2019 Gypsy Moth Slow the Spread Mating Disruption

2019 GYPSY MOTH SLOW THE SPREAD MATING DISRUPTION

PROJECT AVIATION SAFETY AND MANAGEMENT PLAN

IN COMPLIANCE WITH CONTRACT # AG-56A1-C-17-0002

Contents Project Aviation Safety Plan (PASP) ...... 3 PROJECT DESCRIPTION...... 4 BASES OF OPERATION ...... 7 PROJECT AVIATION SAFETY PLAN BRIEFING ...... 10 Project Maps...... 12 MISHAP RESPONSE PLAN ...... 23 Hazard ...... 26 JOB HAZARD ANALYSIS ...... 41 OPERATIONS ...... 42 2019 ORGANIZATION CHART...... 45 OPERATIONS PERSONNEL ...... 51 PROJECT SAFETY REQUIREMENTS & PROJECT SECURITY PLAN ...... 53 PROJECT AND AIRCRAFT MANAGEMENT SECURITY PLAN ...... 55 AIRFIELD AND AIRCRAFT SECURITY CIRCULAR ...... 59 2019 STATE EMERGENCY CALL NUMBERS ...... 66 APPLICATION LABELS ...... 67

Project Aviation Safety Plan (PASP) 2019 Gypsy Moth Slow the Spread Mating Disruption State, Private, Federal lands in R9 and R8

Mission: Aerial Application Project Name: Gypsy Unit: FHP-R9, R8 Fixed Wing Moth Slow the Spread Mating Disruption

Anticipated Project Date: June 1 – August 1, 2019

Project Plan Prepared by: Title: Date: /s/ Laurel Haavik Entomologist, FHP-R9 3/22/2019 /s/ Tom Coleman Entomologist, FHP-R8 3/22/2019

Project Plan Reviewed by: Title: R9 Regional Aviation Officer Date: Robert Madill

Project Plan Reviewed by: Title: R8 Regional Aviation Officer Date: Jerry Perry

Project Plan Approved by: Title: R9 Regional Forester Date: Kathleen Atkinson

Project Plan Approved by: Title: R8 Regional Forester Date: Ken Arney

Final Risk Assessment Value (see page 8): One hazard remained high risk after standard and local mitigation. Due to the nature and complexity of aerial application, some hazards will always remain high regardless of mitigation. Prepared By: Tom Coleman, Laurel Date: 3/22/2019 Haavik

Operation Approved By: Title: R9 Aviation Safety Mgr. Date: George (Nick) Hough Operation Approved By: Title: R8 Aviation Safety Mgr. Date: James Keyes

Project Description This project will include 5 Air Tractor aircraft that are designed and built for aerial application and 3 Cessna aircraft for flight following and communications. All aircraft will be operated by Al’s Aerial Spraying in compliance with FAA Part 137 or Part 135 Operations (as applicable) and with contract specifications (Contract No. AG-56A1-C-17-0002).

The mission is to aerially apply mating disruptants (a pesticide) to slow the spread of the gypsy moth. The aircraft have been contracted to apply SPLAT GMO to approximately 248,877 acres in the states of Virginia, North Carolina, Ohio, Indiana, Iowa, and Wisconsin. The majority of the acres are non-federal lands but there is some federal acreage on two National Forests (the Wayne in Ohio and the George Washington and Jefferson in Virginia) and the St. Croix National Scenic Riverway in WI. The contract is implemented as a service to the states that partner with FS in USDA’s program to Slow the Spread of the gypsy moth (STS). Applications are timed to occur just prior to the emergence and flight of the adult male gypsy moths starting in early June in the south and finishing in late July in Wisconsin. The cloud of pheromone released by the mating disruptants prevents the males from finding or mating with the females; thus suppressing or eliminating the population. Work will start in early June (North Carolina) and should be completed by August 1 in northern Wisconsin.

Justification for Aircraft Use: Application of pesticides to 248,877 acres across 6 states utilizing any method other than aerial application would not be operationally feasible in the narrow biological window available for treatment. Additionally, ground applications would be cost prohibitive, less effective and require the hiring, training and licensing of hundreds of temporary personnel.

General Location/Description: See attached maps. Due to the complexity and scale of this project (55 treatment blocks scattered across 6 states), aerial hazards are not included on these maps. These maps are to provide the PASP reviewers with the general location of the treatment blocks in each state. More detailed maps can be found in the STS map library at http://www.gmsts.org/library.html.

The Project Manager/COR will conduct safety meetings for all project personnel in each state prior to the start of treatment activities. The cooperating state agency prepares maps showing each treatment block and any hazards associated with spraying of the block. All hazard maps are reviewed by the COR, state agency personnel, and contractor prior to starting work. It is also the responsibility of each pilot in command to perform reconnaissance of the spray blocks prior to treatment to become familiar with the boundaries, terrain, and hazards (Contract Specifications, exhibit 13, pg. 36).

APPLICATION AIRCRAFT INFORMATION Vendor: Al’s Aerial Spraying, Ovid, MI Phone: 989-834-5067 Cell: 517-331-7278 Type of Flight: Aerial Application Desired Make/Model: Air Tractor Aircraft N#: Make/Model: Aircraft Color: N444AS AT 400 AT yellow N445MS AT 502B AT yellow N444MS AT 400 AT yellow N144KS AT 400 AT yellow N1025A AT 502 AT yellow N7307T AT 400 AT yellow

Aircraft carded: Prior to mission Application Pilot Names: Al Schiffer, Mike Schiffer, Dan Dantuma, Mike Welch, Ronald Evans, Frank Kimmel, Ralph Lutes, Kent Niese Pilots carded: Yearly, prior to mission, for duration of contract

OBSERVATION AIRCRAFT INFORMATION

Vendor: Al’s Aerial Spraying, Ovid, MI Phone: 989-834-5067 Cell: 517-331-7278 Type of Flight: Aerial Observation Desired Make/Model: Cessna 172/182 Aircraft N#: Make/Model: Aircraft Color: N42801 Cessna C-182 White with various N759JM Cessna C-182 markings N3343F Cessna C-182 N8470M Cessna C-182

Aircraft carded: Yearly, prior to mission, for duration of contract Pilot Names: Virgil Williams, Rodney Bodwalk, Raymond Hill, David Folk, Mike Schiffer Pilots carded: Prior to mission Type of Procurement: Firm, fixed price Charge Code: N/A contract with 4 option years Estimated Flight Hours: 450 hours in Estimated Cost: $1.1 million 2019 (application flight hours + hours flight for observation aircraft)

SUPERVISION

Project Aviation Manager/COR: Contact Number: 828-446-5142 (cell) Tom Coleman Aircraft Manager: Tom Coleman Contact Number: AG-56A1-C-17-0002, OY 2

PARTICIPANTS: Even though personnel listed below are qualified as project aviation managers, Tom Coleman is designated as the project aviation manager. All project personnel are responsible for aviation safety, regardless of the roles/positions assigned. Name: Laurel Haavik Project Role: Project Aviation Mgr./Contract Inspector Name: Amy Hill Project Role: Project Aviation Mgr./Contract Inspector Name: State Cooperators Project Role: Ground operations supervisor; public information and coordination of daily operations plan.

CARGO No cargo is carried on the application aircraft during performance of mission. Pesticide carried totals a maximum of 450 lbs. if the disruptant hoppers are loaded to maximum capacity.

Weight: N/A Non Hazardous Materials

PERFORMANCE PLANNING

Load Calculations: All weight/balance calculations are completed by FS Aviation at carding.

FLIGHT FOLLOWING

Radio – observation aircraft will flight follow application aircraft with verbal check-ins every 15 minutes, then relay to project personnel at mobile base (airport). AFF - AFF is required on application and observation aircraft. Contract Inspectors will flight follow with position checks every 15 minutes utilizing AFF as a back-up to radio flight following. AM Air to Air: 130.650 or 129.70 (back-up) AM Unicom: 122.70

BASES OF OPERATION

Airport Runway Length (ft) Danville Regional Airport (DAN) 5900X100; asphalt Danville, VA Mountain Empire Airport (MKJ) 5252X75; asphalt Wytheville, VA Zanesville Municipal Airport (ZZV) 5000X150; asphalt Zanesville, OH Fairfield County Airport (LHQ) 5004X75; asphalt Lancaster, OH Putnam County Airport (OWX) 4504X75; asphalt Ottawa, OH Albertus Airport (FEP) 5504X100; asphalt Ottawa, OH Boscobel Airport (OVS) 5000X75; asphalt Boscobel, WI Prairie Du Chien Municipal Airport (PDC) 5000X75; asphalt Prairie Du Chien, WI La Crosse Regional Airport (LSE) 8742X150; concrete La Crosse, WI Chippewa Valley Regional Airport (EAU) 8101X150; concrete Eau Claire, WI Solon Springs Municipal Airport (OLG) 3099X60; asphalt Solon Springs, WI Burnett County Airport (RZN) 5000X75; asphalt Siren, WI

MILITARY TRAINING ROUTE (MTR) OR MILITARY OPERATING AREA (MOA)

MTRs and MOAs are overlaid on spray block maps that are located in the Contractor and FS work trailer. FS project personnel communicate directly with the military daily to deconflict MTRs or MOAs. Phone numbers, contact person, date, and time are recorded for the project file. Also, military personnel are given the phone number of the FS work trailer if training schedules change. Observation aircraft pilots also check daily with Flight Services for any NOTAMS, DROTAMS, and TFRs.

PERSONAL PROTECTIVE EQUIPMENT

Type of Operation Personnel Protective Equipment Requirements Fixed Wing-Low Level Flight Application Pilot: Nomex flight suits, helmets, leather boots, polyamide or aramid gloves per contract specifications (Exhibit 2, page 9) Justification Statement for Low Level Flights: In order to be effective and to minimize drift, pesticides must be delivered close to their target (i.e., foliage). According to contract specifications (Exhibit 13, page 36), application release height of 100 to 200 feet above treetops will be maintained unless otherwise directed by government personnel to comply with FAA direction or to mitigate impacts to threatened and endangered species.

EMERGENCY RESPONSE

Procedures: First call to 911. Second call to appropriate USFS Dispatch. Follow Interagency Aviation Mishap Response Guide and Checklist in cooperation with USFS dispatch (See Mishap Response Section)

STS AVIATION RISK ASSESSMENT (See Risk Assessment Worksheet Section)

STS AVIATION MITIGATION SUMMARY

Pre-Mitigation Hazards Count of Outcomes Outcome Grand System High Serious Medium Low Total Aircraft 8 15 6 1 30 Environmental 17 11 5 33 Personnel 26 7 5 38 Technology 7 4 7 1 19 Grand Total 58 37 23 2 120

Post Mitigation Hazards

Count of Outcomes Outcome2 Grand System High Serious Medium Low Total Aircraft 2 4 20 4 30 Environmental 1 11 18 3 33 Personnel 6 29 3 38 Technology 5 11 3 19 Grand Total 3 26 78 13 120

Post Local Mitigation Hazards Count of Outcomes Outcome3 Grand System High Serious Medium Low Total Aircraft 1 1 19 9 30 Environmental 9 12 12 33 Personnel 1 22 15 38 Technology 2 11 6 19 Grand Total 1 13 64 42 120

PROJECT AVIATION SAFETY PLAN BRIEFING A copy of this briefing page will be submitted to the NA, R8, R9 Aviation Officers within 5 days of the completion of this project. Briefing Leader: Briefing Date: Time: Location: Discussion Items: A. Hazard Analysis (as outlined in plan) B. Safety Air Ops (Ground) C. Safety Air Ops (Flight) D. Military Training Routes E. Flight Following F. Frequencies G. Fueling H. Emergency Evacuation Plan I. Authorities J. Weather Considerations K. Airspace Review (TFRs, NOTAMS) L. Other Attendees Signature and Concurrence

Name Project Responsibility/Role Date

Mission Planning/Preflight Briefing Checklist: Will be reviewed with all participants as part of daily preflight briefing 1. Chain of command, individual roles and responsibilities are identified to all participants? Yes No NA 2. Project Aviation Safety Plan is approved and signed at the appropriate levels? Yes No NA 3. Is the emergency evacuation plan, helibase crash/rescue plan reviewed? Yes No NA 4. Are communications and flight following established, including repeater tones? Yes No NA 5. Can terrain, altitude, temperature or weather that could have an adverse effect be Yes No NA mitigated? 6. Are all aerial hazards identified and known to all participants? Yes No NA 7. Have ground operations hazards and safety been identified to all participants? Yes No NA 8. Have mitigating measures been taken to avoid conflicts with military or civilian aircraft? Yes No NA 9. Have adequate landing areas been identified and or improved to minimum standards? Yes No NA 10. Are all agency personnel qualified for the mission? Yes No NA 11. Are there enough (qualified) agency personnel to accomplish the mission safely? Yes No NA 12. Is the pilot carded and experienced for the mission to be conducted? Yes No NA 13. Will adequate briefings be conducted prior to flight to include Pilot, Passengers and Yes No NA Dispatch (all participants)? 14. Are all involved aware that the pilot has the final authority, but if any Yes No NA passenger/aircrew/ground personnel feels uncomfortable, that they can refuse/curtail the flight without fear of reprisal? 15. Is the aircraft capable of performing the mission with a margin of safety? Yes No NA 16. Have manifests of cargo and passengers, load calculations and/or weight & balance Yes No NA completed? 17. Is the aircraft properly carded? Yes No NA 18. Do all personnel have the required PPE? Yes No NA 19. Fuel planning, adequate fuel on board, fuel truck location, availability of commercial Yes No NA fuel? 20. Remember; maps of areas/sites, handheld radios, cell phones, day/survival packs, sic Yes No NA sacks 21. Will the mission be conducted at low levels? (Below 500’ AGL) Yes No NA 22. Can the same objective be achieved by flying above 500’ AGL? Yes No NA 23. Are pilot flight and duty times compromised? Yes No NA 24. Is there an alternative method that would accomplish the mission more safely? Yes No NA Above items (1-20) checked “NO” and item (22-24) checked “YES” require correction, and /or re-evaluation of flight/mission before proceeding. Evaluate additional items accordingly. Identify Correction:

Aerial application of pesticides must be done at low levels in order to be effective and reduce off-site drift. Other than use of highly experienced pilots in aircraft designed and built for the mission, no correction possible

Aircraft/Flight Mgr. Date Pilot Signature: Date Signature:

Project Maps

MISHAP RESPONSE PLAN 1st call: 911 2nd call: FS Dispatch

FOREST SERVICE DISPATCH AND INTERAGENCY AVIATION MISHAP RESPONSE CONTACTS The plan provides both immediate actions and general instructions to follow in the event of an aviation accident. It is the responsibility of project coordinators to coordinate organizational and local needs through one of the following individuals on the Forest or Geographical Area Coordination Center (GACC) supporting the particular operating area. In most cases the GACC is the Forest Dispatch contact in each state. The following National Forests will be available for support:

Emergency Contact List

STATE NATIONAL FOREST FOREST DISPATCH FOREST MANAGEMENT OFFICE CELL PHONE PHONE OH Wayne NF 740.624.2284 740-753-0571 Dispatcher: OH-OIC Michele Stephens 740.516.3535

IN Hoosier NF 812.547.9262 Terry Ceberson (FMO) 812.547.9247 Dispatcher: Maggie Schuetter Jackie Contreras (dispatcher) 812-547-9250

VA GWNF 540.265.5221 Dan Martin (FMO) 434-423-2002 Dispatcher: Marina Foltz

WI Chequamegon Nicolet NF 715.362.1337 Jim Grant - FMO 715.362.1341 715.493.6934 Dispatcher: Steve Radaj

NC NF of North Carolina 828.257.4264 Steve Little (FFMO) 828.257.4811 828.778.2077 Dispatcher: Fred Mascher – Center Diane Hinz Mgr. (828.777.2075 cell)

IA no NF George (Nick) Hough 414.297.1068 414.208.7570 Dispatcher: Nick Hough (R-9 Aviation Safety Manager)

Forest Service Regional Aviation Contacts: Regional Name E-mail Office Cell R-8 Aviation Officer Jerry Perry [email protected] 770.237.1014 478.804.1181 (1014) R-8 Aviation Safety James Keyes [email protected] 404-780-0590 Manager R-9 Aircraft Maint. Dave Serena [email protected] 218.827.8228 218.780.9616 Safety Insp. R-9 Pilot Insp. TBD R-9 Aviation Officer Bob Madill [email protected] 414.297.3744 414.207.2224 R-9 Regional Aviation George (Nick) Hough [email protected] 414.297.1068 414.208.7570 Safety Manager

Crashed/downed aircraft 1. Call 911. A lot of details will not be known when you call. You may have to call them back with precise crash coordinates/location if not known right away (chase or other aircraft may not be there yet). Ask if this call will notify the state police. If it does not, call them.

