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Pest Management - Frequently Asked Questions

Q) I am not trained to make pest management recommendations, so how will I be able develop pest management plans?

A) NRCS’s Pest Management Standard is different from what is commonly understood as "pest management". The prime function of the pest management component of a conservation plan is to reduce the environmental risk of pest management activities. We do not want to take over the role of professional pest management advisors who regularly make pest management recommendations, but we do want to work closely with them to help producers develop resource-friendly pest management alternatives as part of an overall Resource Management System.


Q) I’m already a Certified Crop Advisor. Does that mean I’m automatically an NRCS Pest Management Specialist?

A) No. CCA certification does not automatically certify you as an NRCS Pest Management Specialist. CCA certification focuses on pest identification and appropriate pest management techniques. NRCS Pest Management Specialist certification focuses on environmental risk evaluation and recommending mitigation to meet NRCS Pest Management Standard requirements. CCA certification and NRCS Pest Management Specialist certification require different skill sets that are not interchangeable, but they do have some overlap.


Q) What does mitigation have to do with pest management?

A) Mitigation simply means to "make less severe". Mitigation as it relates to NRCS Pest Management is defined as: "The process of minimizing the potential for harmful impacts of pest management activities on soil, water, air, plant, and animal resources through the application of conservation practices and/or management techniques." When we "mitigate" hazardous off-site movement of pesticides or sediment, we are decreasing the potential for those losses to cause damage to at-risk resources.


Q) How much mitigation is enough?

A) This is not an easy question to answer. In applying the NRCS Pest Management Standard, there is no numeric "T" value to use as a target. Current NRCS Field Office pesticide risk screening tools are qualitative (e.g., Low, Intermediate, High) rather than quantitative (e.g., .5 tons/acre). Since pesticide pollution is often intermittent and at low concentrations, it is difficult to quantify sufficient mitigation, especially in the short term. We must therefore rely on the professional judgement of conservation planners to implementation mitigation techniques that have been shown effective by research. Finding the right set of management techniques and conservation practices that do not over or under mitigate will take collaboration with researchers and practical experience.

Our goal is to reduce potential hazards to the equivalent of a Low or Very Low WIN-PST rating. Since site conditions vary widely due to climate, topography, soils, crop management, distance to sensitive water bodies etc., sets of mitigation techniques that are applicable to specific areas should be developed at the state or area level.

 

Q) Will every Resource Management System conservation plan require a pest management component?

A) Yes and no. If pests are not being managed on land you are planning, then you do not have to apply the Pest Management Standard. If pests are being managed on the land you are planning, then the Pest Management Standard applies and you will have to develop a pest management component for the overall conservation plan. There are some caveats to that however - in the first several years after your state implements the Pest Management Standard, it is not expected that every farm will receive an in depth pest management component. The Pest Management Standard should fist be applied where there is a high risk from pest management activities to vulnerable resources. This includes land in close proximity to at-risk resources and other land that has been shown to directly impact at-risk resources. In some cases, reporting that there are no identifiable at-risk resources may satisfy the Pest Management Standard.


Q) Does pesticide rate, form and timing have to be documented in the conservation plan?

A) No. The Pest Management Standard does not require you to include pesticide rate, form and timing in the plan. Some of that information may be necessary to do an environmental risk screening, but it does not have to be carried into the plan. Rate form and timing for non-chemical pest control measures (such as tillage for weed control) may have to be documented in other plan components.


Q) Can NRCS provide Extension pesticide recommendations to producers?

A) Yes. Nothing in NRCS Pest Management Policy prohibits us from providing Extension pesticide recommendations to producers. However, it would not be acceptable for NRCS to develop our own pesticide recommendations based on label information.

Q) Will I have to be licensed if I give Extension recommendations and/or pesticide specific environmental risk information to producers?

A) Maybe. Each state has its own criteria for pesticide licensing so this question cannot be answered on a national basis. Some states do not require any pesticide licensing. Some states require licensing for everyone that gives any pesticide-related assistance to producers, including pesticide specific environmental risk information. Some states have public licenses for government employees. All state requirements must be met, so you may be required to be licensed to provide pest management assistance to producers in the conservation planning process.

Q) Do you have to be an NRCS certified Pest Management Specialist to develop the pest management component of a plan?

A) No. Anyone can develop the pest management component of a conservation plan. However, only an NRCS certified Pest Management Specialist can approve the pest management component of the plan. Experienced planners, including NRCS employees and Third Party Vendors, should be able to meet NRCS pest management certification requirements with appropriate training.


Q) Why should NRCS planners have to approve someone else’s pesticide recommendations?

A) Approval of the pest management component of a conservation plan does not include approval of the efficacy and economics of pesticide recommendations. Approval of the pest management component only means that planned pest management activities have been screened for potential environmental risks as required by the Pest Management Standard contained in the local FOTG, and all identified risks have been mitigated in the overall conservation plan according to quality criteria in the local FOTG.

 

Q) If unusual circumstances during the growing season call for pesticide recommendations that are not included in the pest management component of the conservation plan, should the plan be updated?

A) Maybe. Infrequent use of a pesticide that was not in the original plan is acceptable. The Pest Management Standard states that "Environmental risk analysis with approved tools and/or procedures should be done for probable pest management recommendations by crop (if applicable) and pest." If a pesticide use was unforeseen, it could not have been included in the plan. However, if a new pesticide use is expected to become commonplace (probable), the pest management component of the conservation plan should be revised to include it and any appropriate mitigation should be added to the plan. If there is no reasonable way to determine probable pest management recommendations, then mitigation should be planned for the highest potential hazard(s) for that crop.