Appendix A - Management strategies and paradigms
used in the report
Risky Business: Invasive species management on National Forests -
A review and summary of needed changes in current plans, policies and programs

February, 2001
by George Wooten and Marlene Renwyck

The following management strategies and frameworks are noted in the report on invasive species management and are outlined in more detail in this appendix.

1. Prevention strategies
2. True Integrated Pest Management
3. Ecosystem management
4. Adaptive management
5. Precautionary principles.
1. Prevention strategies

The following list compiles specific prevention measures that relate to invasive species which should be given consideration in public land management. Not all of these measures may be practical to every situation, however, when used together, they provide the foundation for a holistic invasive species management program where prevention is the primary goal. The following list has been compiled from a number of different sources, including some of the recommendations from the annual Mediated Agreement meeting held in Corvallis, Oregon on December 4-5, 2000.

Recommended prevention measures

2. True Integrated Pest Management

Definitions of Integrated Pest Management (IPM) are not consistent. Wooten (1999b) used a synthesis of existing definitions to define a system of true IPM (including IWM), to differentiate it from invalid claims by agencies to be using IPM. He found, True IPM is an interdisciplinary system of techniques for controlling invasive plants that is both practical and environmentally sensitive.

Components of a true IPM program should include:

A wide variety of pest control options is considered in true IPM with preference for: A wealth of alternatives to chemical controls exist (Wooten, 1999c).

3. Ecosystem management

Some of the principles of ecosystem management have been spelled out by Noss (1999). Ecosystem management should consider the biology of invading species and their interactions within the affected environment, prior to implementing control actions. Preventive measures should be used to stop further spread and prioritize control measures on small populations of new invaders. For different invading species, different control methods should be considered. Decisions made under the premise of ecosystem management need to be based on informed judgment as well as a system of principles that acknowledges the factors which are prohibiting successful restoration of ecosystem integrity. In the case of invasive species, these factors would include activities which create soil disturbances and aid in the transport of seeds. Using the principles cited in Noss, Wooten (1999) listed a number of corollary principles for the use of true Integrated Pest Management within an ecosystem management framework:

Social and Cultural Objectives

Ecosystem Management Objectives Preferred Alternative objectives Herbicides use objectives Examples: As an example of how ecosystem management could improve the management of public lands, consider how plant invaders become established. Initial introductions often arise through the use of roads and trails in which seeds are brought in on cars, off-road vehicles, livestock, wildlife, hiker's boots, mountain bikes, contaminated feed or contaminated seed mixtures. Natural and man-made disturbances adjacent to those introductions then act as sites for further spread. It is ineffective to treat roads in an area where new road building will subsequently act as a vector for reinvasion of a treated species. It is also ineffective to use herbicide on a site where large populations of weeds are adjacent to the site for reinfection. And similarly, it is ineffective to treat grazed public lands through herbicide treatments when livestock will bring the seeds back to the site each year.

Treatments should be consistent with the management objectives for an area. Inappropriate seeding of forage grasses should not be combined with cattle grazing and invasive species management. Pasture grasses such as the wheatgrasses and the bromes have been commonly used in the Pacific Northwest with a number of undesirable ecosystem effects. Their high protein content acts as an attractant to livestock, resulting in increased soil disturbance and weed spread in recovery zones. Seed mixes are often contaminated with seeds of the very weeds that the grasses are supposed to replace. If successful, introduced perennial grasses often act as ecosystem invaders, spreading without control across the landscape, encouraging livestock and thus soil disturbance to new areas.

4. Adaptive management

Adaptive management is another emerging paradigm with promise for the Forest Service. It was defined in Everett (1994, p. 110, citing Baskerville, 1985):