2. Call USFS dispatch for the state you are in. a. Tell then you have called 911. b. Ask about 1-800-4MISHAP – should they call or should I? c. The Forest Dispatch should activate the Interagency Mishap Response Plan (IAMRP), but ask. 3. As soon as possible after calling 911, send someone to the crash site – perhaps a state ground observer, maybe someone at the airport. Have them photograph everything. Have them secure the site until law enforcement or fire arrives. Preserve the scene and remind the contractor that they are not to disturb the wreckage if on site. Also, instruct who goes that there are many hazards at the site – Biohazards (viruses, etc.), toxins (batteries), fire hazards (fuel and oil), pressure vessels (Oxygen containers, tires), mechanical hazards (propellers and sharp edges), and natural environmental hazards (slopes, snakes) that should be considered before acting. Use PPE as recommended (gloves, long sleeves, etc.). Ideally, this PPE is in a kit in the observer’s car. When emergency services (police or fire), arrive at the scene, physical control of the crash site should be turned over to them.

NOTE: Placing calls 1 and 2 (above) will trigger a response from all relevant emergency management agencies (including the FAA and NTSB, if appropriate). After these two calls and sending someone to the site, the remaining activities are notification related (administrative), not for emergency response.

4. Call the USFS. a. NA/R9/R8 aviation contacts: These folks will have a list to be sure that all other necessary actions have been taken. b. Call Asheville, Morgantown and Minneapolis/St. Paul Field offices c. Call the Contracting Officer

5. The state should contact their pesticide spill/hazmat and/or other relevant agencies.

6. The contractor is to call NTSB at some point soon [See “Mishaps” Exhibit 2 (pages 8-10) of the contract].

7. Document all things about the project to this point. Encourage others to prepare their notes.

8. If other planes are not needed for finding the crash site or for other matters related to the crash, allow application planes to finish loads. This decision should be left up to the pilots and they won’t be forced to continue. After the

current load, they will probably be grounded for the remainder of the day. A 24 hour safety stand down will almost certainly occur the following day.

Overdue aircraft 1. 15 minute check-in is required, aside from point to point flights or when AFF is used.

2. If check in is missed, call chase. If no luck, try aircraft via radio or phone, or review AFF data.

3. If no response in 30 minutes, call vendor home base, and the FBO of their expected destination. Next, contact the FAA/Lockheed-Martin Flight Service Station and request and Alert Notice (Alnot): 1-800-992-7433, select 1 to talk to “briefer” (expect a call back)

4. Call the USFS. a. Call USFS dispatch for the state being worked in, or the Forest on which work is being conducted. b. Call R9/R8 aviation contacts: They will have a list to be sure that all other necessary actions have been taken. c. Call the Field office that covers the state you are working in. Inform the Field Reps and Unit Aviation Officers. d. Call the Contracting Officer.

Risk Assessment: STS Aerial Application of Mating Disruptants

Pre Mitigation Post Mitigation

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Remote, unsecure work areas and service Adhere to Project Aviation Safety and Security Plans.

landings (risk to containment, aircraft, Contract addresses security in remote locations, security Contract requires night security. Contractor only uses

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FAA approved congested area plans (CAP) are required. The Contractors must file Congested Area Plans with FAA. Contractor has never been refused approval by FAA. Contractors must adhere to FAA requirements (i.e. some Contractor has a waiver to use a restricted category aircraft

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gh wing operations). Obtain and familiarize with g

r i X

obab obab a and an exemption to 14 operations over congested areas (14 ed

r r

air traffic areas C manufacturer's glide data. Simulate feather/dump/turn S

P P CFR Part 137.51 (b) 4) based on the performance data and M and glide sequence for proficiency and recording GPS file safety history of turbine powered ATs. This simplifies and to document and aid Plan approval. streamlines the process of getting FAA approval for their CAPs.

c c

i i

m Last minute contract changes, dropping If at all possible, leave the block as planned so flight

onal ote SOP for this project includes finalizing all block

oph oph

ous

r r

portions of blocks increases risk to pattern and turns are not affaected. Do not edit blocks m

r X

e e boundaries at least 2 weeks before implementation

R operational safety and to the public the day before treatment. M

atast atast

Occas

C C

There are no maintenance requirements

c c

i i

'per se' for aircraft operating under FAA l Contract requirements include 100 hr inspection and The contractor performs 100 hour inspections, utilizes the FAA

onal

oph oph

gh gh

ous

r r part 137, only the minimum requirements established TBO or TBO extension program through FAA X approved MORE TBO extension program and uses third i

Hi Hi

obab

S P generation, purpose built turbine powered aircraft. per FAA part 91 (annual inspection) atast atast

Occas

C C

Pre Mitigation Post Mitigation

Not Not

e e

y y

ion

t t

ble

n n

m m

i i

r r

o o

io io

eved eved

hood hood

t t

Sub-system Hazard c Mitigation c Additional Local Mitigation

a a

hi hi

c c

eve eve

ut ut

ig ig

S S

A t A t

ikeli ikeli

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Appli

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Turbine-powered aircraft required in contract. (Note: by

Potential for reduced reliability of Contractor utilizes third generation, purpose built, turbine m

um u

onal cal design turbine-powered aircraft tend to have more power ote cal i i

i i i

ous

t t

reciprocating engines compared to i m i powered AT aircraft for application but chase aircraft are not

r X

r r

e e and are more reliable, but does not always guarantee

C C

turbine-powered aircraft turbine powered. M Occas better performance)

Contract specifies minimum required production rates for each

Too many or too few aircraft for i

Project planning determines type of aircraft and contracts project area. Contractor routinely surpasses the required

cal

ote ote

oph

production needs/project area, i

ous

m specify production rates (acres treated per hour) needed m X r production rates. The number of aircraft used in each project

e e

unsuitable spray platform for mission C

R R to complete the project. M

atast area is tailored to the production required to complete that

profile C project area on time.

c c

i i

Contract requirement that all application pilots are Observation aircraft pilots also recon each area prior to and m

ote i

No pre-application survey of area prior to i

oph oph

ous

r r

obab

m responsible for the reconnaissance of each area X during treatment and remind application pilots of hazards each

e project for aerial hazards e

M before treatment. time they re-enter a block with a load. M

atast atast

C C

Fuel Contractor has two levels of verification. 1) A meter is installed on the fueling hose, the results of which are given to

i the pilot when fueling is complete. A Shadin fuel totalizer is

m m

h u u

i i onal Monitor quantity pumped during fueling, monitor flight

oph

g i installed in all cockpits and the pilot compares the two

i Starvation m X

ed ed

a time and distance to services e C figures. 2) Second verification through the single point

M M

atast

O C fuelding system which indicates when a tank has been filled to the selected level. Loads are calculated after considering ferry distance.

Ensure fuel is tested for type and quality prior to fueling. Conractor only pumps fuel to application aircraft through it's m

um um u

Bad fuel (more likely in portable fuel i i i

ote cal cal

i i

t t

obab

m i Monitor quantity pumped. Ensure fuel filters are changed i X own fuel filtering and delivery system which is sampled

ed ed

r r ed systems) e

C C

M M

as required by manufacturer. regularly. M

Availability Environmental conditions for spraying are relaxed with

disruptants compared to liquid sprays; thus urgency to perform

m Involve Supervisor, Program Manager & flight Manager in is decreased. Contractor provides more than adequate

ote

Sense of urgency & pressure to perform onal

oph oph

ous

m all stages of planning and risk assessment. r X numbers of application aircraft and skilled application pilots to

Hi st

(pilot, manager, organization) a

atast meet specified production rates.

Occas

C Program manager/COR will not tolerate performance pressure to outweigh safety considerations

Contractor provides extra aircraft to exceed the production

Tendency to over utilize single i Flight Managers & Program Manager need to be involved

rates thus limiting the pressure to push duty times. Flight m

ote

oph vendor/pilot & maximize flight hours due oph in flight hour/duty day monitoring. Adhere to contract

ous

obab

m X r hours/duty day times are monitored for each pilot and are

to limited availability of other aircraft specifications regarding flight hour/duty limitations. p

atast discussed daily so pilots can manage their loads to remain

within the duty limitations. System - Environmental (FHP Aerial Application)

Weather / Time of l l

m Contract specifies thresholds for allowable winds,

na na

Day i i

onal High wind, high temperatures, low i Size of disruptant particles (flakes or SPLAT drops) is large

ous

g g

s r temperature & relative humidity, cease operations when r X

a a

equent

humidity (pesticide drift) e enough to minimize drift; humidity is not a factor.

M M

F drift conditions exist

Pre Mitigation Post Mitigation

Not Not

e e

y y

ion

t t

ble

n n

m m

i i

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o o

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eved eved

hood hood

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Sub-system Hazard c Mitigation c Additional Local Mitigation

a a

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ikeli ikeli

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c c

i i

m High wind, low humidity, high Contract specifies performance requirements, conduct

Max load in pods (450 lbs) is far below what the aircraft is i

oph oph

g ous

temperatures (affect on aircraft tr load calculations/weight & balance; cease operations tr X

s s

equent

e e certified to carry so overloading is not a factor.

a a

t t

performance) F when conditions out of parameter

a a

C C

Suggest pilots utilize on-board, real time weather

c c

i i

Contractor has installed real time weather on all application

program (such as XM weather on Garmin-type GPS); s

Thunderstorms, lightening, hail, high onal oph o oph aircraft, mobile base has it's own DTN weather station,

ou ous

i i

tr program managers monitor weather stations provided at tr X

r r

s s

e winds e observation pilots monitor weather conditions and program e

a a

S S

cc t airport office, use observation aircraft to help monitor t

a a O manager also monitors weather. C weather conditions C

c c

i i Typical operations start at 6:30 or 7:00 AM well after sunrise

Typically morning operations & in oph oph and conclude at 4:00 PM well before sunset. Contractor plans

ous

Preflight briefing to raise awareness i tr tr X

s s

obab

equent shadows/glare conditions applications on North/South spray lines whenever possible to e

a a

t t

F a a mitigate shadow/glare problems.

C C

Topography or

l l

m m

a a

u u

c c

Time application based on anticipated prevailing winds, i i High Altitude o

i i

Turbulence t t

i i X

ed ed

r r

equent cease operations if unsafe/out of parameter e

C C

M M

m m

u u

onal c

i i

Plan project/treatment block such that application o

oph

i i

t Terrain - box canyons s

i X

ed ed

s r

flight lines allow egress; brief pilot e

M M

m m

u u

onal c

Perform load calculations for departure and i i

oph

i i

t High Altitude - density altitude s

i X

ed ed

s r

destination e

M M

C Remote Areas or Poor Road Access Contractor aircraft all have a minimum of dual coms with an audio panel. Communications are checked prior to the c c

i i

m t leaving the ground for each load. Occaisional issues with

oph Test radio communications prior to project oph

ous

Lack of communications m tr tr X agency/state ground to ground communications (poor cell

s s

e obab implementation

a a

t t P coverage) have been overcome by using observation pilots to

a a C C convey messages to ground personnel in blocks.

c c

i i

Mishap Response Plan to address search and rescue

e Contractor utlizes Aventech satellite based real time AFF;

onal

Long response time in event of search and o oph procedures, observation aircraft may be used to assist oph

ous ous

i i

tr tr X observation aircraft function as "eyes on application aircraft".

r r

s s

e rescue guiding rescue vehicles/personnel to accident site; utilize e e

a a

S S

t t

a a

AFF

C C

Pre Mitigation Post Mitigation

Not Not

e e

y y

ion

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ble

n n

m m

i i

r r

o o

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eved eved

hood hood

t t

Sub-system Hazard c Mitigation c Additional Local Mitigation

a a

hi hi

c c

eve eve

ut ut

ig ig

S S

A t A t

ikeli ikeli

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Appli

L L

Mi Mi

Contractor aircraft all have single point fueling to ensure

propert amounts are loaded and a shadin fuel flow/totalizer to

maintain accurate awareness of fuel remaining in both time

m m

t a and quantity. Prior to take-off for each load, the fueler and

u u

o Monitor flight time/fuel consumption, utilize fuel trucks or i i

oph

Fuel starvation, proper fuel unavailable r

m obab tr X pilot check concurence of aircraft fuel added by comparing the

ed ed

e e have optional fuel sources identified

a S

M M t loader meter with the pilot's on board meter. Initial radio

Im C contact with base after take-off confirms fuel on board. Contractor utilizes their own fuel trucks.

Contractor must obtain permission from airport manager,

l l

Unimproved landing strips or helipads m airstrips must be accessible to vehicles, therefore mostly m

na na

u u

i i

o Contractor utlizes only public-use airports with hard

g g

obab with poor dust abatement and/or poor r r X

m utilizing developed airports (may use unimproved landing

ed ed

a a

e surfaced runways and ramp areas.

