmentally sensitive strategies and least-toxic control methods to ensure the
health and safety of building occupants\users as well as the natural environment.
Traditional pest control involves routine application of pesticides. IPM differs
from traditional pest control methods by focusing on pest prevention and using
pesticides only when needed.
“Least toxic pesticides” Also known as least risk pesticides are pesticides
registered in the Tier III category, in the San Francisco Hazard Ranking system,
or a pesticide that meets the requirements of the San Francisco Pesticide Hazard
Screening Protocol and is sold as a self-contained bait or as a crack-and-crevice
treatment used in areas inaccessible to building occupants. Rodenticides are never
considered least toxic pesticides.
“Emergency” Emergency in this document refers to a pest outbreak that poses an
immediate threat to public health or will cause significant economic or
environmental damage.
The intent of this policy is to enable staff and occupants to work towards the achievement
of the following goals for successful integrated pest management:
Prior to the application of pesticides or baits, alternative non-chemical pest
control methods will be used when emergency treatment is not required
If alternative non-chemical methods fail, least toxic (Tier 3) pesticides will be
used prior to the usage of non-least toxic pesticides and baits where emergency
treatment is not required
Occupants of the buildings will receive notification of the application of
Responsibility for the overall implementation, quality control, and evaluation of the IPM
Policy rests with:
Facilities Management Primary Contact: Chuck Morgan
Title: Asst. Director, Landscape Services, Facilities Management
Email: cmorgan@ucsd.edu
Environment Health and Safety Primary Contact: Gabriel Rubenstein
Title: EHS General Safety Specialist
Email: grubenstein@ucsd.edu
This Integrated Pest Management Policy is effective as of May 15, 2017 and will be
considered effective until it is supplemented or revised by an alternative policy.
Integrated methods that involve monitoring and non-toxic measures such as inspection,
sanitation, exclusion and traps will be used to proactively manage and minimize pest
issues. If the above measures are unable to resolve the problem, refer to the action
thresholds for each type of pest and employ least toxic pesticides prior to resorting to the
use of non-least toxic pesticides. Least toxic pesticides include those ranked as Tier 3 by
the San Francisco Hazard Ranking system. The names of these products can be found on
the Pesticide Research Institute’s Pest Smart Tool
(http://pesticideresearch.com/site/pestsmart/) or on the Pesticide Product Evaluator tool
(https://pesticideresearch.com/site/evaluator/, subscription-based).
If a pesticide is not listed on the Pesticide Research Institute’s Pest Smart Tool or
Pesticide Product Evaluator tool, the San Francisco Pesticide Hazard Review Process
(Appendix A) should be used to determine whether the pesticide is Tier 3 (least toxic).
Products that are not regulated as pesticides by the EPA because they primarily contain
low-risk ingredients, such as orange oil, may also be considered least toxic options, even
if they are not listed as Tier 3 by the San Francisco Hazard Ranking system.
Alternate/Non-chemical Pest Control Procedures and Strategies
- Manage trash receptacles and dumpster areas for clutter and cleanliness to minimize and
eliminate food and water sources available to pests
- Ensure that garbage containers are clean, free of odors and covered wherever feasible
- Eliminate water sources by fixing leaky pipes, cleaning out drains and rain gutters
- Prevent pooling of water on concrete or soil after irrigating landscape
- Clean up plant debris, especially from fruit bearing trees
- Remove invasive plants that are known to harbor or provide food for pests
- Thoroughly clean and maintain food service areas and break rooms
- Rinse food and beverage containers before placing in recycling bins
- Use non-chemical baits such as peanut butter to trap insects and rodents
- Eliminate the usage of chemical baits within the building
- If chemical baits become necessary outdoors, only use solid blocks placed in locked outdoor
Perform visual inspection in and around the building for signs of pests
Assess all pest control measure in place
Monitor pest population
Assess the need for 1 or more pest control methods
Maintain the building envelope by weather stripping around windows and doors
Install door sweeps, screens or other barriers.
Seal cracks and crevices and holes in the building envelope
Keep vegetation trimmed 18 inches from the building and fill area with stones or similar
material to prevent nesting
- Use mulch and other landscaping best practices to promote soil and plant health
- Use weed free soil amendments
- Maintain and plan landscape features to eliminate safe havens for pests and rodents
7.1 Suggested Non-Chemical Treatment for Common Pests
- Ants
- In areas where ants are present, wipe the areas down with soapy water in order to prevent the
formation of major scent trails. If there already is an established trail, wipe backwards from
the food source to the entrance of the trail.