The formalized process of adaptive management allows restoration activities to be initiated based on current information, but efforts need to be constantly updated and redirected as new information becomes available.
The Interior Columbia Basin Ecosystem Management Project (ICBEMP) proposed decision (ICBEMP, 2000) chose to use adaptive management approach (ICBEMP, 2000, p. 19):
. . . the ICBEMP decision will use an adaptive management approach to modify management plans and activities to incorporate new knowledge gained over time.
The process of adaptive management was described in more detail in ICBEMP (2000, Ch. 3, p. 7):
. . . The intent of adaptive management is to incorporate and build on current knowledge, observation, experimentation, and experience to adjust management methods and policies, and to accelerate learning. The intent is for management direction to be modified if a site-specific situation is different than what was assumed during ICBEMP planning; if a flood, fire, or other event changes the characteristics of the environment; if new information gathered through monitoring indicates objectives are not being met; or if new science information indicates a need for change. . . . Monitoring and evaluation are an integral part of adaptive management and are key to achieving the short- and long-term goals and objectives of ICBEMP.
When used in the context as presented above, adaptive management can be a useful tool for restoring degraded areas and identifying successful methods. However, adaptive management is inherently dependent on the long-term commitment to ask questions and acquire information about the effectiveness and appropriateness of actions being taken. Monitoring is thus integral to a successful adaptive management approach which should be applied for invasive species management.

5. Precautionary principles

The risk assessment procedures that have been used by government EIS analysts are beginning to give way to precautionary principles, as described by Montague, 1999d):

Science has no way to analyze the effects of multiple exposures, and almost all modern humans are routinely subjected to multiple exposures: pesticides; automobile exhaust; dioxins in meat, fish and dairy products; prescription drugs; tobacco smoke; food additives; ultraviolet sunlight passing through the earth's damaged ozone shield; and so on. Determining the cumulative effect of these insults is a scientific impossibility; so most risk assessors simply exclude these inconvenient realities. But the resulting risk assessment is bogus.

Risk assessment is inherently an undemocratic process because most people cannot understand the data, the calculations, or the basis for the risk assessor's judgment.

Now after 20 years, the public is catching on, that risk assessment has been a failure and in many cases a scam. Rather than allowing citizens to reach agreement on what's best, it has provided a patina of "scientific objectivity" that powerful corporations have used to justify continued contamination of the environment. With a few rare exceptions (sulfur dioxide emissions, for example) dangerous discharges have increased geometrically during the period when risk assessment has been the dominant mode of decision-making. It is now obvious to most people that risk assessment is a key part of the problem, not an important part of any solution.

In place of risk assessment, a new paradigm is ripening: the principle of precautionary action. The precautionary principle acknowledges that we are ignorant about many important aspects of the environment and human health. It acknowledges scientific uncertainty and guides our actions in response to it.

The precautionary principle says, ‘When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. In this context the proponent of an activity, rather than the public, should bear the burden of proof. [See Rachel's Environmental and Health Weekly #586.] The process of applying the Precautionary Principle must be open, informed and democratic and must include potentially affected parties. It must also involve an examination of the full range of alternatives, including no action.’

Certainly, this method of protecting public interests should be incorporated into invasive species management.

Appendix B - Chemical safety considerations

Forest Chemical Safety Plan

Personnel. Personnel should be knowledgeable about the handling of hazardous substances, and procedures for ordering and procurement of chemicals. Specifically:

  1. The use of proper material handling equipment, protective apparel, and safety equipment;
  2. Emergency procedures, including the cleanup of spills and the disposal of broken containers;
  3. The dangers of contacting chemicals by skin absorption, inhalation, or ingestion;
  4. The meaning of the various DOT labels on shipping packages;
  5. The proper methods of material handling and storage, especially the incompatibility of some common substances, the dangers associated with alphabetical storage, and the sensitivity of some substances to heat, moisture, light, and other storage hazards;
  6. The special requirements of heat-sensitive materials, including those shipped refrigerated or packed in dry ice;
  7. The hazards associated with flammable liquids (especially the danger of their vapors catching fire some distance from the container) (e.g., alkali metals, burning magnesium, metal hydrides, acid chlorides, phosphides, and carbides);
  8. The federal and state regulations governing controlled substance such as radioactive material, drugs, ethyl alcohol, explosives, and needles and syringes;
  9. Chemicals that have offensive smells; and
  10. Packages that exhibit evidence that the inside container has broken and leaked its contents.
Incidents and Accidents

1. Introduction: Reporting incidents and accidents is required by law. Relatively minor incidents without personal injury or only minor injury should be reported on the incident report form. Serious accidents (fatalities and multiple hospitalization injuries) must be reported directly to OSHA. Forms will be available from the Safety Officer.