M M surface condition M strip only in event of emergency). M

Biological Window Contractor provides extra pilots/aircraft to exceed the

Contract specifications include adequate number of production rates thus limiting the pressure to push flight

m m

u u

onal

i i

Prioritizing treatment timing based on pest oph aircraft to accomplish mission within biological window, o

g hours/duty times. Flight hours/duty day times are monitored

tr i X

ed ed

phenology above safety brief daily emphasizing safety over production, adhere to e for each pilot and are discussed daily so pilots can manage

M M

cc t

a O flight and duty limitations their loads to remain within the duty limitations.

Airspace

c c

i i

Contact flight service station or ATC to determine if active

o Working within Military Operating Area, oph and, if so, may request traffic advisories from the oph No MOAs within operating areas in 2019; government

ous

tr tr X

s s

obab

e potential mid air collision controlling agency prior to entry; address during e personnel coordinate with military to deconflict MTRs

a a

t t

P a premission planning and briefing a

C C

Address during permission planning and briefing; keep alert (application aircraft and observation aircraft);

c c

i i

Government pre-clears all missions that intersect MTRs with e contact flight service station to determine if active and, if

Working within or proximity to Military t

oph oph

ous appropriate contacts in AP1B; maps posted in mobile office ous

g so, request times of scheduled activity, altitudes in use,

i i

r r

m Training Route, potential mid air collision tr tr X

obab

s s

e e

r showing MTRs with appropriate buffers overlaid on treatment

a actual route width ; not all MTRs are published on a S S

t t

a a blocks.

C sectionals... obtain copy of AP1B for phone numbers to C military installations and contact schedulers to deconflict MTR

c c

i i

Unable to establish TFR for oph Post applications projects as NOTAM, remain aware of oph Observation aircraft constantly monitor the area for other

ous ous

i i

tr tr X

r r

s s

obab

e applications projects potential for other aircraft to enter project area e aircraft traffic and advise/warn application pilots e

r a a

S S

t t

a a

C C

c c

i i

COR/Project Manager & National Airspace Coordinator to

onal

Military training operations distracting oph oph communicate "training" problem to military, describe o

ous ous

i i

tr tr X

r r

s s

e application aircraft distraction to application operations and risk e e

a a

S S

t t

a a

C C

Pre Mitigation Post Mitigation

Not Not

e e

y y

ion

t t

ble

n n

m m

i i

r r

o o

io io

eved eved

hood hood

t t

Sub-system Hazard c Mitigation c Additional Local Mitigation

a a

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c c

eve eve

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A t A t

ikeli ikeli

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Appli

L L

Mi Mi

P Go to FAA.gov to identify contact and follow procedures

for filing NOTAMs... post aerial application NOTAM

within 3 days of project (also retrieve NOTAMs for your

c area ; call 1-800-WX- BRIEF, request to be transferred to c

i i

Inability to post NOTAMs due to FAA t

onal the NOTAM Desk, inform them that 1) you are the

o i Observation pilots are responsible for checking NOTAMS and

oph oph

ous

s i

office closures and difficulty identifying tr tr a X

Hi responsible party, 2) give your phone number and that of

s s e

e e DROTAMS prior to daily operations.

cc a a

contact point t t O your communications base, 3) give operational details

a a C (location, date/timing, duration of work); problems in C filing should be elevated your safety manager and FAA superiors

Typically avoid, however, Project Manager may request

permission to work within FTA or TFR if possible and

e e

s m m

t t

u u

i i Working in proximity to/or within FTA or o oph absolutely necessary, coordination between dispatch, o

i X

m m

ed ed

e e TFR e application pilot, and aerial supervision is required;

R R

M M

C ability to "XM download" to on board GPS will help with TFRs.

Typically avoid, however, if necessary permission to enter

e e

t t

Restricted Areas (artillery firing, guided o o None of the spray activities will require flight in restricted oph may be coordinated through ATC; know intercept

ous

i X

m m

s r

e e missiles or aerial gunnery) e procedures, reference in contracts/prework and include in areas.

R R

daily briefings.

Prohibited Areas (e.g.. lack of coordination

e e

t t

For all intents and purposes "permanently off limits" - try i prior to entering Camp David, White o oph o

ous

i t No spray activities in prohibited areas in 2019

i X

m m

e e House, Presidential Ranch…) e to avoid.

R R

Contractor aircraft all have a minimum of dual coms to

c c

i i

e Observation and application aircraft remain aware of e facilitate communications with local airports, regardless of the

t t

Mid Air collision while working within or o o

oph oph

ous ous ous

i i i

tr other traffic, pilot request clearance, maintain tr X

m m airspace type. Both application and communications/safety

r r r

s s

e e crossing Class B, C, D Airspace e e e

a a

S S S

R R t communication with ATC or tower as required t pilots are high time facilitating the ability to communicate

a a

C C effectively while flying.

c c

i i

Communicate with & utilize observation aircraft, ATC,

e Columbus, OH area - meet with tower personnel at Port

onal

Airspace in general - near miss/collision in oph oph etc... see and avoid, consider TCAS to warn of o

ous ous

i i

tr tr X Columbus Int. and OSU airport prior to treatment to

r r

s s

e congested areas transponding aircraft in proximity to application aircraft e e

a a

S S

R cc t t coordinate communications during project activities

a a

C C

Airstrip

Contractor delineates non-congested areas for off site landings

Availability, m m

u u

i i

o No alternative or suitable landing oph Identify emergency landing zones in advance (fields, in every congested area. Google earth photos with these

tr Condition and i X

ed ed

s r

obab location for emergency situations open areas, meadows) e delineations highlighted are provided to each pilot.

M M

Services P

m m Contractor communicates fuel needs to FBO well in advance of

u u

onal

i Call FBO/airport ahead of time to determine fuel i

No alternative fuel source r

i X project and checks again several days before arriving for work.

ed ed

availability, use alternate airport or fuel tender e

M M

e e

l l Be aware that preferred approach/departure based on

w w

ous

li One-way landing/departure r wind may not be an option, be aware of the potential for X

Lo Lo

obab obab

r r

P oncoming air traffic P

Pre Mitigation Post Mitigation

Not Not

e e

y y

ion

t t

ble

n n

m m

i i

r r

o o

io io

eved eved

hood hood

t t

Sub-system Hazard c Mitigation c Additional Local Mitigation

a a

hi hi

c c

eve eve

ut ut

ig ig

S S

A t A t

ikeli ikeli

O O

Appli

L L

Mi Mi

l l

m Use vegetation (grass, tree tops) as reference; if

na n

i i

o Contractor utilizes only public-use airports with hard surfaced

ous

g g

No windsock at landing zones r available, ground support can call pilot with conditions r X

a a

equent

e e runways and ramp areas as well as windsocks.

M M

F prior to landing, hang flagging

m Contract aircraft all have Garmin 496's with AWOS weather

ous

Effects of prevailing wind i Know local conditions, retrieve automated weather

li r X data so the pilot can monitor all weather conditions.

equent equent

r r

F F

N Terrain/ Contract specifications require FAA part 137-qualified

Obstructions Operations below 500' in either

pilots. Maintain situational awareness, identify emergency

helicopter or fixed-wing, potential to m Contractor requires a minimum of 5000 hours of flight time m

u u

i i

oph o

g landing zones (fields, open areas, meadows); preflight

tr and 2500 hours of aerial application time for all application impact terrain or obstruction - aerial i X

ed ed

equent briefing, review aerial hazard map, contract specifies e

r C

M M

application typically 50-200 feet above F pilots. a reconnaissance of area prior to treatment tree tops C

Animal activity

l l

s Know flyways, observation aircraft and ground support m m

a a

u u

onal c c

Potential for serious injury/aircraft damage i i

i i i

t t s to communicate avian activity if present in area

i i X

ed ed

r r

e from birds e

C C

M M

l Potential for serious injury/aircraft

s Ground support to clear runway, communicate activity m m

u u

onal c

i i damage from wildlife on runway o

i i

to pilot; keep deer away by scattering "Irish Spring" soap r

i X

ed ed

e (common at remote and county airports) e

M M

cc around runway perimeter M

Containment &

l Handling

m Contractor is required to have spill plan, contract requires

w w

No spill plan for fuel & chemicals, no i

obab

r spill plan, follow pesticide label regarding PPE li X

Lo Lo

label and SDS for pesticide, no PPE e

Agency and state contracts require that all tanks and Contractor disruptant dispersal systems are specific to the

Insufficient cleaning of tanks and delivery pesticide delivery systems must be thoroughly cleaned product they are designed to carry, thus cross contamination

nal

um um

ote cal

i i

obab r components between projects, when m i and free of rust, residues, and particulate matter, such as X of chemicals cannot occur. All dispersal systems are cleaned

ed ed

M M changing chemicals (env. hazard) M grit and sand and will inspect all tanks before they are m prior to the contract and cleaned daily during operations.

I filled with insecticide or water.

l Treatment areas are posted on public lands only (not

m No human healt hazards associated with mating disruptants

w w

Human exposure due to treatment i o necessary for private landowners requesting treatment),

obab r li X that contain the gypsy moth pheromone as the active

Lo Lo

areas not posted e roads may be closed on public lands at discretion of site

M ingredient.

manager Im

System - Personnel (FHP Aerial Application) Pilot and/or vendor

nal

Minimal local experience/unfamiliar with oph Preflight briefing, review aerial hazard maps, conduct Contractor is generally familiar with all the project areas

ous

r X

equent equent area reconnaissance flights e because of work history (1998 to 2017)

Fr Fr

atast

Pre Mitigation Post Mitigation

Not Not

e e

y y

ion

t t

ble

n n

m m

i i

r r

o o

io io

eved eved

hood hood

t t

Sub-system Hazard c Mitigation c Additional Local Mitigation

a a

hi hi

c c

eve eve

ut ut

ig ig

S S

A t A t

ikeli ikeli

O O

Appli

L L

Mi Mi

Contracts require current State Applicator License… obtain

nal

ote Prior to starting work in each state, state applicator licenses for

obab No current State Applicator License r

li m certification within all states where project is planned, be X

Low

a e pilots and ground support are checked.

aware that project may cross state lines N

Contract specifies number of hours by mission type

i Contractor requires a minimum of 5000 hours of flight time

(number of hours in typical terrain, number of hours in m

nal

um u

onal ote i i oph and 2500 hours aerial application time. The firm works to

Minimal flight hours/mission hours r make/model), check flight log files & be aware possibility m X

a e build a culture of safety allowing each pilot to fly within their

atast exists for these to be falsified/unable to verify

Occas

C personnal minimums.

Agency and state contracts provide aerial hazard maps of

c c

i i

known hazards, some states will GPS hazards prior to

Inordinate attention to application, This remains a serious concern because new hazards (e.g.

onal ote oph project implementation, contract requires "all application oph

ous

r r

impacting aerial hazards (new hazards m X met towers) can pop up overnight and can be difficult to see r

e pilots are responsible and required for the reconnaissance e

R installed often, e.g. cell towers) from the air during recon flights. S

atast atast

Occas C of each area before treatment" C

Contractor pilots require a minimum of 5000 hours of flight

c c

i i

time and 2500 hours aerial application time. The firm works m

nal

o Not all pilots equally skilled, do not pressure into ote i

oph oph

ous

r r Coerced into uncomfortable situation i m X r to build a culture of safety allowing each pilot to fly within

e uncomfortable situations (encourage all to speak up) e

atast atast their personnal minimums. Program manager/COR does not

Occas

C C

push for performance.

nal

onal cal ote i

Inadequate briefings from Project Manager Address in work plan; contract requirement to hold i Daily briefings and work planning session conducted in

i i

ous

i m X

e e preseason, premission/daily, postmission briefings conjunction with contractor and state

Occas

Contractor aircraft all have single point fueling to ensure

propert amounts are loaded and a shadin fuel flow/totalizer to

c c

i i

maintain accurate awareness of fuel remaining in both time

ote

Lack of awareness leading to fuel onal Proper preflight planning, Project Manager & pilot

oph oph

ous

i and quantity. Prior to take-off for each load, the fueler and

r r

m r X

e starvation monitor flight time e

S R pilot check concurence of aircraft fuel added by comparing the

atast atast

Occas C C loader meter with the pilot's on board meter. Initial radio contact with base after take-off confirms fuel on board

i All project personnel to be aware of illness (may be colds

cal i

onal ote

i oph to serious health issue), ask if medicated, know FAA regs

r Self-medication t

i m X

ed for use of over-the-counter and prescription drugs while e

atast

Occas

C operating equipment

um u

i i

onal ote cal

oph

i i

Incomplete preflight inspection Pilot to utilize preflight check list, FAA requirement t m i X

r ed

atast

Occas

onal ote cal Accepting unreasonable risk, Preflight briefing to establish tone for the day, "aviation i The contractor's firm has a strong culture of safety;

oph

i i

m i X

r ed "barnstormer" attitude program first, pest management second" e "barnstorming" attitude not tolerated.

atast

Occas

Pre Mitigation Post Mitigation

Not Not

e e

y y

ion

t t

ble

n n

m m

i i

r r

o o

io io

eved eved

hood hood

t t

Sub-system Hazard c Mitigation c Additional Local Mitigation

a a

hi hi

c c

eve eve

ut ut

ig ig

S S

A t A t

ikeli ikeli

O O

Appli

L L

Mi Mi

Contracts specify that pilot may be relieved of duties (in Contractor always has alternate pilots listed and carded so

ote

oph

ous g

Pilot incapacitated obab

m event of sickness, under influence of alcohol or drugs, replacement can be made if required. This lowers the

r X

Low

insufficient rest/time off) N pressure to perform when sick.

atast

Contract specifies duty limitations and rest periods;

m contract specifies contractor not allowed to do other

nal

onal ote i Contractor provides extra aircraft and ground crew to mitigate

oph

Fatigue r projects until completing current agency or state project; m X

a e excessive work requirements.

atast assure enough personnel to support aircraft and project

Occas C schedule

i Contractor works to maintain a positive culture of safety which

m Be aware that experienced pilots may tend toward

onal ote cal i

i oph includes candid discussion each day between all members of

i i

r Complacency t complacency… conduct morning safety briefings, m i X

ed e the team. This helps keep the safety awareness at a high level.

M retain situational awareness throughout day M

atast

Occas

Agency or State

e Contractor application aircraft seat the pilot only so there is

Personnel Exposure to increased risk by boarding Most fixed-wing application aircraft seat pilot only,

nal

um um

cal i i ote no risk of agency personnel boarding the application aircraft.

obab

i unauthorized aircraft (FAA part 137 not m federal and state personnel may not fly in restricted X

ed ed

p Chase aircraft are Part 135 certified for passenger transport if

M M

carded for personnel transport) category (FAA part 137) aircraft m

needed.