- Block all entry points to the building – ants will give up trying to find a way through after 12 days. Temporary blockades can be made using sticky substances such as petroleum jelly,
chili powder, or cinnamon.
- Always keep opened foodstuffs in sealed containers or store them in the refrigerator or
freezer. Clean out kitchen cabinets, drawers and shelves to remove crumbs and stains. Keep
sinks and worktops clean and dry.
- Baits are best put in the path of an ant trail and then removed after the ant activity stops,
before they lure ants from another colony to the area.
- Prune branches close to the building and removed fences or anything that might create a
bridge for the ants to cross.
- Low toxic compounds to control ants include diatomaceous earth (DE), a chalk-like powder
consisting of the fossilized remains of diatoms, a type of hard-shelled algae.
- Ants often enter buildings seeking food, water, or refuge from hot weather or flooding. Long
trails of ants leading from nests to food sources can cause considerable concern among
building occupants. Successfully managing ants requires diligence and a combination of
integrated pest management strategies.
- Exclusion
- Ant infestations often follow a seasonal cycle. Prepare for the annual influx of ants by
caulking and sealing the building envelope before ants are likely to invade. Ants prefer to
make trails along structural elements, such as wires and pipes, and frequently use them to
enter and travel within a building. Focus exclusion efforts in these areas.
- Sanitation
- Ants eat sugars, fruits, nuts, fats, dead or live insects, and meat. Store attractive food items in
closed containers and wash the container exterior to remove food residue. Rinse out empty
beverage containers or remove them from the building. Thoroughly clean up grease, spills
and crumbs from kitchens, food service areas, and office desks. Remove garbage from the
building and change liners frequently. Look for indoor nesting sites, such as potted plants,
and remove if ants have settled there.
- Landscape Management
- Ants like to make nests near plants that support large populations of honeydew-producing
insects such as aphids, soft scales, mealybugs or whiteflies. Avoid planting these trees and
shrubs next the building, or use IPM methods to manage honeydew-producing insects. Keep
plants, grass, and mulch several inches away from the foundation of buildings because this
can be an ideal nesting site for ants. Ants may also be attracted up into trees or shrubs by
ripening or rotten fruit or floral nectar. Trim branches and limbs of trees and shrubs that
touch the building to keep ants from gaining access via these routes. Keep ants out of trees by
banding the trunks with a sticky substance. Check bands regularly for debris buildup that will
allow ants to cross.
- Non-Toxic Treatments
- Detergent and water – A Green Seal certified cleaning product mixed with water is an
effective non-toxic treatment method. This solution, when sprayed on ants, will immobilize
them, allowing them to be wiped up with a sponge or mop. This method should be followed
by exclusion and sanitation methods to prevent more ants from invading the same location.
(Note: This approach will be employed by building staff; California state regulations do not
allow certified pest control providers to employ detergent/water in this context.)
- Desiccant dusts – Desiccant dusts, such as diatomaceous earth, are low in toxicity to people
and do not lose their effectiveness over time, as long as they do not get wet. Desiccant dusts
are inert dusts combined with absorptive powders that destroy insects by absorbing their
protective outer body cover, causing them to dry out, or desiccate. Diatomaceous earth is
readily available in retail stores. Place desiccant dusts within cracks and crevices where ants
enter the structure.
- Baits – Baits should be used in combination with the strategies outlined above to be fully
effective. Baits greatly reduce the amount of pesticide that must be used to kill ants. Foraging
ants take the bait back to the nest to feed to other members of the colony, resulting in colony
death. There are many types of baits that differ in their formulation (paste, liquid, gel, etc.),
their attractant (protein, oil, sugar, etc.), and in the toxicant (active ingredient) they utilize.
Different species of ants respond differently to bait toxicants, attractants, and formulations.
Proper identification of ant species and proper bait selection is an important aspect of any ant
IPM program. Place bait stations along foraging trails, but do not disturb ant trails between
the nest and the bait. Killing the ants or disturbing the trails prevents the ants from taking the
bait back to the colony to kill nest mates. Ant colonies may switch their bait preferences as
their nutritional requirements change. A colony may prefer a protein bait one week and an oil
bait the next. If ants stop taking an existing bait, it may need to be changed.
- Cockroaches contaminate food with their excrement and secrete and unpleasant odor that can
permeate the indoor environment.
- There are five main species of cockroaches and effective control depends on identifying them
- Integrated pest management measures for controlling cockroaches include effective hygiene
and exclusion practices, sticky traps lined with pheromones, and insect growth regulators.
- All food handling areas should be cleaned frequently.
- Control is necessary on a regular basis because of the mobility, reproduction, longevity, and
behavior of cockroaches.