2. Reportable Incidents Include:

A. Every accident (injurious or non-injurious). B. Accidents resulting in damage to instruments or the building. C. Situations or conditions, which have a potential for injury, hazard to health, or damage to the property. D. Situations in which a member of the public claims to be harmed.
3. Serious Accidents Include:
A. Fatalities B. Injuries requiring hospitalization C. Injuries requiring medical treatment D. Property damage E. Chemical exposure resulting in lost time which may involve the public
4. Investigation:
A. Minor incidents reported to the supervisor will be investigated and a report filed in a 30-year archive file with an evaluation and recommendations. B. Major accidents or serious incidents will be investigated by the supervisor and Safety Officer in conjunction with the safety committee and a full report given to the supervisor.
5. Reporting Accidents.
A. All accidents and injuries, no matter how minor, shall be reported PROMPTLY to the immediate supervisor, Office Director or person in charge of the work area. The agency's employee personal injury report form will be used to report all injuries or incidents.
B. The injured worker's immediate supervisor or the person in charge must conduct a thorough unbiased investigation to determine the cause(s) of the accident.
C. The injured employee and his/her supervisor shall handle and complete the Labor and Industries (L&I) Injury Claim Report, Form F242-130-111 if necessary.
D. The circumstances of any injury accident resulting in an immediate or suspected fatality shall be reported immediately to the local office of the Department of Labor and Industries and to the Safety and Benefits Section.
(1) Except where removal is essential to prevent further injury, equipment involved in a fatal accident shall not be moved until the investigation is completed or the equipment is released by the L&I investigator.
(2) All personnel shall cooperate fully with the L&I Industrial Safety and Health investigators and inspectors.
E. Cases involving injuries which are so severe that the employee may be off work for an extended period require the employee to be counseled with respect to benefits and various employment/compensation options available and how they may affect pay, retirement and leave provisions.
Accidents, Spills, and Releases. Spills of toxic substances or accidents involving any hazardous chemical shall be resolved immediately according to the State Public Health Laboratories' emergency procedure plan. Clean up of hazardous chemicals will be performed by qualified personnel from the area where the spill occurred. All accidents must be documented, and reported to the Safety Officer.

Emergency procedures for spills and accidents. All spills are different, and remediation requires judgement; below are some guidelines for reaction to spills.

  1. Attend to any person who may have been contaminated or injured.
  2. Notify your supervisor and appropriate emergency responders immediately.
  3. If spilled chemical is flammable, extinguish all nearby sources of ignition.
  4. Notify persons in the immediate area about the spill.
  5. Evacuate all nonessential persons from the spill area.
  6. If the spilled material is flammable turn off any heat source.
  7. If a person has been splashed with a chemical, remove all contaminated clothing, flush the contaminated area with running water for at least 15 minutes, and GET MEDICAL ATTENTION, CALL 911.
  8. If a person has been overexposed by inhalation, get victim to fresh air if it is safe to do so, begin rescue breathing if necessary, and GET MEDICAL ATTENTION, CALL 911.
  9. Avoid breathing vapors of the spilled material; if necessary use a respirator.
  10. Ingestion: GET MEDICAL ATTENTION, CALL 911and the local poison control center and follow their instructions.
  11. Leave on or establish exhaust ventilation if it is safe to do so.
  12. In other cases of overexposure, GET MEDICAL ATTENTION, CALL 911 and follow the instructions of the medical professional.
  13. Secure supplies to effect cleanup. Promptly clean up spills using appropriate protective apparel and equipment and proper disposal.
  14. Inform the safety officer if a regulated substance is involved.
Emergency procedures for spills and accidents. In handling emergencies:
  1. DO NOT handle emergencies alone, GET HELP.
  2. DO NOT linger at the accident scene if you are not one of the emergency responders.
  3. DO NOT apply medical aid procedures without training in first aid. If you are not trained in first aid, get MEDICAL ATTENTION, CALL 911, or contact a medical professional as soon as possible.
Release of hazardous substances. The release of hazardous substances should minimize exposure of personnel and property. This preplanning should include consideration of the following factors:
  1. potential location of the release;
  2. the quantities of material that might be released and whether the substance is a piped material or a compressed state;
  3. chemical and physical properties of the material (e.g., its physical state, vapor pressure, and air or water reactivity);
  4. hazardous properties of the material (its toxicity, corrosivity, and flammability), and
  5. the types of personal protective equipment that might be needed.
Commercial spill kits must be available with all applicators complete with instructions, absorbent, reactants, and protective equipment. These kits should also be strategically located in work areas where chemicals are stored, and with field personnel who will be travelling to treated areas.