Include expert aviation and pest management

l All FS personnel are experienced with this type mission and

cal personnel in project planning, briefing and onal cal i

i i i

ous

t t Minimal experience with mission type s

i i current on training for roles on the project. State personnel r X

r r

obab

r implementation; train and mentor new employees

C C

M P are also experienced with this type mission. (subordinates and supervisors) Occa

Contractor and government safety plans empower each

m Undue pressure upon employees or staff member to come forward with any safety issue.

cal i

onal ote Utilize crew resource management, all are i

oph

i contractor to perform by Program m X Program manager/COR will not exert pressure to perform.

ed empowered to stop an unsafe act e

M Manager/Supervisor M atast "Its just a bug" is the mantra when pressure begins to build.

Occas

State and federal employees never ride in application

aircraft under FAA part 137 but may in observation aircraft Although chase aircraft are Part 135 certified and FS carded to

nal

w Exposure to risk for personnel if (federal requirements: pilot carding per FAA part 135, i carry passengers, the project rarely if ever loads a passenger

ous g

r X

equent equent participating in observation flight e in these aircraft. Field personnel, AFF and DGPS downlads are

monitoring personnel on board must be qualified Fixed- eg

Fr Fr wing Flight Manager or Helicopter Manager); consider N used to monitor operations.

utilizing AFF to monitor operation

Outline project schedule within the RFP, proposals to address how intended to meet production

requirements/assure adequte rest, recommend RFP Flight hours/duty times for pilots is closely monitored and

m enforced. Government personnel follow the same schedule

provide vendor weekly opportunity to specify changes to nal

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Hi obab state or ageny for review; Positive safety culture will a ed

atast encourage adequate rest for all, appropriate number of per day with a mandatory rest day on the 7th day of

C aircraft assigned to project; Responsibility of Project operations. Manager to ensure adequate rest for all personnel (crew

resource management)

Pre Mitigation Post Mitigation

Not Not

e e

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M Occas resource management)

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i Consider including in contract specs that all

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pilots and pilot operators that help m m

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i Consistent with the goals of the Aerial Application Safety

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l Notify Dispatch of planned activities and provide Project

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plan and utilize a combination of communication m

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Lack of staffing on weekends or outside of Brief dispatch on operational periods, ensure i Project personnel conduct flight following on site at mobile

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flight hours dispatcher staffing or flight following personnel e bases.

l Circulate flight plan to all dispatch centers in project

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c Coordination in

Lack of mission understanding among l related meetings, industry and user group events to

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i RAOs/RASMs, FAOs, state directors, etc… liaison/promote safety and efficiency; have current unit m X

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l include all agency funded aerial application projects (e.g.,

um u

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onal ote cal coordination on aerial application projects oph

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Contracting CO has previous contrract experience with pest suppression

CO, COR/COTR turnover leading to lack of i Include expert aviation and pest management personnel

contracts, contract specs were reviewed and approved by FS

onal cal i

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gh aviation staff; COR is an expert in pest management with 10+

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ed personnel performing oversight administration; train and mentor new employees (future e C years experience; Overlap of previous COR and current COR

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Short time frame from contract advertising

to implementation (impacts operating Begin drafting contract early enough to ensure that a

onal cal

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i season, quality of contract, limits quality contract has been developed, draw highest m X

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m AFF will be utilized in all application and chase aircraft and

ote centers do not have visual display of oph other aircraft that may approach project area, consider oph

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personnel (not everyone uses AFF) and that AFF is not "air m

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ed knows location OR if dispatch thinks all e

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ote cal oph checks/position reports are still required (may be at

m i X

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r at computer greater time interval, 30 minute checks instead of 15 e of AFF.

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r Aircraft monitored on AFF

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State and agency contracts require all observation Contractor observation aircraft all have panel mounted GPS;

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i aircraft have at a minimum handheld GPS and m treatment blocks plotted on FAA sectional maps and

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M "...conveniently located for the pilot" M provided to observation pilots.

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M rather than flying the mission Fr working in similar operations)

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Pre Mitigation Post Mitigation

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P Properly mount antenna, stow handheld GPS and cables

Cockpit clutter/loose equipment in

so as not to interfere with flight or utilize yoke- mounted m

nal nal

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g g

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GPS (if fitted for yoke-mounted GPS and unit is not in use, m X

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a a wires for power and external antenna) e

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M M remove any protruding brackets that may cause injury) M

Occas

Radios FAA radio requirements vary widely (e.g. there may be

no positive radio communication with GA aircraft/there is no blanket FAA requirement, class E & G airspace only

No communications (in general) air-to- m

nal requires radio where there is a control tower at the nal

um um

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r r ground, with other aircraft or dispatch m m X Pre-flight radio checks each day

ed ed

a airport), describe communications needs in prospectus a ed

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M M centers and require through contract, describe in work & safety M plan, list frequencies and how to be used in communications plan, ALWAYS practice see and avoid

e e All contractor aircraft have panel mounted radios within

l l

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i Inaccessible radios/controls, difficult to Break from flight pattern to access radio and make convenient reach of the pilot. All pilots wear helmets with w

obab obab

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r r operate a adjustments p p speakers and boom mikes with push to talk buttons on the

m m

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o oph oph

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collision e CRM aircraft traffic and advise/warn application pilots

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e If using TCAS: false sense of security that Recognize that all other aircraft may not have functioning

onal

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tr all other aircraft have functioning tr transponders, continue practice of "see and avoid", apply X

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t transponders t CRM

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If using TCAS: Signal interference, s

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e System Emergency dump valve malfunction m

nal nal

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i i i onal Inspect and assure functioning dump valves for helicopter ot

g g

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causing load to dump (misapplication of m X

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M M pesticide) M

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i i i Hose to nozzle detaching, pesticide onal Preflight inspection to include examining pesticide ote

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M M

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Pre Mitigation Post Mitigation

Not Not

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n n

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Sub-system Hazard c Mitigation c Additional Local Mitigation

a a

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A t A t

ikeli ikeli

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P Maximum load for the aircraft (400-500 gallons liquid or

c c

i i 3600-4500 lbs) far exceeds the load the disruptant hoppers

Inability to jettison in event of emergency ote Inspect and assure functioning dump valves for helicopter ote i oph oph can carry (450 lbs); thus the aircraft will never approach its

ous ous

r r

i i

m m X

r r

e e e & fixed-wing e maximum carrying capacity on this project which mitigates

S S

R R

atast atast

C C the need to dump in the event of an emergency.

Contractor application aircraft are calibrated multiple times

Agency and state contracts specify all aircraft must be

each season. Each load provides an additional calibration by

nal nal

um um

i i

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onal i equipped with an electronic flow metering system and i

g g

Improper pesticide application rate r r m X comparing the product loaded with the SATLOC acres applied.

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a a delivery system must be calibrated prior to project e

M M

ccas M M Each pilot has the skills to adjust that calibration between O implementation

loads as required.

JOB HAZARD ANALYSIS

U.S. Department of Agriculture 1. WORK PROJECT/ACTIVITY 2. LOCATION 3. UNIT Forest Service FIXED-WING AIRCRAFT SAFETY NC, VA, IN, WI, IA, OH R-8/R-9 JOB HAZARD ANALYSIS (JHA) 4. NAME OF ANALYST 5. JOB TITLE 6. DATE PREPARED References-FSH 6709.11 and -12 (Instructions on Reverse) LAUREL HAAVIK ENTOMOLOGIST March 12, 2019 7. TASKS/PROCEDURES 8. HAZARDS 9. ABATEMENT ACTIONS Engineering Controls * Substitution * Administrative Controls * PPE GROUND OPERATIONS IN SUPPORT LACK OF BE FAMILIAR WITH FSH 6709-11 AND FSH 6709-12 OF THE AERIAL APPLICATION OF KNOWLEDGE OF MATING DISTRUPTION ON PRIVATE, FSH 6709-11 AND FEDERAL, STATE LANDS 6709-12 REGULATIONS

* NOISE FROM WEARING HEARING PROTECTION. REQUIRED FOR AIRCRAFT PILOT AND GROUND PERSONNEL ENGINES AND PUMPS * PROPELLERS IN USE EXTREME CAUTION. RESTRICT ACCESS TO MOTION AUTHORIZED PERSONNEL ONLY. DO NOT APPROACH AIRCRAFT UNTIL PROPELLER IS STOPPED. ASSURE PILOT RECOGNITION BEFORE APPROACHING AIRCRAFT.

* EYE NJURIES WEAR GOGGLES

* * * SMOKING AND SMOKING IS NOT PERMITTED WITHIN 100 FEET OF OPEN FLAME AIRCRAFT OR FUEL PUMP. USE CAUTION AROUND FUEL. NO OPEN FLAMES

* EYE INJURY HAVE PERMANENT OR PORTABLE EYEWASH FROM DUST AND FACILITIES AVAILABLE ON SITE. DEBRIS FROM AIRCRAFT ROTORS

OPERATIONS

This document includes information on project location, administrative organization and responsibilities, pre-spray and spray activities, monitoring activities, public notification and information, and safety and security guidelines.

The aircraft and pilots to be used for application will be supplied by the contractor. The aircraft and pilots to be used for chase will also be supplied by the contractor except in the state of Wisconsin, where WI DNR will provide observation aircraft and pilots. The contractor also provides ground support services that include transporting, mixing, and loading of the insecticides and fueling of aircraft. Operations will be consistent with the specifications in Contract No. AG-56A1-C-17-0002.

The USDA Forest Service (FS), 626 E Wisconsin Ave, Suite 300, Milwaukee, WI 53202 will have overall responsibility for administering the contract. Primary direction and coordination of the project on private, state, and federal lands will come through the state agencies in IN, OH, IA, and WI. Technical support will be provided by USDA-FS personnel located at Asheville, NC; Morgantown, WV; and St. Paul, MN. The agency proposing treatment under the 2017 contract will be responsible for all administrative services related to their project area and personnel. The FS, through designated Contracting Officer's Representative(s) (COR), will oversee the contract implementation in each project area.

Roles & Responsibilities Government staffing for the project will involve USDA- FS, and State agency personnel. Ground crews necessary to close roads, provide treatment information in agency designated areas, monitor weather conditions, and provide flight following information from the treatment blocks will be provided by each state agency for designated treatment blocks. Duties and responsibilities of project personnel are outlined below. Staffing for this project may include two or more Forest Service persons fulfilling the duties of the following positions:

Contracting Officer (CO) - The Contracting Officer has overall responsibility for the contract.

Contracting Officer's Representative (COR) & Project Aviation Manager - The person acting in this dual capacity will have overall responsibility (ground and air) for conducting the entire project and assisting the contracting officer to ensure that the contractor complies with all contract specifications. This individual plans, organizes, and manages the aviation operations. This person also ensures that the directives outlined in the Project Aviation Safety Plan as well as governing articles found in Forest Service Manual (FSM) 6700 and Forest Service Handbook (FSH) 6709.11 (Health and Safety Code Handbook) are followed. This person will periodically inspect project operations to check compliance with the Safety Plan and be available to the investigation team following any accidents. The COR will also be responsible for base operations that involve communications (ground to air/ground to ground); media; and keeping the Daily Diary (as required by FS policy). It is extremely important to log in all communication checks, events daily by time, phone-radio calls, any actions taken, etc. into the daily log. The COR or Designee is also responsible for conducting daily briefings, assignments, safety briefings, and coordinating the next day’s events with the contractor. The COR also serves as Project Supervisor.

Contract Inspectors – These individuals assist the COR and Project Aviation Manager. They monitor contract performance (track loads and review DGPS files to confirm accurate application on each treatment block), perform flight following, track pilot flight hours / duty times, monitor weather, coordinate with the military to de-conflict

MTRs and MOAs, act as safety officer(s) and perform other duties as needed during contract implementation.

Forest Dispatch – National Forest dispatch offices will be briefed on the project, provided a copy of this plan and called for assistance in the event of an aviation mishap or accident.

Aviation Management, Assistance, Support, and Responsibilities within the Southern Region, Eastern Region, and Northeastern Area The land mass covered by this massive project includes three organizations within the Forest Service as well as many States in the eastern United States. This requires a coordinated effort and understanding in regard to who is responsible at any given time during the progress of the project. The following sections identify the specific geographic areas, aviation managers, and their duties regarding the support to this project.

Southern Region (Region 8) Regional Aviation Officer (RAO) – The RAO provides the project manager with necessary technical and operational support within their authority, to ensure successful mission accomplishment that is within established policies and guidelines.

Regional Aviation Safety Manager (RASM) - The RASM is responsible for providing safety support and recommendations to help ensure a mishap free operation. The RASM will ensure prompt follow-up on all SafeCom reports as well as assisting with initiation of actions associated with emergency mishap response, including mishap investigation support when a mishap occurs in any Southern Regional State Cooperator lands or national forest lands within the Southern Region.

Eastern Region (Region 9) Regional Aviation Officer (RAO) – The RAO provides the project manager with necessary technical and operational support within their authority, to ensure successful mission accomplishment that is within established policies and guidelines.

Regional Aviation Safety Manager (RASM) - The RASM is responsible for providing safety support and recommendations to help ensure a mishap free operation. The RASM will ensure prompt follow-up on all SafeCom reports as well as assisting with initiation of actions associated with emergency mishap response, including mishap investigation support when a mishap occurs on national forest lands within the Eastern Region.

If an aircraft mishap or fatal accident occurs, the COR will notify the appropriate Forest Service Aviation Safety Officer, the nearest National Transportation Safety Board (NTSB) field office, the nearest Federal Aviation Administration (FAA) Office, and nearest airport where there is a Fixed Base Operator on site, as soon as possible.

Aircraft & Pilot Inspector - These Inspectors will be responsible for assuring that the contractor's equipment, and personnel meet the specifications of the contract prior to performance and for issuing cards.

State Cooperators - The State Cooperators will serve as Ground Operations Supervisor. They will be responsible for gathering and recording weather measurements from the ground crews, obtaining weather forecasts from the National Weather Service, and relaying weather information to the Project Director. This person will also supervise the area closures, spray block delineation, and inform the local media of closures, times, and dates for treatment areas as well as making determinations of need for an aerial observer. 43

Aerial Observers (AO) – States are allowed to put an aerial observer in the Communications/Safety aircraft. Although aerial observers are rarely utilized, they may assist the COR in maintaining records on application, swath overlap, application pilot performance and pilot/aircraft flight time. If needed, they will assist in search and rescue operations. They will also function as aerial airspace observers watching for other aircraft traffic in the airspace to the blocks, over spray blocks, and return to base.

Block Monitors – Block monitors will assist in environmental monitoring, closure of spray areas, communications and other tasks as assigned.