- When outside contractors are hired ensure that least toxic pesticides are being used. It is not
always the case that they use environmentally appropriate chemicals.
- Rodent control should start with a survey to determine the source of the problem and the
conditions that encourage the infestation. Following the survey, implement a program to kill
the rodents, removing their sources of food and water, eliminating their place of refuge and
making it rodent-proof, and educating and obtaining the cooperation of employees. If the
food supply is removed before you eradicate them, the rodents will migrate to other areas,
making elimination more difficult.
- Openings in building foundations and walls should be closed or screened with wire mesh that
has holes not more than 1.25 cm (0.5 in) wide. Where pipes enter masonry, force heavy
hardware cloth or steel wool into the opening, then fill it with concrete.
- Continuous surveillance is necessary, and places where rodents have been gnawing to gain
entry to a building should be sealed with metal flashing.
- Doors are particularly vulnerable to rodent entry so ensure that external doors and windows
close tightly with no gaps at the bottom.
- Materials stored in the open, in sheds or in building should be stacked at least 30 cm (1 ft.)
above the ground.
- Stringent waste disposal practices should be observed – secure all waste in closed containers
and not just plastic bags.
- Wash dustbin areas regularly. Make sure composting bins are designed to prevent rodents
from entering.
- Traditional mouse and rat traps, or snap traps, kill instantly. If trapping efforts fail, it is
usually due to too few traps being used. No toxic forms of rodent bait are considered leasttoxic. Rodents may be attracted to snap traps via harmless forms of organic, food-material
bait like peanut butter, chocolate, cheese, bacon, oatmeal or apples. These materials or
similar foodstuffs with no toxic content are the only types of substance approved for the
purpose of baiting snap traps.
- An alternative to snap traps is a battery-operated trap that generates a high-voltage once the
rat or mouse is inside.
- The best control method for mosquitoes is to eradicate their habitat.
- Mosquitoes like moisture and lay their eggs in standing water, it is important not to leave
flower pots, buckets, plastic sheeting or other open containers outside collecting water.
Ensure that rainwater collectors are fitted with lids.
- Clear debris from gutters and drains to ensure there is no standing water after rain and drain
unused pools or fountains so that the water cannot become stagnant.
- Drain or fill depressions, mud flats, and other areas that might hold water.
- Repair leaking taps and air-conditioning units so that puddles cannot form and ensure that
septic tanks and sewage systems are properly maintained and in good working order.
- Avoid over-irrigating lawns and gardens, and keep weeds and grass (where the insects rest)
- Fill ponds or lakes with mosquito-eating fish such as top-feeding minnows or goldfish. They
will eat the mosquito larvae before they mature into adults.
- Some buildings have successfully reduced the number of mosquitoes and other insects by
attracting bats to their property. A simply-built bat house will usually accommodate up to
100 bats.
- To prevent mosquitoes from coming indoors, fit fine-mesh screens to porches, doors and
- If these measures are insufficient, area repellents such as citronella candles, coils or sprays
will repel mosquitoes from porches, patios and other unscreened outdoor areas, although they
only work well when the air is still.
7.2. Action Thresholds
Action threshold describes the scenarios when pest control methods need to be employed.
The regular treatments which involve monitoring and non-toxic methods will be
implemented first followed by the least toxic and the non-least toxic methods.
Emergency treatment includes the use of the most-effective control method as a first step,
which may be non-toxic.
Action Threshold
- Regular treatment will be performed if ants are noted in the building and their presence is
confirmed through monitoring.
- Emergency treatment may be used if there are ten or more reported cases or complaints of
ants within a two day period
Other insects
- Regular treatment will be performed if nuisance insects are noted in the building and their
presence is confirmed through monitoring.
- Emergency treatment may be used if there are ten or more reported cases or complaints of
nuisance insects within a two day period.
- Regular treatment will be performed if cockroaches are noted in the building and their
presence is confirmed through monitoring.
- Emergency treatment may be used if the presence of cockroaches is confirmed in two
different spaces within the building OR if the presence of a large population of
cockroaches is confirmed in one space in the building.
Rat, Mouse
- Regular treatment will be performed if rats or mice are noted in the building and their
presence is confirmed through monitoring.
- Emergency treatment may be used if the presence of rats or mice is confirmed in two or
more different spaces within the building.
- Baits will only be used for high risk areas such as the Housing and Dining buildings
where concerns over safety of the occupants overrides IPM steps outlined in this policy.
For more information please refer to: http://ipm.ucanr.edu/ which is followed by all UC
Bed bugs
- Emergency treatment may be used if the presence of bed bugs is confirmed in the
Other occasional
- If the pests pose a threat to occupants’ health, emergency treatment may be sought.