Supplies and equipment must be on hand to deal with spills, consistent with the hazards and quantities of the spilled substance. These cleanup supplies should include neutralizing agents (such as vermiculite and sand). Paper towels and sponges may also be used as absorbent-type cleanup aids, although this should be done cautiously. Appropriate gloves should be worn when wiping up toxic materials with paper towels. Also, when a spilled flammable solvent is absorbed in vermiculite or sand, the resultant solid is highly flammable and gives off flammable vapors and, thus, must be properly contained or removed to a safe place.

Handling of Spilled Liquids:

  1. Wear appropriate personal protective apparel; gloves, overcoat, mask, eyewear, or face shields as necessary.
  2. Confine or contain the spill to a small area. Do not let it spread.
  3. For small quantities of materials, absorb the spill with nonreactive material such as vermiculite, dry sand, or towels.
  4. Carefully pick up and remove any cartons or bottles that have been splashed.
  5. If the spilled material is extremely volatile, let it evaporate and be exhausted before attempting to clean it up without protective clothing and respiratory gear. Be sure that associated mechanical equipment in the area is spark-proof.
  6. Dispose of residues according to safe disposal procedures (keep references manufacturer's references and material safety data sheets available to all personnel).
Exposure Evaluations and Medical Consultations

Suspected Exposures to Toxic Substances. When employees or supervisors suspect that an employee has been exposed to a hazardous chemical to a degree and in a manner that might have caused harm to the victim (circumstances suggest a reasonable suspicion of exposure), the affected employee shall be provided an opportunity for medical consultation. Such consultation shall be for the purpose of determining the need for a medical examination. All medical examinations and consultations shall be performed by or under the direct supervision of a licensed physician and shall be provided at no cost to the employee, without loss of pay and a reasonable time and place.

Criteria of "Reasonable" Suspicion of Exposure. It is the policy of the Forest Service to promptly investigate all employee-reported incidents in which there is even a remote possibility of employee overexposure to a toxic substance. Regular medical surveillance should be established to the extent required by the regulations.

Circumstances That Constitute a Suspected Exposure:

  1. Anyone whose work involves regular and frequent handling of toxicologically significant quantities of a chemical should consult a qualified physician to determine on an individual basis whether a regular schedule of medical surveillance is desirable.
  2. Where exposure monitoring reveals an exposure level routinely above the action level (or in the absence of an action level, the PEL) for an OSHA regulated substance for which there are exposure monitoring and medical surveillance requirements, medical surveillance shall be established for the affected employee as prescribed by the particular standard.
  3. A hazardous chemical leaked, spilled or was otherwise rapidly released in an uncontrolled manner.
  4. Odor was noticed, especially if person was working with any chemical, which has a lower TLV than odor threshold.
  5. An employee had direct skin or eye contact with a hazardous chemical.
  6. An employee manifests symptoms, such as headache, rash, nausea, coughing, tearing, irritation or redness of eyes, irritation of nose or throat, dizziness, loss of motor dexterity or judgement, etc.
  7. Some or all of the symptoms disappear when the person is taken away from the exposure area and breathes fresh air.
  8. The symptoms reappear soon after the employee returns to work with the same hazardous chemicals.
  9. Two or more persons in the work area have similar complaints.
  10. All complaints will be promptly investigated to determine risk of employee overexposure to the toxic substances in their work place.
Exposure Evaluation. All complaints and their disposition, no matter what the ultimate disposition may be, are to be documented. If no further assessment of the event is deemed necessary, the reason for that decision should be included in the documentation. If the decision is to investigate, a formal exposure assessment will be initiated.

Exposure Assessment. In cases of emergency, exposure assessments are to be conducted by a Chemical Hygienist after the victim has been treated.