2019 Organization Chart

Contracting Officer Melissa Johnson

Contracting Officer's Representative (COR) & Project Aviation Manager Tom Coleman

Contract Inspectors FS Aviation L. Haavik, A. Hill, D. Leonard R8 RAO - Jerry Perry R8 RASM - Jimmy Keyes R9 RAO - Bob Madill State Cooperators R9 RASM - George (Nick) Hough NC - C. Elder

VA - L. Bradfield

OH - D. Adkins IN - P. Marshall R9 Aircraft & Pilot Inspectors WI - C. Foelker IA - T. Feeley

Forest Dispatch Block Monitors & Aerial Observers

Contractor Al's Aerial Spraying Al Schiffer

Pilots

Ground Crew

Equipment and Pesticides Contractor: Al’s Aerial Spraying, LLC (Ovid, MI) Aircraft - Fixed-wing, turbine powered Air Tractors will be the application aircraft for this project. One observation aircraft (used for communications and safety), Cessna 182 or 172, may follow one or more application aircraft in a project area.

Ground Vehicles – Crew vehicles, mobile bases, fuel trucks and semi-trailers for pesticide storage, spare parts and cleaning supplies will be supplied by the contractor.

Pesticides – Controlled release formulations containing the gypsy moth pheromone are the pesticides to be used on this project. SPLAT-GMO® (ISCA Technologies, Riverside, CA) is a biodegradable amorphouse polymer matrix formulation that releases the pheromone over a period of 11 weeks or longer. It is 13% active ingredient by weight; the remaining ingredients consist of waxes, water, emulsifiers, oils, and preservatives. The Contractor will treat each block with a single application of SPLAT-GMO and is responsible for transportation, storage, handling and loading of pesticides.

Pod Dispersal System – SPLAT-GMO requires a custom dispersal system, which are pods suspended under the wings. An FAA Supplemental Type Certificate is required to mount and use this equipment on an aircraft. The pods can be calibrated to dispense both products at the 30.4, 15.2, and 6 grams active ingredient (ai) per acre dose.

Aircraft Calibration The application aircraft will be calibrated to deliver the 6, 15.2 and 30.4 g ai/ac doses prior to commencement of treatment. Aircraft may be characterized at the discretion of the COR.

Safety Briefing Schedule Pre-spray safety meeting- The Project Aviation Safety and Management Plan will be made available online for all cooperators to download and distribute to project personnel. Hard copies will also be made available at each of the designated Fixed Wing Bases. The COR will conduct a pre-spray safety meeting for all project personnel in advance of treatment activities for each state to: 1) establish lines of communication; authority; responsibilities; and 2) emergency notification procedures (i.e., identify personnel allergies, hospital locations, Medi-vac service for project area, security measures etc.). The state cooperator will be responsible for 1) providing hazard maps (with aerial hazards identified and available for viewing at base operations), 2) briefing the contractor of hazards associated with the treatment blocks in their project area, 3) assigning ground personnel to each treatment block, and 4) providing a working communication plan.

Daily updates- Before daily operations begin, contractor and base of operations personnel will be briefed on safety procedures and proposed work schedule by the COR. At the end of the daily operations, tailgate safety sessions will be incorporated into the planning session for the next days work schedule. If field personnel cannot be available for these briefings, it is the responsibility of the agency representative attending the briefing to pass this information to those unable to attend.

Security Measures- Before daily operations begin and at the conclusion of operations, equipment, product, and base security procedures will be enforced.

Hazard Analysis- Military flight routes and other safety concerns will be reviewed prior to the spraying of each treatment block: (1) maps showing each treatment block and any hazards associated with spraying of the block (i.e., KV lines, towers, etc) and reviewed by the COR and contractor, (2) an overlay of military flight routes associated with each treatment block will be available at base operations (3) daily check-in by COR or inspector to inform military of spray activities (i.e., locations of treatment blocks, altitude of spray aircraft, and type of aircraft being used) and (4) daily briefing by COR to update contractor on military flight routes. Calls made daily to de-conflict airspace will be recorded in the daily log including the phone number and name of the military contact.

Project Communications Communication between ground personnel will be primarily through the use of cellular telephones with a limited number of satellite telephones available for use in poor cell coverage areas like northern MN. Ground crews in the treatment blocks will be supplied with handheld radios programmed to the project frequency for communication with the observation / communication aircraft during operations.

All aircraft and the base(s) of operations will be equipped with 720 channel VHF-AM aeronautical radios. No flights will be made without functioning radio communications. The application aircraft and observation aircraft will maintain air to air communications and the observation aircraft will maintain communication with base of operation and, in some instances, with ground personnel in the treatment blocks.

Flight Following - Satellite based aircraft tracking hardware for automated flight following (AFF) is required on all aircraft (See Contract, Exhibit 11) and will be monitored by project personnel at the base of operation. Although AFF will be utilized, the primary method of flight following will continue to be radio check-ins at 15-minute intervals when the observation aircraft will report the location and status of the application aircraft.

Insecticide Transportation and Storage The Contractor will be responsible for the storage, transportation, loading and safety of the mating disruption products. Pesticide containers will be secured in the truck bed to prevent tipping or excessive jarring during transit. Vehicles transporting insecticides will not be left unattended at any point along the route of travel unless insecticide containers are in a locked compartment. Any left over insecticide will be returned to the locked storage area at the end of the day. Insecticides will not be left unattended at the work site.

The contractor is responsible for containing and cleaning up any insecticide or sticker spill according to their approved spill response plan. The spill material will be contained and disposed of according to Federal and State laws and regulation.

The contractor is responsible for proper disposal or recycling of all empty insecticide and sticker containers according to label requirements, State laws and regulations.

Mixing and Loading Insecticide Loading is done directly into the application aircraft and involves only contractor personnel who are properly licensed and certified. The Forest Service personnel along with state cooperators will provide assistance in determining exact amounts of the insecticide needed. Handling, storage, and disposal instructions appearing on product label will be strictly followed. Also, see FSH 2109.12 "Pesticide Storage, Transportation, Spills, and Disposal Handbook."

Ground Vehicles The operator of any Forest Service vehicle is responsible for the safe maintenance and operation of that vehicle. All operators of Forest Service vehicles must have a valid State operator's license and a Forest Service operator's license and must be familiar with FSH 7109.18 (Driver-Operator Handbook). They will observe all State, local, and Forest Service driving regulations. On the fixed-wing base ground vehicles will be limited only to those necessary to the operation being carried out.

Aircraft Fueling Operations Aircraft fueling will be conducted by contractor personnel only and will be done in compliance with contract specifications (Exhibit 9 – Fuel Servicing Specifications). Government personnel will remain at least 50 feet away from any aircraft during fueling.

Air Operations Fixed-wing aircraft will be used for application and observation (communication/safety). Most phases of the project having to do with aircraft and air operations will be conducted by personnel under Government contract. All personnel involved in air operations must be knowledgeable of hazards associated with air operations and be prepared to exercise necessary caution (see FSM 5700 "Aviation Management").

Although there is more risk involved in air operations activities, most accidents involving aircraft are the result of human error and are usually preventable. Most serious accidents can be avoided by carefully adhering to this aircraft safety plan and practicing good safety attitudes and habits.

A SafeCom (www.safecom.gov) will be used to report any conditions, observances, act, maintenance problem, or circumstance, which has a potential to cause an aviation-related mishap. All accidents and serious injuries will be reported to the COR. Accidents involving aircraft will be reported to either the R8 Regional Aviation Safety Manager, R9 Regional Aviation Safety Manager, or the Northeastern Area Aviation Officer, depending upon the location and jurisdiction of the accident. SafeComs can be reported or initiated by anyone.

Application Constraints Operations will usually be prohibited when any one of the following conditions exists within the treatment area: (Insecticide label restrictions will take precedence over the conditions listed below when label restrictions are more limiting).

 If wind conditions exist or occur during treatments that is determined by the COR to adversely affect deposit, it is at the discretion of the COR to stop spray operations.  During rainy or foggy weather, or when the foliage is wet, or when there is an imminent threat of rain.  When air turbulence (thermal updrafts, etc.) is so great as to seriously affect deposit.  To avoid treatment in unspecified areas, application will be terminated if the DGPS is not working properly and the application aircraft must return to the airport.  Flight operations will be conducted in DAY/ VFR conditions only.

These conditions will be monitored by the communication/safety aircraft and/or ground personnel in the treatment blocks.

Air speed will be determined at the time of calibration and must stay within allowable air speed limits of the aircraft. Application heights will range between 100-200 feet above tree tops, depending on terrain. Effective swath width for the aircraft will be determined at the time of characterization and calibration.

Monitoring To assure proper application of the mating disruptants, the contractor will be required to have Differential Global Positioning System (DGPS) in the application aircraft. These flight log files will be downloaded daily to insure adequate coverage of the treatment blocks was achieved.

Weather measurements including wind speed will be taken at the proposed treatment area by ground personnel. On site computers and airport weather resources will be used to access local weather maps for current weather conditions. Weather information provided by the pilots will also be used to determine project operations.

Public Notification Public notification regarding aerial treatments will be the responsibility of each participating state agency.

2019 Project Areas and Airports Designated as Bases

Location, acreage, and estimated start date for each project area

Estimate of Project Areas Polygon Acres # Blocks Estimated Start Date Treatable Acres VA Study Plots 1,000 1,000 8 6/7 Virginia & North Carolina Piedmont 6,538 6,225 6 6/5 Southern Ohio 72,132 57,730 12 6/14 Virginia Mountains 92,886 91,572 12 6/21 Northern Ohio & Indiana 19,774 6,340 5 6/18 Southern Wisconsin & Iowa 32,367 25,210 6 6/28 Central Wisconsin 41,523 32,600 4 7/10

Northern Wisconsin 30,161 28,100 2 7/15 Subtotal 296,381 248,777 55

The following airports are designated for each project area will serve as the Fixed Wing Base and project headquarters prior to and during the operational phase of the project. A/P Project Area Airport Address Contact Phone # ID

Danville 424 Airport Drive NC Piedmont DAN Marc Adelman 434-799-5110 Regional Airport Danville, VA 24540

Mountains VA/NC Mountain 8223 Lee Highway MKJ Brian Burkett 276-783-8805 & Study Plots Empire Airport Rural Retreat, VA 24368 Zanesville 840 Airport Rd, Central Ohio Municipal ZZV Jim Witte 740-452-3625 Zanesville, OH 43701 Airport 3430 Old Columbus Rd Fairfield County Pat Rooney Southern Ohio LHQ Carroll, OH 43112 740-654-7001 Airport Lonnie Watts Putnam County 10218 County Rd 5H Northern Ohio KWX Kent Niese 419-523-3910 Airport Ottawa, OH 45875 1255 E Airport Rd Illinois Albertus Airport FEP Darrell Janssen 815-232-1078 Freeport, IL 61032 1006 Wisconsin Avenue Southern WI/Iowa Boscobel Airport OVS Steve Wetter 608-375-5232 Boscobel, WI 53805 Prairie Du Chien 37735 US-18 Richard Iowa Municipal PDC 608-326-2118 Prairie du Chien, WI 53821 Yeomans Airport La Crosse 2850 Airport Dr Central WI LSE Clint Torp 608-789-7456 Regional Airport La Crosse, WI 54603 Chippewa Valley 3800 Starr Ave., Suite 1 Central WI EAU Charity Zich 715-839-4900 Regional Airport Eau Claire, WI 54703 Solon Springs 12285 S US Hwy 53 North central WI Municipal OLG Neil Mathison 218-348-3176 Solon Springs, WI 54873 Airport 715-349-2181 Burnett County 7410 Co Rd K Northern WI RZN Nathan Ehalt After hrs: 715- Airport Siren, WI 54872 222-1702

OPERATIONS PERSONNEL

State Name E-Mail Address Office # Cell # Home # State Cooperators VA Larry Bradfield [email protected] 540.394.2507 540.392.1556 David Gianino [email protected] 804.786.3515 804-495-5838 Brandon Turner [email protected] 540.394.2507 540.739-4736 Mary Simms [email protected] 540.228.5501 276.613.1383 Wendy Robertson [email protected] 540.228.5501 434.841.4692 Brian Kreowski [email protected] 540.228.5501 276.229.1313 Ed Burlett [email protected] 276.228.5501 276.613.1384 Ben Templeton [email protected] 276.228.5501 276.690.0841 Cindy Hubbard [email protected] 757.562.6637 804.221.3063 Jessica Driver [email protected] 276.628.6261 434.710.1945 Mohamed Abdella [email protected] 757.363.3902 757.477.6528 Gina Goodwyn [email protected] 757.562.6637 757.334.0042 Tina MacIntyre [email protected] 757.562.6637 804.564.9696 Angela Barnes [email protected] 757.387.7416 757.387.7416 Nolan Hudson [email protected] 757.859.6590 434.774.9092 W614.282.9867 David Adkins [email protected] 614.387.0907 740.869.3150 OH P614.404.6388 Brian Burke [email protected] 614.995.1487 614.271.7748 614.995.1487 515-669-1402 IA Tivon Feeley [email protected] 515.725.8453 Mike Kintner [email protected] 515-725-1470 515-745-2877 Robin Pruisner [email protected] 515-725-1470 515-231-4481 Nick Groves [email protected] 515-725-1470 515-306-0746 Todd Voss [email protected] 515-725-1470 515-306-0895 Lane Kozel [email protected] 515-725-1468 515-306-0920 IN Kallie Bontrager [email protected] ------219-851-1836 574-876-5983 Lauren (Ren) Hall [email protected] 317-234-0187 463-202-4168 248-225-9993 Angela Rust [email protected] ------812-549-9291 812-547-6225 Eric Biddinger [email protected] ------574-835-1728 574-223-4211 Phil Marshall [email protected] 812-358-9034 812-595-2740 812-620-2101 Zack Smith [email protected] 317-232-4117 317-437-7088 317-736-7362 Vince Burkle [email protected] ------260-452-8992 260-436-3012 Terry Shafer [email protected] ------765-667-9508 765-384-5244 Kristy Stultz [email protected] ------765-716-0328 765-729-5149 Eric Bitner [email protected] ------812-786-5217 502-264-2986 Megan Abraham [email protected] 317-232-4189 317-605-9468 317-496-8630 Nancy Marshall [email protected] ------765-432-2560 574-753-2477 Ken Cote [email protected] ------812-322-7249 812-331-9026 Jared Spokowsky [email protected] ------317-447-0084 585-250-2775 NC Chris Elder [email protected] 919.707.3743 Whitney Swink [email protected] 919.707.3752 919.612.8970

919.733.2483 x Kevin Carpenter [email protected] 919.218.2531 224 Casey Buddenbaum [email protected] 919.707.3748 704.579.0135 Paul Adams [email protected] 910.604.1276 Mike Massey [email protected] 919-218-8654

State Name E-Mail Address Office # Cell # Home # Derreck Long [email protected] 252-567-1247 Chad Taylor [email protected] 336.466.0478 Ginger Hemmings [email protected] 336.314.9334 Andrew Allen [email protected] 336.404.5873 Heidi Humlicek [email protected] 406.750.6432 April Bauder [email protected] 919.777.3251 Chris Foelker [email protected] 608.224.4581 608.422.1121 608.852.7191 WI Melody Walker [email protected] 608.224.4586 608.516.5487 608.583.4074 Nick Clemens [email protected] 608.224.4585 608.516.7050 608.493.9431 Stephanie Jentz [email protected] 608.294.8321 Bill Bonadurer [email protected] 608.224.4591 608.347.1082 608.738.1139 John Jorgensen [email protected] 608.246.5377 608.219.2841 608.242.0840 Brian Kuhn [email protected] 608.224.4590 608.516.1367 608.231.6723 USFS Forest Health Protection Team USFS Tom Coleman [email protected] 828.257.4399 828.446.5142 859.494.0911 Amy Hill [email protected] 304.285.1565 304.276.8993 John Kyhl [email protected] 651.649.5265 651.366.7706 763.229.8067

Laurel Haavik [email protected] 651.649.5234 479.422.4997 Donna Leonard [email protected] 828.257.4329 828.273.4324 828.684.8796 USFS Regional Aviation Safety Officers R8 Darlene Hall [email protected] 616.723.2741 George (Nick) R9 [email protected] 414.297.1068 414.208.7570 Hough USFS Contracting Staff USFS Melissa Johnson [email protected] 814.728.6241 Contractors Al’s Al Schiffer [email protected] 989.834.5067 517.331.7278 Mike Schiffer [email protected] 989.834.5067 517.331.7810 Schiffer trailer 517.331.7814 Technical Support VT Mannin Dodd [email protected] 540.231.9119 540.239.1640 Ksenia Onufrieva [email protected] 540.250.7428 Denise Dodd [email protected] 540.231.9979 304.558.2212 304.550.3887 WV Timothy L. Brown [email protected]

PROJECT SAFETY REQUIREMENTS & PROJECT SECURITY PLAN

SAFETY Objectives: Safety or actively working to eliminate the risk of injury to all project personnel will be integrated into all phases of aviation operations by minimizing or eliminating hazards and risks. Because of potential risks, there will be extensive inspections of aviation personnel, equipment, and operations. Only trained, qualified personnel will be used to implement aviation operations.

