1. Dealing with Contract Pest Control in Deployed Operations LTC Jamie Blow Chief, Operations Division Contingency Liaison Officer Armed Forces Pest Management Board

2. Deployed Pesticide Operations Military personnel and contractors responsible for pest management and disease vector control during military contingency operations and deployments shall apply pesticides and conduct operations consistent with the policies and procedures of DODI 4150.07(May 08) and the guidance in TG 24 Contingency Pest Management. Individuals who apply pesticides shall be DoD or State certified IAW DOD 4150.7-M. Contractors are used in most deployments to provide support that U.S. Forces are unable to sustain. Contracts are often written by personnel who know nothing about pest control.

3. Certified Applicator Any individual who applies pesticides who has successfully completed an EPA-approved training program that includes written examinations in core and specific categories. Certification may be by the DoD, a State, or when OCONUS applies where consistent with applicable international agreements, SOFA, final governing standards (FGS), issued for host nation, or the criteria in the Overseas Environmental Base Line Guidance Document (OEBGD).

4. Contractor Applicator A contract employee, certified by a State or host nation, who applies pesticides on DoD installations and property. The contractor shall be required to provide evidence of certification of applicators in all appropriate pest management categories for which the work is to be done at the time the contract is let.

5. Contracts LOGCAP writes a Statement of Work (SOW) –The SOW provides the guidance to the contractor. –Obtain a copy of the SOW. –Identify who in theater is the LOGCAP representative and work with them to refine the SOW for pest control operations. Managed by the Defense Contract Management Agency (DCMA). –DCMA is responsible for monitoring and enforcing the contractors compliance with the SOW. –A Administrative Contracting Officer (ACO) is appointed for each SOW. –The ACO is the only one who can make modifications to the contract requirements. –DCMA often uses Contract Officer Technical Representatives (COTRs) or Contract Officer Representatives (COR) to inspect contractor compliance with SOW. –COTR/CORs must understand the SOW and the contractor requirements: They can not make changes to the SOW. They are responsible for monitoring compliance with the SOW. They provide reports to the ACO.

6. Contracts Depending on the size of the base or theater a contract can either be written by the base logistic office or LOGCAP. Pest control contracts are usually written by someone who knows nothing about pest control. We have to go looking for the people who write the contracts because they usually don’t know we exists.

7. Statement of Work First section usually has regulatory requirements that hold throughout SOW. –General. Notwithstanding any other provisions of this SOW, the contractor shall comply with all U.S. laws. –The contractor shall adhere to all Army and U.S. Environmental Protection Agency guidelines in the performance of this SOW unless otherwise directed by the ACO. These 2 statements mean that it is inherent upon the contractor to know and comply with all of the regulations and guidance.

8. Contract Specifications Example from Iraq SOW 59/89: Vector Control Section 5.9: The contractor shall maintain vector control records to include but not limited to, areas inspected, pest quantities, date of inspection, date of treatments, type of pesticides used and quantities of pesticides used in treatments. These records shall be provided monthly to the ACO. Section 8.12: The contractor shall perform all pest control functions (to include animal control and removal) to mitigate pests in all base camps, containers, and contractor maintained facilities, using materials and chemicals that are in compliance with the Army’s and the host nation’s environmental regulations. Government units will support all contractor efforts by not feeding or maintaining animals in their camps other than military working dogs.

9. Contract Specifications SOW 139 Section 5.9 The contractor shall maintain pest management records of all pest management operations, to include but not limited to, pest surveillance activities, habitat management, sanitation, consultations, etc. This data shall be recorded on DD Form 1532-1 (Pest Management Maintenance Record) or its computer generated equivalent. The DD Form 1532-1, or equivalent, shall be submitted monthly to the Theater (MNC-I) Medical Entomologist (Theater Pest Management Consultant, Government COTR), prior to being submitted through LOGCAP channels to the ACO and subsequently to the U.S. Army Center for Health Promotion and Preventive Medicine (USACHPPM) for archiving. PEST MANAGEMENT. The contractor shall perform all pest management functions (to include pest surveillance and control, and animal control and removal) to mitigate pests in all base camps and contractor-maintained facilities in accordance with the MNC-I Integrated Pest Control Plan. The contractor shall ensure that all chemicals and pesticides used in pest management operations are in accordance with DoD Armed Forces Pest Management Board (AFPMB) recommendations, and will be approved, prior to use, by the MNC-I Pest Management Coordinator. For emergencies or unique situations, pest management materiel not approved by the AFPMB may be purchased locally if approved by the MNC-I Pest Management Coordinator. 8.11.1. DoD Preventive Medicine Detachments/Units have pest management responsibilities in their respective areas of operations. The contractor shall ensure that pest management personnel coordinate/communicate pest surveillance and control efforts with their respective Preventive Medicine Detachments/Units. This purpose of this coordination is to ensure that pest management efforts are complimentary and not duplicated, which could result in overexposing personnel to pesticides.

10. Contract Specifications SOW 139 con’t 8.11.2. The contractor shall meet DoD competency requirements for all pest management personnel who apply pesticides. All pesticide applicators are to be state-certified in appropriate categories (appropriate in the types of pest control work required). The contractor shall submit pesticide applicator certification documentation to the MNC-I Pest Management Coordinator/Certifying Official to ensure DoD competency/certification standards are met. 8.11.3. All pesticide applicators without DoD Pesticide Applicator Certification are to be at minimum state-certified in appropriate categories. 8.11.4. The contractor shall humanely trap feral animals. All traps that have captured feral animals shall be secured and humanely transported to veterinary personnel or other veterinary-designated personnel for euthanasia. KBR personnel shall not be required to euthanize animals. Euthanizing personnel will bag carcasses in a single, black, non- porous plastic bag and return the carcass to the contractor. The contractor shall then transport bagged carcass to either solid waste incinerator, burn pit, or bury them 1 meter underground to dispose of them.

11. Pesticide Reporting All pesticide application, except those done by Field Sanitation Teams, has to be reported per DODI 4150.07 para 5.4.6 and para E4.9.4. Reporting can be done using a computer generated DD Form 1532-1 or DOD IPMIS. Send DD Forms 1532-1 for achieving to pesticide.archival@amedd.army.mil

12. Applicator Certification DoD certification: –FIFRA – What Service Members receive and U.S. based applicators –Non-FIFRA – what non-U.S. based applicators receive after completing DoD training and testing. State Certification

13. Applicator Certification All State and DoD pesticide applicator certification is based on EPA requirements. Each State does things slightly differently. –Categories do not cross walk from state to state to DoD. –Many states break categories into sub- categories.

14. State Applicator So how do you check if a contract applicator has the appropriate certification? The AEC website has links to each state pest control

15. AEC Pest Management

16. AEC DoD Certification

17. State Certification Information

18. State of California

20. Recurring Issues Validation of State Certifications –State Applicators not certified in necessary categories. Continuing Education –Contract requirement to provide certified/liscenesed pesticide applicators in appropriate categories. Unqualified Personnel providing QA/QC for pesticide contracts –DCMA Quality Assurance personnel either need to have a current DoD pesticide applicator certification or PMQAE training.

21. New Initiative DoDI 4150.07 vol II will have section that allows for an apprenticeship program to train third country nationals or local nations. Individual can only be in program for a maximum of 2 years. Must attend DoD Non-FIFRA training and pass certification exams to become DoD Non-FIFRA applicators.

22. Questions?