It is not the purpose of an exposure assessment to determine that a failure on the part of the victim, or others, to follow proper procedures was the cause of an exposure. The purpose of an exposure assessment is to determine that there was, or was not, an exposure that might have caused harm to one or more employees or members of the public, and, if so, to identify the hazardous chemical or chemicals involved. Exposure assessments determine facts; they do not make recommendations. Unless circumstances suggest other or additional steps, these actions constitute an exposure assessment:

  1. Interview the complainant and also the victim, if not the same person.
  2. List the essential information about the circumstances of the complaint, including:

  3. A. The chemical and physical properties involved and the quantity in use; the potential for overexposure associated with the operation involved and an estimation of the duration of exposure;
    B. Other chemicals used by victim;
    C. All chemicals being used by others in the immediate area;
    D. Other chemicals stored in that area;
    E. Symptoms exhibited or claimed by the victim;
    F. How these symptoms compare to symptoms stated in the materials safety data sheets for each of the identified chemicals;
    G. Were control measures, such as personal protective equipment and clothing, being used properly?;
    H. Were any air sampling or monitoring devices in place? If so, are the measurements obtained from these devices consistent with other information?;
    I. Monitor or sample the air in the area for suspect chemicals;
    J. Determine whether the present control measures and safety procedures are adequate.
Physician Written Opinion. For examination or consultation required under this standard, the employer shall obtain a written opinion from the examining physician (WAC 296-62-40013) which shall include the following:
  1. Any recommendations for further medical follow-up.
  2. The results of the medical examination and any associated tests.
  3. Any medical condition, which may be revealed in the course of the examination, which may place the employee at increased risk as a result of exposure to a hazardous chemical, found in the workplace.
  4. A statement that the employee has been informed by the physician of the results of the consultation or medical examination and any medical condition that may require further examination or treatment.
  5. The written opinion shall not reveal specific finding of diagnoses unrelated to occupational exposure.
Notification of Monitoring Results. Within 15 working days of receipt of the results of any monitoring, employees will be notified of those results either individually or by posting results in an appropriate location that is accessible to employees.

Medical Consultation. When employees are suspected or known to be overexposed to toxic chemicals, they should receive prompt medical attention. To ensure that they do receive proper and informed medical attention, the Forest Service will designate preferred medical facilities for consultation and diagnosis.

Medical Consultation Authority. It is the authority of the Safety Officer, to authorize medical consultation in Non-Emergency cases. The employee to be examined will consult with or visit previously designated medical facility. It is the responsibility of supervisory staff or designee to arrange transportation to and from the medical facility. (Note; if chemical exposure is confirmed or suspected, a supervisor cannot assure the victim can properly operate a motor vehicle). The medical report will be sent directly to the Safety Officer, who will pass the appropriate information along to those involved.

Documentation. All memos, notes, and reports related to a complaint of actual or possible exposure to hazardous chemicals are to be maintained as part of the record.

Notification. Employees shall be notified of the results of any medical consultation or examination with regard to any medical condition that exists or might exist as a result of overexposure to a hazardous chemical.

Pesticides. A pesticide label containing information on use and safety must be attached to all pesticide containers. The label includes the product name, name and amount of active ingredients, EPA registration number and establishment number, name and address of the manufacturer, and net contents.

The use classification (general use or restricted use) is noted on the label. The signal word (danger, warning, or caution) provides information about hazard classification. Precautionary statements inform users of handling requirements, procedures, and special concerns. Directions for use specify legal application sites, rates, and mixing and handling instructions. The pesticide label is a binding legal agreement between the EPA, the registrant, and the user. It is illegal to use a pesticide in a way or place not specified on the label.

Procedures for Carcinogens, Reproductive Toxins, Substances with a High Degree of Acute Toxicity and Chemicals of Unknown Toxicity. Follow the procedures described in this section when performing work with any carcinogen, reproductive toxin, substance that has a high degree of acute toxicity, or a chemical whose toxic properties are unknown. This includes pesticides with "inert ingredients" that have not been profiled by the EPA.