1) Accident Prevention: Accident prevention shall be a continuing part of every operation by all personnel involved including the government contractor and/or cooperator personnel. 2) Employee Responsibility: Each employee has the responsibility to conduct all activities in a safe manner. Each is to ensure that all equipment and work areas are kept free of potential hazards. Help yourself and others by making a conscious effort to anticipate unsafe conditions or situations. Remember that detailed safety procedures are not available for each situation or task, an alert attitude, thoughtful approach, and good common sense are prerequisites for any job. Our goal is to strive for and attain a good safety record.

Policy: No person will engage in Forest Service aviation operations who does not meet the safety requirements set forth in:  This Project Aviation Safety Plan  FSM 5700 (Aviation Management)  FSH 5709.16 (Flight Operations)  Federal Aviation Regulations (FAR)s  State and local laws  Requirements specified in the 2019 Aerial Application of Mating Disruptants Contract AG-56A1-C-17-0002.

Preventative Measures: The following preventative measures will be followed during the project to reduce the probability of an accident or lessen its severity should one occur.

1. Government personnel riding in the Communication/Safety aircraft will be limited to those needed for effective contract implementation.

2. Spectators will be prohibited within 500-1,000 feet of the Operations Area (landing, loading, and fueling areas) unless escorted by project personnel.

3. Smoking will not be permitted within 50 feet of any fueling or loading operations.

4. The operations area for the aircraft will have a first-aid kit, fire extinguisher, and a vehicle equipped with a cellular phone. This vehicle will also serve as an ambulance should the need arise. Ground personnel must be familiar with First Aid and CPR procedures.

5. Use of cellular phones by Contractor ground support personnel working immediately around operating project aircraft creates distraction and is considered an unsafe practice. The area within an aircraft-ground-operational area (airport ramp) where material loading, refueling, or aircraft parking takes place are dangerous areas. Within these high-risk areas involving airplane/helicopter operations, such a distraction can be fatal. The cell phone voice-mail feature will record the message from the sender for the receiver to retrieve when positioned in a safer area away from the ramp and parking area.

6. All equipment located on the airfield that is susceptible to propeller backwash shall be removed or secured.

7. Only those personnel authorized by the COR will be in the Operations Area.

8. Prior to any refueling operations, all aircraft engines will be shut down, and all passengers off-loaded except as authorized in the contract for the spray aircraft.

9. All landing approaches and departure routes will be kept clear of vehicles and personnel.

10. Static grounds are not required for fixed-wing aircraft fueling; however, refueling operations must be "bonded" to aircraft prior to fueling.

11. All personnel involved in any portion of the fixed-wing operations will be familiar with and comply with the direction in FSH 5709.16. All personnel will be provided copies of the 2019 PROJECT AVIATION SAFETY AND MANAGEMENT PLAN and will be briefed at a pre-work meeting on the content of the Plan.

12. Contractor PPE requirements (See Contract, Exhibit 2, pp. 9-10) will be followed

13. The observation aircraft will fly no less than 1000 feet above ground level (AGL). This is a Region 8 standard.

14. The Observation aircraft will maintain a safe separation from the application aircraft at all times, both on the ground and airborne.

15. At the morning briefing, all pilots will discuss how they will maintain both separation and flight path altitude with respect to terrain, weather; review hazards associated with the treatment blocks; and the type of mission for that day.

16. Daily operations will be coordinated with the military to avoid conflicts with military training routes and spraying operations.

17. If aerial spraying is conducted near a private or commercial airport, the airport manager will be notified of the date and time of spraying to coordinate flights of aerial applicators and general commercial aviation users.

PROJECT AND AIRCRAFT MANAGEMENT SECURITY PLAN

Introduction

Purpose Due to the September 11th, 2001 disaster, measures must be taken to insure the public safety and project integrity while implementing aerial treatment contracts. The purpose of this Project Security Plan is to identify potential threats, concerns, situations and problems associated with the aerial spray project and outline procedures doing everything possible to protect the health and welfare of managers, project staff personnel, cooperators, contractor personnel and the public.

Objective The objective of this plan is to provide project personnel with guidelines, sound direction, and established protocol in reacting to a threat or occurrence that places people, equipment, or facilities in harms way. This plan is designed to be concise and easy to use with local information to meet the “immediate” needs of project personnel at a time when a potential- threat or real-life threat occurs.

Standards The National Terrorism Advisory System, or NTAS, replaces the color-coded Homeland Security Advisory System (HSAS). This system will more effectively communicate information about terrorist threats by providing timely, detailed information to the public, government agencies, first responders, airports and other transportation hubs, and the private sector. NTAS Alerts include the following: 1. Imminent Threat Alert- Warns of a credible, specific, and impending terrorist threat against the United States. 2. Elevated Threat Alert- Warns of a credible terrorist threat against the United States. These alerts will include a clear statement that there is an imminent threat or elevated threat. Using available information, the alerts will provide a concise summary of the potential threat, information about actions being taken to ensure public safety, and recommended steps that

individuals, communities, businesses and governments can take to help prevent, mitigate or respond to the threat. The NTAS Alerts will be based on the nature of the threat: in some cases, alerts will be sent directly to law enforcement or affected areas of the private sector, while in others, alerts will be issued more broadly to the American people through both official and media channels.

3. Sunset Provision- An individual threat alert is issued for a specific time period and then automatically expires. It may be extended if new information becomes available or the threat evolves. If threat information changes for an alert, the Secretary of Homeland Security may announce an updated NTAS Alert. All changes, including the announcement that cancels an NTAS Alert, will be distributed the same way as the original alert.

NTAS Alerts will be issued through state, local and tribal partners, the news media and directly to the public. The public can also expect to see alerts in places, both public and private, such as transit hubs, airports and government buildings.

Materials Handling The Contractor shall be responsible for the security of the product from the time it is released from the manufacturer through the time of application. The Contractor must be able to provide documentation disclosing the chain-of-custody for SPLAT-GMO upon request of the Contracting Officer at any time during the project. If the integrity of the products has been compromised in any way resulting in a failure to maintain product security, all spray operations will cease until the Contractor can resolve these issues to the satisfaction of the Contracting Officer.

Delivered/On-Site – Agricultural products

Handling (safeguarding) Only trained and authorized personnel, using appropriate personal protective equipment, shall handle agricultural materials, such as pesticides.

Distribution (one place to another) Distribution occurs hourly and daily at an on-site operation between the storage facility and the agricultural aircraft. This ongoing operation must be safeguarded to lower the risk of any unauthorized person gaining access to the material.

Storage On-site storage of material will be kept secured at all times which includes during operational periods and non-operational periods. These facilities will be locked and safeguarded overnight with the ultimate responsibility upon the project manager. Utmost accountability for safeguarding agricultural materials on-site is essential to assure that the material being dispersed is the material that has been safeguarded. Storage facilities should be identified clearly to all project personnel in order to

safeguard the material and utilizing all personnel’s support in doing so. Numbered seals where possible will be utilized each day to assure that stored materials have not been compromised.

Chain-of-Custody (On-site) The Contractor is responsible for developing and maintaining a Key Control Custody Policy that insures security of agricultural materials. Duties and responsibilities will be clearly defined and assigned to responsible personnel capable of handling tasks related to security of materials throughout the project.

1) One individual, designated by the Contractor, will be responsible for issuing materials and maintaining daily logs. 2) Containers shall only be opened just prior to loading into the aircraft. 3) Only persons designated by the Contractor shall handle materials.

Documentation Project Daily Journal A log journal at the Base Operations area will be maintained at all times commencing on the first event of the day through the last event of the day. Daily opening and closing of the log as well as every event related to the project shall provide the date, time, and signature for every entry. This insures that action was recognized and executed as every event occurs. If a manager or project personnel must depart the project, a log journal and status briefing aids the incoming person as to the status of the job.

Key Control Register Referenced in Solicitation No. AG-56A1-C-17-0002 (Exhibit 2 – Security of Aircraft, Equipment and Product, pp. 6-7). The contractor is responsible for key control.

Security Considerations for Agricultural Aircraft Operators Will be posted at base operations.

On-Site – Petroleum products (aircraft fuel) The local fuel supply operator generally handles security of aircraft fuel, however, we must be aware that fuel contamination can and does contribute to aircraft engine malfunction. Operators conduct fuel checks for water and visual contaminates on a daily basis, however, we must be aware that this is an easy source to contaminate or interrupt the operation of an aircraft engine. Discussion with the fuel supplier and how safeguarded the fuel storage tanks and airport tank farm may aid in taking further actions regarding security.

Personnel

Health & Safety (Hygiene) The health and safety of personnel is the most significant factor for all organizations.

Personal Protective Equipment (PPE) PPE required by the SDS sheets and product labels will be used to reduce the risk of personal injury. If a particular task requires a specific piece of PPE, it is incumbent upon all of us to insure that our employees are protected with these safety devices. This part shall define how an organization has planned to protect its employee’s health and welfare.

Public information (keep project specific) Keeping the public informed prior to and during the aerial spraying operation builds credibility and reduces public rhetoric. However, specific and personal information of an employee, contractor, or organization should be very limited and responded to in generic terms. Security of our employees and associates on the job is as important as keeping them safe.

Facility Security

The FAA has raised the security posture at all Part 107 airports throughout the United States as a prudent measure of informing airport and airfield operators of this concern. Accordingly, to help keep public and private airfields safe and secure during the foreseeable future, the FAA has requested the help of everyone affiliated in the aviation industry.

Airfield and Aircraft Security Circular (see following pages), is a circular that the FAA encourages distribution to all organizations, which have a regular presence on an airfield. This circular should be printed and displayed on information bulletin boards at base operations advising actions to be taken by project personnel.

REMEMBER: If you see something highly dangerous, such as weapons or explosives, being loaded on an aircraft; or if you have other reason to believe that a serious crime or some sort of attack is about to occur, immediately call local law enforcement authorities …AND CALL YOUR NEAREST FBI OFFICE

Airfield and Aircraft Security Circular

AIRPORTS

Airfield and Aircraft Security in the Wake of the Terrorist Attacks

Following the September 11, 2001, multiple terrorist attacks against U.S. civil air carriers, involving the World Trade Center and the Pentagon, the FAA is advising of the potential for follow-on terrorist attacks.

As we have done on several occasions in the past, the FAA is seeking your cooperation in helping to safeguard the air transportation system. We are raising the security posture at all Part 107 airports throughout the United States. We believe that it is prudent to inform airport and airfield operators of our concern. Accordingly, to help keep public and private airfields safe and secure during the foreseeable future, we need your help.

IF YOU ARE THE OWNER OR OPERATOR OF AN AIRFIELD PLEASE:

1. Distribute this circular to all organizations, which have a regular presence on the airfield. 2. Contact your local law enforcement agency and verify the procedures you would use to report any suspicious activity at your airfield. 3. Promptly report information indicating possible criminal activity to your local law enforcement agency.

PERSONS INVOLVED IN OPERATING, SERVICING OR RENTING SMALL AIRCRAFT SHOULD BE ON THE LOOK-OUT FOR:  Aircraft with unusual or unauthorized modifications;  Persons loitering for extended periods in the vicinity of parked aircraft or in air operations areas;  Pilots who appear to be under the control of other persons;  Persons wishing to obtain aircraft without presenting proper credentials or persons who present apparently valid credentials but do not have a corresponding level of aviation knowledge; or  Anything that doesn't look right! (i.e. events or circumstances, which do not fit the pattern of lawful normal activity at your airport.)

AND CALL YOUR NEAREST FBI OFFICE

Security Considerations for Agricultural Aircraft Operators

Prepared by the National Agricultural Aviation Association

 Considering the September 11th, 2001 terrorist attacks on the United States, and the resulting federal government and national news media focus on our industry, the National Agricultural Aviation Association (NAAA) reminds all agricultural aircraft operators to maintain, and where necessary, improve aircraft and operations security. Having endured multiple ground stops over the last few weeks it is obvious that our ability to work and protect American agriculture is in a precarious state. We must address security concerns expressed by federal and state law enforcement agencies to insure that our aircraft, crop protection chemicals, and operations are maintained in a secure state.

 NAAA recommends that, where possible, aircraft and crop protection products are stored in locked hangars with electronic security systems when not in use. Loader trucks, forklifts, or other equipment may also be parked and temporarily disabled in such a manner as to block movement of the aircraft. In cases where hangar space is not available and aircraft must be left outdoors, propeller chains, locking high strength tie down chains, or blocking equipment are practical alternatives. Outdoor security lighting is also recommended.

 Operators are also encouraged to explore the possibility of installing hidden security switches to insure no unauthorized aircraft starting. This, however, must be accomplished in compliance with FAA regulations governing aircraft modification.