Otherwise, regular treatment will be performed.
7.3. Least Toxic Pesticides
Chemical pesticides are considered a last resort under the tenets of integrated pest
management. This control strategy is to be used after non-chemical options are
exhausted. Pesticides that meet the requirements of Product Hazard Tier 3 are considered
least-toxic. To qualify as a least-toxic, all of the following statements must be true:
-Product contains no known, likely, or probable carcinogens
-Product contains no reproductive toxicants (CA Prop 65 list)
-Product contains no ingredients listed by Illinois EPA as known, probable, or suspected
endocrine disrupters
-Active ingredients has soil half-life of thirty days or less
-Product is labeled as not toxic to fish, birds, bees, wildlife, or domestic animals
7.4. Emergencies and Corresponding Notification
A pest outbreak is considered an emergency when it poses an immediate threat to public
health or will cause significant economic or environmental damage. Emergency pesticide
applications require notification to building users within 24 hours of the application using
the notification guidelines listed in the Communication Strategy section of this policy. A
notification sign similar to Appendix B can be used.
7.5. Communication Strategy
Notifying building users of all pesticide (least as well as non-least) applications is a
critical component of integrated pest management. Providing occupants and visitors with
the appropriate information at the appropriate time enables individuals to take
precautions as they see necessary to protect their personal health. At a minimum the
responsible party must:
Notify building occupant or employee who request notification and post a sign at the
application site, which must remain in place for 24 hours. For emergency applications of
a pesticide, anyone who requested notice must be notified within 24 hours of the
application and given an explanation of the emergency. Post signs at every entry point to
where the pesticide is applied, if applied in an enclosed area. In highly visible, open area
locations, post signs around the perimeter of the area where the pesticide is applied.
Signs must be standardized and easily recognizable. See Appendix B for the approved
notification sign template.
Each sign must contain the following information at a minimum:
-The pesticide name
-The targeted pest
-EPA registration number
-Treatment location
-The application date
-The name and contact information of an individual that is responsible for fielding
questions regarding the application.
Each sign must be in both English and Spanish. Copies of posted signs shall be retained
for record keeping purposes for one year.
7.6 Occupant communication
If pests are observed in a work space, the responsibility of notifying the supervisor or a
responsible party in a similar capacity lies with the occupants\users. Timely notification
will result in immediate action against pests and the application of pesticides can be
7.7 Non-Least Toxic Pesticides
Non-least toxic pesticides include all chemical rodent baits as well as any product
classified as a Tier 1 or 2 pesticides by the San Francisco Hazard Ranking system, or any
product that meets the Tier 1 or 2 criteria according to the San Francisco Hazard Review
Process. Non-least toxic pesticides may only be used if:
-Alternative, integrated, and least toxic pest control measures have been exhausted and
the pest action threshold is still exceeded.
-The emergency action threshold has been exceeded.
The use of non-least toxic pesticides or rodenticides as pest control in areas requiring
frequent treatment on a permanent basis is not an acceptable strategy. Non-least toxic
pesticides will not be continuously applied in the building and on the site. Integrated and
alternative pest control measures will be resumed once the action threshold specified
below for the applicable pest is no longer exceeded.
All pest control activity undertaken at the University of California, San Diego, including
inspections, should be recorded in an IPM tracking log. Record keeping is required to
demonstrate ongoing compliance with the IPM policy and all pesticide application
including least toxic applications have to be tracked.
Tracking compliance with the goals established by this policy will take place on an
annual basis.
The responsible party will evaluate the IPM tracking log on a quarterly basis to evaluate
progress towards the implementation goals. If any pest management activity is not being
properly recorded, the responsible party will inform the appropriate individuals to ensure
that activities are recorded moving forward. If any implementation goals are not being
met, the responsible party will investigate the situation and will work with the individuals
performing the maintenance activities to resolve the issue. The responsible party will
evaluate whether updates are necessary to the plan or the integrated pest management
process in order to achieve the implementation goals.
A: IPM Tracking tool
B: Notification Sign Template
D BY (Name
and Title)
for signs,
(refer to
Note 1
Y Tier3
Tier 2
Tier 1
to Note
ON (Y/N),
ON? (Y/N)
2) Refer to the Pesticide Research Institute’s Pest Smart Tool or Pesticide Product Evaluator tool to determine the level of
1) Refer to Action Threshold in the Integrated Pest Management Directive for determining pesticide application requirements.
Appendix A: IPM Tracking tool
Appendix B: Notification template
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EPA #: