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1 2019 GYPSY MOTH SLOW THE SPREAD MATING DISRUPTION PROJECT AVIATION SAFETY AND MANAGEMENT PLAN IN COMPLIANCE WITH CONTRACT # AG-56A1-C-17-0002
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2019 GYPSY MOTH SLOW THE SPREAD MATING DISRUPTION

PROJECT AVIATION SAFETY AND MANAGEMENT PLAN

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

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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

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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 Moth Slow the Spread Mating Disruption

Unit: FHP-R9, R8 Fixed Wing

Anticipated Project Date: June 1 – August 1, 2019

Project Plan Prepared by:

/s/ Laurel Haavik /s/ Tom Coleman

Title: Entomologist, FHP-R9 Entomologist, FHP-R8

Date:

3/22/2019 3/22/2019

Project Plan Reviewed by: Robert Madill

Title: R9 Regional Aviation Officer Date:

Project Plan Reviewed by: Jerry Perry

Title: R8 Regional Aviation Officer Date:

Project Plan Approved by: Kathleen Atkinson

Title: R9 Regional Forester Date:

Project Plan Approved by: Ken Arney

Title: R8 Regional Forester Date:

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 Haavik

Date: 3/22/2019

Operation Approved By: George (Nick) Hough

Title: R9 Aviation Safety Mgr. Date:

Operation Approved By: James Keyes

Title: R8 Aviation Safety Mgr. Date:

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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).

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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#: N444AS N445MS N444MS N144KS N1025A N7307T

Make/Model: AT 400 AT 502B AT 400 AT 400 AT 502 AT 400

Aircraft Color: AT yellow AT yellow AT yellow AT yellow AT yellow 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#: N42801 N759JM N3343F N8470M

Make/Model: Cessna C-182 Cessna C-182 Cessna C-182 Cessna C-182

Aircraft Color: White with various markings

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 contract with 4 option years

Charge Code: N/A

Estimated Flight Hours: 450 hours in 2019 (application flight hours + hours flight for observation aircraft)

Estimated Cost: $1.1 million

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SUPERVISION

Project Aviation Manager/COR: Tom Coleman

Contact Number: 828-446-5142 (cell)

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

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BASES OF OPERATION

Airport Runway Length (ft) Danville Regional Airport (DAN) Danville, VA

5900X100; asphalt

Mountain Empire Airport (MKJ) Wytheville, VA

5252X75; asphalt

Zanesville Municipal Airport (ZZV) Zanesville, OH

5000X150; asphalt

Fairfield County Airport (LHQ) Lancaster, OH

5004X75; asphalt

Putnam County Airport (OWX) Ottawa, OH

4504X75; asphalt

Albertus Airport (FEP) Ottawa, OH

5504X100; asphalt

Boscobel Airport (OVS) Boscobel, WI

5000X75; asphalt

Prairie Du Chien Municipal Airport (PDC) Prairie Du Chien, WI

5000X75; asphalt

La Crosse Regional Airport (LSE) La Crosse, WI

8742X150; concrete

Chippewa Valley Regional Airport (EAU) Eau Claire, WI

8101X150; concrete

Solon Springs Municipal Airport (OLG) Solon Springs, WI

3099X60; asphalt

Burnett County Airport (RZN) Siren, WI

5000X75; asphalt

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.

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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)

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STS AVIATION RISK ASSESSMENT (See Risk Assessment Worksheet Section)

STS AVIATION MITIGATION SUMMARY

Pre-Mitigation Hazards

Count of Outcomes Outcome

System

High

Serious

Medium

Low Grand 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

System

High

Serious

Medium

Low Grand 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

System

High

Serious

Medium

Low Grand 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

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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

PROJECT AVIATION SAFETY PLAN BRIEFING

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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

mitigated?

Yes No NA

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

Dispatch (all participants)?

Yes No NA

14. Are all involved aware that the pilot has the final authority, but if any

passenger/aircrew/ground personnel feels uncomfortable, that they can refuse/curtail the

flight without fear of reprisal?

Yes No NA

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

completed?

Yes No NA

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

fuel?

Yes No NA

20. Remember; maps of areas/sites, handheld radios, cell phones, day/survival packs, sic

sacks

Yes No NA

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.

Signature: Date Pilot Signature: Date

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Project Maps

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MISHAP RESPONSE PLAN

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 PHONE

CELL PHONE

OH Wayne NF 740.624.2284 740-753-0571

740.516.3535 Dispatcher: OH-OIC Michele Stephens

IN Hoosier NF 812.547.9262 Terry Ceberson (FMO) 812.547.9247

Jackie Contreras (dispatcher) 812-547-9250

Dispatcher: Maggie Schuetter

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)

Fred Mascher – Center Mgr. (828.777.2075 cell)

828.257.4811 828.778.2077

Dispatcher: Diane Hinz

IA no NF George (Nick) Hough 414.297.1068

414.208.7570 Dispatcher: Nick Hough (R-9 Aviation Safety Manager)

1st call: 911 2nd call: FS Dispatch

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Forest Service Regional Aviation Contacts:

Regional Name E-mail Office Cell

R-8 Aviation Officer Jerry Perry [email protected] 770.237.1014 (1014)

478.804.1181

R-8 Aviation Safety Manager

James Keyes [email protected] 404-780-0590

R-9 Aircraft Maint. Safety Insp.

Dave Serena [email protected] 218.827.8228 218.780.9616

R-9 Pilot Insp. TBD

R-9 Aviation Officer Bob Madill [email protected] 414.297.3744 414.207.2224

R-9 Regional Aviation Safety Manager

George (Nick) Hough [email protected] 414.297.1068 414.208.7570

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

Crashed/downed aircraft

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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.

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.

Overdue aircraft

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Risk Assessment: STS Aerial Application of Mating Disruptants

26

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

System - Aircraft (FHP Aerial Application)

Avionics (for radios

see "Technology" tab)

Unplanned avionics failures (overheating,

faulty wiring, etc.)

Occ

asio

nal

Mar

gin

al

Med

ium

Have dual communications in the audio panel; users

prepared witch to alternate frequencies; have a spare

radio on site.

Rem

ote

Mar

gin

al

Med

ium

X

Contractor's application and communication/safety aircraft

utilitze at least two Comm radios controlled by an audio

panel. No history of radio problems in past perfromance on

similar FS contracts covering several million acres.

Lo

w

Unavailable or disfunctional emergency

locator (analog ELT systems will be

discontinued affecting most aircraft; not

required for P-137 but may be equipped) Rem

ote

Mar

gin

al

Med

ium

Switch to 406 MHz digital ELT systems before February 1,

2009; require digital ELT in all contracts; recommend ELTs

with real time or satellite flight following functionality

Imp

rob

able

Neg

ligib

le

Low

X

Contactor has 406 MHz digital ELT

Lo

w

Aircraft

Configuration

Emergency landing difficulty with

engine failure < 500' AGL

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Select appropriate aircraft based on project profile

considering risk factors such as maneuverability, glide

distance, emergency landing zone requirements and

potential crash footprint

Imp

rob

able

Cat

astr

op

hic

Med

ium

X

Contractor utilizes third generation, purpose-built, turbine

powered Air Tractor aircraft.

M

ediu

m

Contract may not accurately specify

application equipment, pesticide

formulation, and rates of application ( EPA,

NEPA & possibly state violations - env.

hazard, double applications, increases in

flight and ferry time)

Imp

rob

able

Neg

ligib

le

Low

Biology to dictate prescription and whether single or

multiple treatments, specify in project design and in

agency and state contracts including nozzle type, rate of

application, pesticide formulation, dose, droplet size,

swath width, and environmental parameters during

application

Imp

rob

able

Neg

ligib

le

Low

X

Contract accurately specifies application systems,

formulations and doses

Lo

w

Reduced visibility if aircraft not purpose

built for aerial application or if using bi-

wing Rem

ote

Cat

astr

op

hic

Seri

ou

s

Contracts use only aircraft designed and built for aerial

application, conduct reconnaissance for aerial hazards

prior to project, recognize bi-wing may not be the best

choice for some applications

Imp

rob

able

Cri

tica

l

Med

ium

X

Contractor utilizes third generation, purpose-built, turbine

powered Air Tractor aircraft with downsloping nose, large side

windows and upper turn windows for maximum visibility

during application. M

ediu

m

Performance

Standards- Fixed

Wing

Insufficient planning considering project

needs and aircraft capabilities (mission

profile, horsepower, etc.) Imp

rob

able

Cat

astr

op

hic

Med

ium

Contract to address minimum requirements: observation

aircraft capable of transporting a minimum payload of

530 pounds on a standard day at sea level and Power

loading not greater than 13.5 pounds, (aircraft with a

power loading greater than

13.5 pounds per horsepower (PPH) must be turbo-

charged), if multi-engine aircraft are used they shall

have 240-horsepower per engine, or more, unless

turbo-charged. Application aircraft must be Turbine

engine powered.

Imp

rob

able

Cri

tica

l

Med

ium

X

Contractor utilizes third generation, purpose-built, turbine

powered Air Tractor aircraft for application and appropriately

powered Cessna 182 for chase.

M

ediu

m

Overloading aircraft

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Perform load calculations based on weight of pesticide

formulation, weight of fuel and consider distance to

treatment area; download for pilots with minimal

experience

Imp

rob

able

Cat

astr

op

hic

Med

ium

X

Maximum load for the AT-400 or 500 aircraft (400-500 gallons

liquid or 3600-4500 lbs) far exceeds the maximum load the

disruptant hoppers can carry (450 lbs total); thus the aircraft

will never approach its maximum carrying capacity on this

project

Lo

w

High density altitude operations

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Match machine to task & environment, monitor weather,

reduce load

Imp

rob

able

Cat

astr

op

hic

Med

ium

X

Same as above

M

ediu

m

Page 27: 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

27

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Possibility of fixed wing operating near

stall speeds in downwind

turns/operations in general Freq

uen

t

Cat

astr

op

hic

Hig

h

Brief on heavy load, wind direction &

speed/downwind leg, avoid "high G" turns, pay

attention to winds

Occ

asio

nal

Cat

astr

op

hic

Hig

h

X

Contractor pilots are highly experienced in aerial application

over forested and mountainous terrain (> 5,000 hours).

H

igh

Terrorist or

malicious activity

Aggressive public, verbal or physical

threats (including gun threats) to do

harm Rem

ote

Cat

astr

op

hic

Seri

ou

s

Conduct effective outreach to the public; contact

emergency services (911) and state police to notify of

operations; assign a government Public Information

Officer and defer communications with the press to the

PIO; treat all threats as serious, know and brief on

procedures, have emergency contact information handy,

notify base of operations and pilots; obtain all physical

description info possible without placing self at risk

(name, address, description of person, vehicle and license

plate), follow up IMMEDIATELY with state law

enforcement and demand serious action!

Imp

rob

able

Cri

tica

l

Med

ium

X

State agencies conduct outreach to local officials and the

public prior to the project and again during implementation.

Emergency services (911, local LEO) also notified prior to and

during implementation.

YouTube will be monitored during project in an effort to catch

any threats.

M

ediu

m

Remote, unsecure work areas and service

landings (risk to containment, aircraft,

personnel… theft or damage to

aircraft/equipment… threat to public

safety)

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Adhere to Project Aviation Safety and Security Plans.

Contract addresses security in remote locations, security

plan required for both insecticide & aircraft/support

equipment… prop lock, fuel lock, chain of custody for

insecticide)

Imp

rob

able

Cri

tica

l

Med

ium

X

Contract requires night security. Contractor only uses

municipal airports (fenced) and provides security personnel

during non-working hours

Lo

w

Inspection &

Maintenance Existence of corrosion/fracture in aircraft

components due to weights and chemical

exposure (e.g.. Skids, landing gear, wing

struts/attach fittings)

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Partially mitigated by annual inspections per FAA part 91,

recommend increasing contractual requirement to 100hr

inspections (as in part 135), use only purpose built aircraft,

utilize carding procedures

Imp

rob

able

Cat

astr

op

hic

Med

ium

X

Contractor performs 100 hour inspections and utilizes third

generation, purpose built, turbine powered Air Tractor.

Carding procedures used.

Lo

w

Engine malfunction due to unforeseen

failure or insufficient maintenance

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Utilize electronic engine monitoring technology to

simplify cockpit workload, provide in-flight alerts of

critical exceedance, download data card with

performance history (aids analysis for scheduled or

unscheduled maintenance needs); adhere to FAA

requirements and manufacturer specs, stay current on

ADs and SBs, consider internet subscription for easy

access to daily updates such as through the AD Resource

System (or other) also providing maintenance-related ACs

and STCs

Rem

ote

Mar

gin

al

Med

ium

Electronic engine monitoring installed on two of contractor

aircraft, contractor has subscription for updates.

M

ediu

m

Aging aircraft and/or not identifying

inspecting critical stress points (aerial

application aircraft subject to multiple

cycles and maximizing payloads)

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Require and implement a Structural Health Monitoring

Program approved by the aircraft’s manufacturer. A copy

of the program shall be provided to the CO and agency

aviation inspectors.

Rem

ote

Mar

gin

al

Med

ium

X

Contractor performs 100 hour inspections and utilizes third

generation, purpose built, turbine powered Air Tractor.