 In the case of operators who live on the premises, or have employees living on airport grounds, enhanced security lighting, alarms, and dogs are effective deterrents against criminal activity.

 NAAA recommends that operators establish contact with federal and local law enforcement agencies to coordinate responses to security breaches at Ag aviation facilities. Appropriate law enforcement agency telephone numbers should be posted in a prominent place and employees should be instructed to maintain enhanced security awareness. These telephone numbers should be registered with any private security company that monitors the electronic security system of an agricultural aviation operation.

 We also recommend you securely store and monitor all of your chemicals. Recommendations include storage in a building with steel doors, use of an electronic security system, and tampering tape. The protection of crop protection chemicals is essential to maintaining a safe operation.

October 26, 2001

Airports

Lighting Evaluate security lighting in the aircraft ramp area as well as in vehicle parking lots. Agricultural aircraft may be required to be moved into a lighted area to adequately secure the aircraft overnight.

Fencing Security fencing around an established airport limits the potential for an intruder to tamper with aircraft. The lighting and fencing are identified on the airport operations plan that can aid the project manager in negotiating ramp space for aircraft parking.

Crowd control Crowd control and sightseers at an airport are fairly well controlled by the fencing and gating of ramps, taxiways, and runways of an airport. At smaller airports crowd control may become a more important issue for officers and employees assigned to the project. Law enforcement personnel will be assigned to the project for security and crowd control. This will assure assistance if necessary and to control specific crowd problems.

Fire support Identify what fire suppression apparatuses exists on-site, location of the local fire department, and what the procedures are to contact the fire organization. Many towns are equipped with 911 County Disaster Control Centers, however, there are areas that do not have this service. All cooperating agencies will provide the information upon arrival to each base of operations and will be posted in a centralized location and identified to each person on site. Emergency numbers will also be included in the project safety plan.

Law Enforcement Local, state, and federal law enforcement organizations provide the primary backup for officers assigned to this project. A complete list of these agencies along with dispatch and contact numbers is included as an appendix to this Plan. Coordination with these agencies prior to an emergency can improve the quality, and speed of any emergency response. Local law enforcement will be notified by uniformed Forest Service law enforcement officers on operations site during operational periods. At that time they will double check telephone numbers and contact lists in case of emergency.

Visitor staging area Identifying a visitor staging area provides the safety and security of personnel actively engaged in the project and the visitors and sightseers that are interested in watching the operation of the project. This area shall be identified and

maintained in order to provide control of people. Base Operations Padlocks Securing Base Operation Centers, where appropriate, is the responsibility of the project manager or a designated representative. Facilities, materials, and equipment such as computers and sophisticated equipment will be secured at the end of each work session.

Authorized Personnel Authorized personnel shall be identified and listed in the log journal with POC information for making emergency calls, information on personal allergies, etc. A personnel list will be established and posted at the base of operations. Only personnel designated by the project coordinator or Contractor will be allowed on the base of operations. All authorized personnel will be issued photo Id’s by the Contractor and are to be worn at all times. Unauthorized personnel will be prevented from accessing the site by project security personnel.

Communications Base communications operate in two modes, internal and external. Therefore, it is critical to limit specific information on a person or persons’ involvement in a project.

Computer capable Computers hold much information and data that can be helpful to both a manager and a terrorist. Safeguarding computer hardware, passwords, and email addresses results in a more secure operation. Identify how many computers are involved in the project and the security measures in maintaining security.

Parking lots/Aircraft ramps It is important to always be aware of your surroundings, particularly in parking lots. Be aware of where you park your automobile and the parking lot lighting available.

Communications

Human Assure that all instructions are clearly understood and that everyone is accountable for stopping an unsafe act in order to prevent personnel injury. Throughout all phases of the project, it is critical that all personnel contribute their individual efforts into a collective force that promotes dialogue, respect, and professionalism. Radio

Transmitting radio messages should be clear, concise, and limited to project work. It is important to conduct a communications-test prior to the commencement of daily operations to assure that two-way communication is functioning properly and the system is operational.

Frequencies (safeguard) It is important to safeguard radio frequencies as much as possible. Though many scanners identify a frequency when activated, it is a security issue when the frequencies are intercepted and used by unauthorized personnel. If this occurs, contact your unit’s communications manager or the local Federal Communications Commission representative in your area.

Base Base radios are often supplied with the capability of transmitting messages at greater distances due to the increased power wattage. Therefore, voice transmissions are being carried at greater distances than that of a portable radio, however, a radio-phenomena known as ‘skip’ can project messages hundreds of miles or further. Limit your voice transmissions and focus them on project needs only. Undoubtedly, those interested in monitoring local communications traffic with scanners will be receiving your transmissions, therefore, it is critical to think about coding aircraft call-signs rather than using pilot names, coding geographic locations with numeric or alpha-numeric identifiers, and documenting transmissions both to/from the base in the project log journal.

Portable Radios (safeguard/secure) In order to maintain security and accountability of these small electronic communication tools, inventory portable radios periodically. Record your inventory-count in the log journal for record. Upon initial distribution of radios, write the serial numbers and assigned operators on a separate page of the log journal in order to maintain an accurate inventory. Portable radios will only be issued to necessary personnel.

Telephones

Base Only cell phones will be used at the base of operations. All personnel will safeguard the individual numbers and not divulge the information to persons outside the project.

Satellite Phones A satellite phone will be assigned to the project that may be used for emergencies in areas with poor cell coverage. .

Listings posted Telephone listings will be posted and maintained at the base operations as well as with every person on the project. In the event of an emergency, it is critical that this information is readily available to all and that a protocol is used in calling personnel. If a national disaster occurs and field personnel are unaware, it is critical to inform these people and let them know what to do. These listings shall also be secured by a document cover if posted on a wall.

Activities Log Journal It is very critical to document every significant event with a time/date and short narrative, and action taken for incoming/outgoing messages and decisions.

Aircraft

Contractors working for cooperators must abide by any current regulations issued by the FAA with regard to aircraft and insecticide safeguarding and security, as well as any rules and/or recommendations that are issued by the National Association of Aerial Applicators, the USDA Forest Service, USDOT Federal Aviation Administration, or any other responsible agency.

Fixed-wing There are a number of ways an aircraft may be disabled and secured. One method is to use security personnel to guard aircraft during non-operational periods. Another method utilized to secure aircraft may incorporate the use of a mechanical device. However, with recent concerns in securing and locking aircraft, there may be two key Federal Aviation Regulations (FAR) that may be overlooked.

The first is FAR Part 23.679, which states: "If there is a device to lock the control system on the ground or water (a) there must be a means to- (1) give unmistakable warning to the pilot when the lock is engaged"

The second FAR, Part 23.783 (c) (6) states: "Auxiliary locking devices that are actuated externally to the airplane may be used but such devices must be overridden by the normal internal opening means."

1) All agricultural spray application aircraft must be disabled when not in use so that they cannot be started and/or operated by anyone other than authorized personnel. 2) All aircraft will have a keyed locking shut-off device for the fuel system to prevent aircraft operation. 3) Security will be provided by the contractor during off duty hours.

Following are a few recommendations that may be used, in-part or whole, to secure various types of aircraft.  Aircraft, where hangars are available, should be locked inside.

 Aircraft cabin doors will be locked.  Flight logbooks and credit cards should be removed when not in use.  Small expensive items, such as hand-held GPS units, should be removed and secured when not in use.  Pre-flight inspections will include checks for tampering of any sort.  Keys will be managed in secure locations only.

Insecticide Containers Insecticide containers, hoppers, mix tanks, pumps, hoses, and similar equipment must be located in a secure area, locked when not in use or have all possible points of entry sealed.

Threats

Telephone/Electronic/Computer, and Bomb Threats Contact your project manager & project LEO or security Contact the local and state law enforcement Contact the local FBI Field Office (found in Telephone book)

Human-oriented (onsite protestors) Contact your project manager & project LEO or security Contact the local and state law enforcement

Aircraft  In-flight weapons shooting incident  In-flight aircraft mid-air attack These terrorist events are to be reported to the project LEO or security, project manager, local and state law enforcement, and the local FBI Field Office. Be sure that the FBI is notified of the event since threatening, shooting, attacking, or causing harm to any aircraft while in flight is a federal offense. Breach of Security

Incidents of unauthorized personnel in the secure area of operations, tampering with aircraft, attempts to cross fences or defeat other security measures will be immediately reported by calling 911, with subsequent advice to the Project/Aviation Manager and State Officer-in-Charge. If the project is being conducted in cooperation with a federal agency, the agency’s aviation manager shall be contacted and informed of the violation. The Security Incident Situation Report (see next page), provides the reporting agent a standardized format for reporting an incident. It is very critical to accurately report the incident immediately and in accordance to the reporting protocol that is predetermined during the project planning process.

2019 STATE EMERGENCY CALL NUMBERS

INDIANA

STATEWIDE EMERGENCY SERVICES 911

IOWA

STATEWIDE EMERGENCY SERVICES 911

NORTH CAROLINA

STATEWIDE EMERGENCY SERVICES 911

OHIO

STATEWIDE EMERGENCY SERVICES 911

VIRGINIA

STATEWIDE EMERGENCY SERVICES 911

WISCONSIN STATEWIDE EMERGENCY SERVICES 911 CHEMICAL SPILLS – WI DEPT. OF AGRIC 1-800-943-0003

ACTIVE INGREDIENT: Disparlure (Z)-7,8-Epoxy-2-methyloctadecane: 13.00% OTHER INGREDIENTS: 87.00% TOTAL: 100.00%

Net Contents: Lbs Kg Batch Number:

EPA Reg. No. 80286-12 EPA Est. No. 80286-CA-004 ™ KEEP OUT OF REACH OF CHILDREN GM -O CAUTION For Mating Disruption of FIRST AID STATEMENT Lymantria dispar, gypsy moth IF IN EYES: • Hold eye open and rinse slowly and gently with water for 15-20 minutes. • Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. • Call poison control center or doctor for treatment advice. SPLAT (Specialized Pheromone & Lure Application IF ON SKIN OR CLOTHING: • Take off contaminated clothing. Technology) is an amorphous polymer matrix for • Wash skin immediately with soap and water, then rinse with plenty the sustained release of insect pheromones. of water for 15-20 minutes. IF SWALLOWED: SPLAT GM-O provides control by disrupting mating • Call poison control center or doctor immediately for treatment behavior. advice. • Have person sip a glass of water if able to swallow. • Do not induce vomiting unless told to do so by poison control center or doctor. • Do not give anything by mouth to an unconscious person. For Organic Production HOTLINE NUMBER National Pesticides Information Center: Have the product container or label with you when calling a poison control center, doctor, or going for treatment. For emergency information concerning this product, call the National Pesticides Information Center (NPIC) at 1-800-858-7378 seven days a week, 6:30 am to 4:30 pm Pacific Time (NPIC Web site: www.npic.orst.edu). See side/back panel for additional precautionary statements.

PRECAUTIONARY STATEMENTS cylinders, or a combination of both. The flow of SPLAT GM-O product can be controlled HAZARDS TO HUMANS AND DOMESTIC ANIMALS, CAUTION: Causes moderate eye irritation. Harmful if with agricultural-type solenoids. Calibrate applications based on volume output and swallowed or absorbed through skin. Avoid contact with skin, eyes, or clothing. Wash thoroughly with soap and application speed and swath area treated. Do not apply this product through any type of water after handling and before eating, drinking, chewing gum, using tobacco, or using the toilet. Remove irrigation system. SPLAT GM-O can also be applied manually using other devices like a contaminated clothing and wash before use. metered dosing gun. To ensure proper application, consult your pest control advisor, PERSONAL PROTECTIVE EQUIPMENT (PPE): Applicators and other handlers must wear long-sleeved shirt distributor, or ISCA Technologies, Inc. and long pants, waterproof gloves, and shoes plus socks. Follow the manufacturer’s instructions for cleaning POINT For ground applications, SPLAT GM-O dollop size can be varied depending on pest maintaining PPE. If no such instructions for washables, use detergent and hot water. Keep and wash PPE SOURCE SIZE, population and duration of control desired. A dense infestation will require a higher density separately from other laundry. PLACEMENT, of point sources to achieve optimal mating disruption. With aerial applications, there is ENVIRONMENTAL HAZARDS: For terrestrial uses: Do not apply directly to water, or to areas where surface AND SPACING less control over the variation in droplet size and there will be a range from approximately water is present or to intertidal areas below the mean high water mark. Incidental applications to water under 300 to 2000 microns in size. When SPLAT GM-O is sprayed on the tree canopy at 46 the forest canopy are not considered to be a direct application to water, but should be avoided if practicable. grams per acre (6 grams AI per acre), the range in droplet size will usually be 300 to 1000 Spray valves must be shut off when passing over surface water not under the canopy. Do not contaminate microns. This will provide area-wide, season-long management of low-density water when cleaning equipment or disposing of equipment washwaters or rinsate. populations. To ensure proper application, please consult your pest control advisor, DIRECTIONS FOR USE distributor, or ISCA Technologies, Inc. It is a violation of Federal Law to use this product in a manner inconsistent with its labeling. Always consult CLEANING Clean equipment with water and citrus or limonene detergents. your pest control advisor, distributor or ISCA Technologies, Inc. for advice regarding the use of SPLAT GM-O. EQUIPMENT STORAGE AND DISPOSAL Do not contaminate water, food or feed by storage and disposal. GENERAL SPLAT GM-O uses the pheromone of the gypsy moth (Lymantria dispar), to disrupt adult PESTICIDE Store product sealed and refrigerated, if possible. If refrigerated, do not store with food. If moth mating and thus reduce larval damage to trees. STORAGE refrigeration is not available, store product in a cool dry place, out of direct sunlight. Do not exceed TARGET PEST Gypsy Moth (Lymantria dispar) 75°F for long-term storage. Avoid freezing. In case of leak or spill, wipe with paper towel AREA-WIDE This product is only for use in wide-area gypsy moth control programs sponsored by and dispose of waste when product hardens. CONTROL government entities. Areas of application include, but are not limited to: forests; residential, PESTICIDE Wastes resulting from the use of this product may be disposed of on site or at an approved municipal, and shade tree areas; recreational areas such as campgrounds, golf courses, DISPOSAL waste facility. parks, and parkways; ornamental and shade trees; shelterbelts, rights-of-way; and other CONTAINER Nonrefillable container. Do not refill or reuse this container. Triple rinse (or equivalent) easements. Area-wide or wide-area application of SPLAT GM-O is most effective. The DISPOSAL promptly after emptying. Then offer for recycling if available, or puncture and dispose of in efficacy of any mating disruption strategy will be reduced by the influx of adults from a sanitary landfill, or by incineration, or, if allowed by state and local authorities by burning. surrounding areas. It is for this reason that mating disruption works increasingly well with If burned, stay out of smoke. larger acreages, where the ratio of exposed borders to overall area treated is reduced. WARRANTY AND LIMITATION OF DAMAGES Always make application of SPLAT GM-O in consultation with your pest control advisor, Read all directions carefully. All statements concerning the use of this product apply only when used as distributor, or ISCA Technologies, Inc. directed. ISCA Technologies warrants that this material conforms to the specifications on the label and is No intentional food uses are permitted. However, an exemption from the requirement of a reasonably fit for the intended purpose referred to on the label. To the extent consistent with applicable law, tolerance is established for residues of (Z)-7,8-epoxy-2-methyloctadecane (Disparlure) on ISCA Technologies makes no other express or implied warranty of merchantability or fitness for a particular all food and feed crops that occur when it is used to treat trees, shrubs, and pastures and purpose or any other express or implied warranty. such use results in unintentional spray and drift to non-target vegetation including non- ISCA Technologies, Inc. 1230 Spring St., Riverside, CA, 92507 951-686-5008 www.iscatech.com food, food, and feed crops.