The following definitions will apply:

1. Select carcinogen: Any substance defined as such in 29 CFR 1910.1450 and any other substance described as such in the applicable MSDS. "Select carcinogen" means any substance, which meets one of the following criteria:

A. It is regulated by OSHA as a carcinogen;
B. It is listed under the category, "known to be carcinogens," in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) (latest edition); or
C. It is listed under Group 1 ("carcinogenic to humans") by the International Agency for Research on Cancer Monographs (IARC) (latest edition); or 7.4Procedures for Carcinogens, Reproductive Toxins, Substances with a High Degree of Acute Toxicity and Chemicals of Unknown Toxicity
D. It is listed in either Group 2A or 2B by IARC or under the category, "reasonable anticipated to be carcinogens" by NTP, and causes statistically significant tumor incidence in experimental animals in accordance with any of the following criteria: a) After inhalation exposure of 6-7 hours per day, 5 days per week for a significant portion of a lifetime to dosages of less than 10 mg/m3; b) After repeated skin application of less than 300 (mg/kg of body weight) per week; or c) After oral dosages of less than 50 mg/kg of body weight per day.
2. Reproductive toxin: Any substance described as such in the applicable MSDS, or any substance identified as a reproductive toxin by the Oak Ridge Toxicology Information Resource Center (TIRC), (615)576-1746; or for teratogen only: Any substance identified as such in Thomas H. Shepard, "Catalog of Teratogenic Agents", 6th ed., John Hopkins Press, 1989. 3. Substance with a high degree of acute toxicity: any substance for which the LD50 data described in the applicable MSDS cause the substance to be classified as a "highly toxic chemical" as defined in ANSI Z129.1 4. Chemical whose toxic properties are unknown: A chemical for which there is no known statistically significant study conducted in accordance with established scientific principles that establishes its toxicity.

All work involving carcinogens must be done using barrier clothing out of doors to reduce the risks of employee exposure to the vapors.

Records. This section reviews the value of documenting compliance with this safety standard for general liability and the ability to periodically assess the safe conduct of employees.

  1. Accident records should be written and retained.
  2. Chemical Hygiene Plan records should document that the facilities and precautions were compatible with current knowledge and regulations.
  3. Inventory and usage records for high-risk substances should be kept as specified. Maintain records of the amounts of these materials on hand, amounts used, and the names of the workers involved.
  4. Medical records should be retained by the institution in accordance with the requirements of state and federal regulations.
  5. Specific records may be required in the event of time loss resulting from an exposure by accident on the job. The standard form OSHA 200 is used to document lost workdays from incidents that occur at work.
  6. In addition to records required by OSHA, it will be desirable to keep special records developed internally which document suspected exposures and employee exposure complaints regardless of the outcome of the Exposure Evaluation. Other incidents and activities could be documented for future reference. These include:

  7. A. COMPLAINTS FROM EMPLOYEES - Even if the complaint is found to be unjustified, it is desirable to keep a record of the complaint, the investigation, and the outcome. The complaint might be about chemical exposure, but could include complaints about inoperative-engineered controls or defective personal protective equipment.
    B. REPAIR AND MAINTENANCE RECORDS FOR CONTROL SYSTEMS - Demonstrate that equipment such as protective clothing and gear is well maintained and kept in clean, proper operating order. These are useful; they suggest corrective actions and indicate that equipment was or was not well maintained and kept in working order.
    C. MAJOR SAFETY SUGGESTION FROM EMPLOYEES - Can be valuable to improve workplace safety. Even if the issue is decided to be non-workable, the fact that the suggestion was take seriously and examined is valuable.
    D. NEAR-MISS REPORTS - Employees who participate in or witness events that could have caused harm, but fortunately did not, should prepare reports of the incidents. These reports are used to develop changes in procedures that will prevent a future more serious occurrence.
    E. RECORDS TO BE KEPT - The Forest Chemical Safety Plan requires that records of air concentration monitoring results, exposure assessments, medical consultation, and examinations be maintained for at least 30 years and that they be accessible to employees or their representatives. A system will be developed to retain documents related to distribution and maintenance of Material Safety Data Sheets and to the safety training of employees. Specific records may be required in the event of lost work time resulting from injury on the job.
Record keeping. All records should be kept for at least as long as the employees affected are employed with the Government. Require medical records to be kept for 30 years beyond the employee's time of employment. It is prudent to set up an archiving system to keep all-important documents related to safety employee training and distribution of Material Safety Data Sheets for the lifetime of the company. Medical records of employees who have worked less than one year need not be retained after employment, but the employer must provide these records to the employee upon termination of employment.

Storage of Records and Documents. All records pertaining to personnel training, and safety concerns or actions will be kept in a locked fireproof container. These records will be accessible to the employee to whom they pertain.