MONITORING Monitor for pests on a regular basis so that timely intervention with insecticides or alternative controls are possible. Use gypsy moth pheromone-baited monitoring traps made by ISCA Technologies or other suitable traps to monitor the presence of male moths, their emergence and their movement. Place monitoring traps before applying SPLAT GM- O to determine the infestation level. Continue monitoring throughout the season to evaluate efficacy and longevity of the pheromone application. Monitor treated plots for the target pest. Implement supplementary control measures if the pest population densities are above economic threshold levels. APPLICATION Apply SPLAT GM-O anytime in the two weeks preceding male flight and adult activity. TIMING Additional applications may be made if populations exceed the economic threshold. Consult your pest control advisor, distributor, or ISCA Technologies, Inc. for proper application timing. APPLICATION Apply SPLAT GM-O when the ambient air temperature is above 50°F. SPLAT GM-O will CONDITIONS cure within 3-4 hours following application, after which it will become rain fast and UV resistant. Do not apply if rain is expected within 1-2 hours of application or the temperature is outside of this range. APPLICATION The application rate of SPLAT GM-O ranges from 23 grams to 230 grams of undiluted RATE product per acre. This is equivalent to 3 grams to 30 grams of pheromone active ingredient (AI) per acre. Do not exceed 150 grams of AI per acre per year for multiple applications. PREPARATION Always check SPLAT GM-O 24 hours before using. If SPLAT GM-O has been stored in a FOR USE refrigerated area and has hardened, allow at least 48 hours at room temperature to achieve a workable consistency. Always mix SPLAT GM-O thoroughly before use: a drill with a paint mixing paddle or similar device works best. Avoid mechanical mixing with sharp blades, which come into contact with the plastic container as this can introduce shards of plastic into the SPLAT GM-O formulation, which might interfere with product flowability and application. APPLICATION SPLAT GM-O is applied either aerially or by ground with conventional application systems EQUIPMENT pressurized either by centrifugal pumps or positive displacement pumps, pressurized gas

Safety Data Sheet Splat GM-O Last Revised: April 29 2014 Version: 1 Section 1: Identification Manufacturer: ISCA TECHNOLOGIES, Inc. Product Name: Splat GM-O 1230 Spring Street Product Code: Splat GM-O Riverside, CA 92507 www.iscatech.com Recommended Use: For the control of Gypsy Moth, Emergency Phone Number: 951 686 5008 Lymantria dispar. SPLAT GM-O uses the pheromone of the gypsy moth (Lymantria dispar), to disrupt adult moth mating and thus reduce larval damage to trees.

Section 2: Hazard Identification

GHS-US classification and Hazard Statement: Hazard Pictograms: H305 - May be harmful if swallowed and enters airways H316 - Causes mild skin irritation H320 - Causes eye irritation GHS07 H333 – May be harmful if inhaled

Precautionary Statements: P102 - Keep out of reach of children P305+P351+P338 - If in eyes: Rinse cautiously with water P103 - Read label before use for several minutes. Remove contact lenses, if

P270 - Do not eat, drink or smoke when using this product present and easy to do. Continue rinsing P233 - Keep container tightly closed. P312 - Call a POISON CENTER or doctor if you feel unwell P264 - Wash hands, forearms, and exposed areas P337+P313 - If eye irritation persists: Get medical thoroughly after handling. advice/attention P280 - Wear eye protection, protective clothing, P403+P233 - Store in a well-ventilated place. Keep protective gloves container tightly closed P303+P361+P353 - IF ON SKIN (or hair): Remove/Take off P235 - Keep cool immediately all contaminated clothing. Rinse skin P501 - Dispose of contents/container according to local, with water/shower regional, national, and international regulations P304+P340 - IF INHALED: Remove person to fresh air and keep comfortable for breathing

SECTION 3: Composition/information on ingredients Active Ingredient Name CAS # Molecular Molecular Chemical Name GHS-US Classification Mass Formula Disparlure 29804-22-6 282.50 C19H38O Cis-7,8-Epoxy-2-methyloctadecane H227, H316, H320, H335 SPLAT GM-O (Mixture: Active Ingredient + Inert Ingredients) Name CAS # Molecular Molecular Chemical Name GHS-US Classification Mass Formula Splat GM-O Not applicable Not Not Not applicable H305, H316, H320, (mixture) applicable applicable H333 Note: The inert ingredients consist of water, wax, oils and food grade emulsifiers and preservatives.

SECTION 4: First aid measures Description of first aid measures Inhalation: Move victim to fresh air. Administer oxygen if breathing is difficult. Give artificial respiration if victim is not breathing. Skin: In case of contact with substance, immediately flush skin with running water for at least 20 minutes. Wash skin with soap and water. Take off contaminated clothing and wash before reuse. If skin irritation occurs: Get medical advice/attention. Eye: IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. If eye irritation persists: Get medical advice/attention. Ingestion: Call poison control center or doctor immediately for treatment advice. Do NOT induce vomiting unless told to do so by poison control center or doctor. Have person sip a glass of water if able to swallow. Do not give anything by mouth to an unconscious

person. Notes to Physician: All treatments should be based on observed signs and symptoms of distress in the patient. Consideration should be given to the possibility that overexposure to materials other than this product may have occurred.

Safety Data Sheet Splat GM-O Last Revised: April 29 2014 Version: 1 SECTION 5: Firefighting measures Suitable Extinguishing Media: Not applicable. Splat GM-O is not flammable.

SECTION 6: Accidental release measures Personal precautions, protective equipment and emergency procedures: Personal Precautions: Applicators and other handlers must wear long-sleeved shirt and long pants, waterproof gloves, and shoes plus socks. Follow the manufacturer’s instructions for cleaning maintaining PPE. If no such instructions for washables, use detergent and hot water. Keep and wash PPE separately from other laundry. Environmental precautions: For terrestrial uses: Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark. Incidental applications to water under the forest canopy are not considered to be a direct application to water, but should be avoided if practicable. Spray valves must be shut off when passing over surface water not under the canopy. Do not contaminate water when cleaning equipment or disposing of equipment washwaters or rinsate. Methods and material for containment and cleaning up: In case of leak or spill, wipe with paper towel and dispose of waste when product hardens. Clean equipment with water and citrus or limonene detergents.

Section 7 - Handling and Storage Storage: Store product sealed and refrigerated, if possible. If refrigerated, do not store with food. If refrigeration is not available, store product in a cool dry place, out of direct sunlight. Do not exceed 75°F for long-term storage. Avoid freezing. Incompatible materials: Keep away from heat, oxidizers and strong acids.

SECTION 8: Exposure controls/personal protection Exposure Controls: Engineering Controls: Safety shower and eye wash. Personal Protective Equipment: Applicators and other handlers must wear long-sleeved shirt and long pants, waterproof gloves, and shoes plus socks. Follow the manufacturer’s instructions for cleaning maintaining PPE. If no such instructions for washables, use detergent and hot water. Keep and wash PPE separately from other laundry. Safety goggles are recommended. General Hygiene measures: Handle in accordance with good industrial hygiene and safety practice. Wash thoroughly with soap and water after handling and before eating, drinking, or using tobacco.

Section 9 - Physical and Chemical Properties Active Ingredient: Physical state: Liquid Specific Density: 0.844±0.06 g/cm3 Temp: 20 °C Odor: Waxy, fatty Partition coefficient Log P: 8.540±0.253 Temp: 25ºC n-octanol/water:

pH: Not applicable Solubility: Not soluble in water. Soluble in most organic solvents Melting point: Data Not Available Evaporation Rate: Data Not Available Boiling point: 340.6±10.0 °C @ Press: 760 Torr Vapor Pressure: 1.68E-4 Torr. Temp: 25 °C Flash Point: Flash Point: 139.7±15.9 °C SPLAT GM-O (Mixture: Active Ingredient + Inert Ingredients) Physical state: Thick liquid, semi-solid, Specific Density: 0.93 g/cm3 Temp: 25 °C grease-like consistency

Odor: Waxy, fatty Partition coefficient Data not available n-octanol/water:

pH: 6.88 Solubility: Partially soluble in water Melting point: Data Not Available Evaporation Rate: Data Not Available Boiling point: Above 100ºC Vapor Pressure: Data not available Flash Point: Not applicable. Product is not flammable

Section 10: Stability and Reactivity Reactivity: No dangerous reaction known under conditions of normal use. Chemical stability: Stable under normal temperatures and pressures. Possibility of hazardous reactions: Hazardous polymerization will not occur. Conditions to avoid: High temperatures, sparks, open flames and live electrical circuits.

Incompatible materials: Oxidizing agents, strong acids. Hazardous decomposition products: In case of fire oxides of carbon, fumes or vapors, soot and smoke may be produced.

Safety Data Sheet Splat GM-O Last Revised: April 29 2014 Version: 1

Section 11 - Toxicological Information Active Ingredient: Acute oral LD50 (rat) : >34600 mg/kg Acute dermal LD50 (rabbit): >2025mg/kg 3 Inhalation LC50 (rat): >5000mg/m

SPLAT GM-O (Mixture: Active Ingredient + Inert Ingredients): Toxicological properties of this product have not been thoroughly investigated.

Section 12 - Ecological Information Data is not available. Product should not be directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark. Incidental applications to water under the forest canopy are not considered to be a direct application to water, but should be avoided if practicable. Spray valves must be shut off when passing over surface water not under the canopy. Do not contaminate water when cleaning equipment or disposing of equipment washwaters or rinsate.

Section 13 - Disposal Considerations Appropriate Method of disposal: Contact a licensed professional waste disposal service to dispose of this material. This material may be burned in a chemical incinerator equipped with an afterburner and scrubber or disposed in a sanitary landfill in accordance with local, state, and federal regulations. Observe all federal, state, and local environmental regulations.

Section 14 - Transport Information Transport in accordance with local, state and federal regulations.

Section 15 - Regulatory Information US Classification and label Text: Indication of Danger: Irritant. Safety Statements: Keep away from heat – no smoking. United States Regulatory information: SARA Listed: No

Section 16 - Other Information The above information is believed to be correct but does not purport to be all inclusive and shall be used only as a guide. The information in this document is based on the present state of our knowledge and is applicable to the product with regard to appropriate safety precautions. It does not represent any guarantee of the properties of the product. Users are advised to confirm in advance of need that information is current, applicable and suited to the circumstance of use. Isca Technologies, Inc. shall not be held liable for any damage resulting from handling or from contact with the above product. Furthermore, Isca Technologies, Inc. assumes no responsibility for injury caused by abnormal use of this material even if reasonable safety procedures are followed. Any questions regarding this product should be directed to the manufacturer as described in Section 1.

A NIST, NIH, USDA, NSF, US Air Force, US Army, and Vodafone research award recipient company

Frequently Asked Questions

What Is SPLAT GM-O?

SPLAT GM-O is an organic, biodegradable formulation for the control of Gypsy Moth (Lymantria dispar) using Mating Disruption. It is made entirely of food grade materials and has the consistency of hand cream. SPLAT GM-O uses pheromone, an effective and safe method to control Gypsy Moth without impacting other insects, mammals or the surrounding environment.

What Are Pheromones?

Pheromones are natural compounds that insects use to communicate, similar to the way humans use language. Applying pheromone to a field confuses the insects, removing their ability to mate and controlling populations in a completely non-lethal manner.

What Is Mating Disruption?

Mating disruption is a mechanism for insect control that utilizes species-specific pheromones to disrupt the life cycle of insects. Confusing insects and removing their ability to mate controls populations without the use of toxic chemicals.

How Will SPLAT GM-O Be Applied?

SPLAT GM-O is almost always applied aerially. Airplanes or helicopters flying 100 to 200 feet above treetops will spray SPLAT GM-O over areas where gypsy moth control is desired.

Page 1 of 2 ISCA TECHNOLOGIES, INC. 1230 Spring Street, Riverside, California 92507, U.S.A. www.iscatech.com Tel: (951) 686 5008 Fax: (815) 346 1722 E-mail: [email protected]

A NIST, NIH, USDA, NSF, US Air Force, US Army, and Vodafone research award recipient company

How Much SPLAT GM-O Will Be Used?

For control of Gypsy Moth, doses of active ingredient (pheromone) can range from a low of 3 grams per acre to a high of 30 grams per acre. Most frequently, it is applied at a dose of 6 grams per acre, which equates to 46 grams of SPLAT GM-O. This is less than a cup of SPLAT GM-O being spread over an acre of forest per year to control Gypsy Moth.

Is SPLAT GM-O Harmful To Humans Or Animals?

No, SPLAT GM-O is completely harmless to humans and animals. All of the ingredients in SPLAT GM-O are listed by the Environmental Protection Agency (EPA) as safe and have been approved for food use. Should you, your children and/or pets come in contact with SPLAT GM- O, simply wash the affected area with soap and water. Clothing can be cleaned with hot water and laundry detergent.

Is SPLAT GM-O Harmful To The Environment?

No, SPLAT GM-O is completely harmless to the environment. SPLAT GM-O is a biodegradable formulation specifically targeted at the Gypsy Moth. It will not affect other insects or wild life.

Is SPLAT GM-O Organic?

Yes, SPLAT GM-O is certified organic under the USDA’s National Organic Program. In 2017, ISCA also expects to receive organic certification from the Organic Materials Review Institute (OMRI).

What If SPLAT GM-O Lands on My Car or Lawn?

SPLAT GM-O will not harm the paint of your car. If you notice SPLAT GM-O droplets on your car, wash it with a mild detergent and water like you would with road grime. SPLAT GM-O will not harm your lawn and will immediately start biodegradation into the soil.

Page 2 of 2 ISCA TECHNOLOGIES, INC. 1230 Spring Street, Riverside, California 92507, U.S.A. www.iscatech.com Tel: (951) 686 5008 Fax: (815) 346 1722 E-mail: [email protected]