M

ediu

m

Corrosion/fracture of spray tanks,

delivery components leading to leakage,

parts detaching Rem

ote

Cri

tica

l

Med

ium

Develop monitoring program for spray operations, critical

aircraft components and delivery system

Rem

ote

Mar

gin

al

Med

ium

X

Disruptant dispersal systems are thoroughly cleaned each day

at the end of operations

Lo

w

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28

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Insufficient daily cleaning of aircraft to

reduce corrosion (all aircraft)

Rem

ote

Cri

tica

l

Med

ium

Agency and state contracts require that all equipment

which comes in direct contact with the pesticides must be

kept thoroughly clean and free of residues and foreign

particulate matter, ensure adequate preflight/postflight

inspection, provide for containment of residue in contract

Imp

rob

able

Mar

gin

al

Med

ium

X

Contractor regularly pressure washes aircraft during

operations, often daily. The insides are cleaned at least three

times annually. The outsides are washed by hand and sponge,

soap, and water several times each season. The disruptants

used on this project are not corrosive

Lo

w

Unapproved modifications to equipment

or unapproved equipment

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Contracts to require a supplemental Type Certificate (STC)

or FAA field approval

Imp

rob

able

Cat

astr

op

hic

Med

ium

X

Contractor has STCs for their disruptant pods and any other

modifications.

Lo

w

Contract Aircraft

(common to both

State and Federal

operations = mix of

fixed and rotor wing,

CWN or Exc Use)

Minimally skilled pilots

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Contract requires 1500 hrs minimum for application pilot,

25 hrs in make/model used, 500 hrs experience in aerial

application & 200 hrs experience in typical terrain.

Imp

rob

able

Neg

ligib

le

Low

X

Contractor requires 5,000 hours minimum and 2500 hours

aerial application time.

Lo

w

Using incorrect aircraft type for terrain

(fixed vs. rotor wing)

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Project planning shall determine the type of aircraft

required, contracts may specify when important to do so.

Establish parameters for a/c type (e.g. some mountainous

terrain may be better suited for helicopter)

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Contractor respectfully submits that given the safety of

turbine helicopter compared to Pratt and Whitney powered

AT, there is never an instance when helicopters are safer. Use

pilot experience and smaller loads to mitigate mountaineous

terrain. M

ediu

m

Incentive to maximize flight time,

regardless if paid by acre treated or

hours flown Rem

ote

Cat

astr

op

hic

Seri

ou

s

Flight Managers & Project Supervisor need to be involved

in monitoring flight time and duty hours.

Imp

rob

able

Neg

ligib

le

Low

X

Flight hours/duty times for pilots is closely monitored and

enforced. Government personnel follow the same schedule

as contractor, so their duty time is also limited to 14 hours

per day with a mandatory rest day on the 7th day of

operations. Lo

w

Operations in densely populated/high

air traffic areas

Pro

bab

le

Cri

tica

l

Hig

h

Contractors must file Congested Area Plans with FAA.

Contractors must adhere to FAA requirements (i.e. some

FAA offices require rotor only, others may allow fixed

wing operations). Obtain and familiarize with

manufacturer's glide data. Simulate feather/dump/turn

and glide sequence for proficiency and recording GPS file

to document and aid Plan approval.

Pro

bab

le

Mar

gin

al

Seri

ou

s

X

FAA approved congested area plans (CAP) are required. The

Contractor has never been refused approval by FAA.

Contractor has a waiver to use a restricted category aircraft

near congested airways (14 CFR, Part 91.313 (e) 1, 2 and 3)

and an exemption to 14 operations over congested areas (14

CFR Part 137.51 (b) 4) based on the performance data and

safety history of turbine powered ATs. This simplifies and

streamlines the process of getting FAA approval for their

CAPs. M

ediu

m

Last minute contract changes, dropping

portions of blocks increases risk to

operational safety and to the public

Occ

asio

nal

Cat

astr

op

hic

Hig

h

If at all possible, leave the block as planned so flight

pattern and turns are not affaected. Do not edit blocks

the day before treatment.

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

SOP for this project includes finalizing all block

boundaries at least 2 weeks before implementation

M

ediu

m

There are no maintenance requirements

'per se' for aircraft operating under FAA

part 137, only the minimum requirements

per FAA part 91 (annual inspection) Pro

bab

le

Cat

astr

op

hic

Hig

h

Contract requirements include 100 hr inspection and

established TBO or TBO extension program through FAA

Occ

asio

nal

Cat

astr

op

hic

Hig

h

X

The contractor performs 100 hour inspections, utilizes the FAA

approved MORE TBO extension program and uses third

generation, purpose built turbine powered aircraft.

Se

rio

us

Page 29: 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

29

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Potential for reduced reliability of

reciprocating engines compared to

turbine-powered aircraft

Occ

asio

nal

Cri

tica

l

Seri

ou

s

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

design turbine-powered aircraft tend to have more power

and are more reliable, but does not always guarantee

better performance)

Rem

ote

Cri

tica

l

Med

ium

X

Contractor utilizes third generation, purpose built, turbine

powered AT aircraft for application but chase aircraft are not

turbine powered.

M

ediu

m

Too many or too few aircraft for

production needs/project area,

unsuitable spray platform for mission

profile

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Project planning determines type of aircraft and contracts

specify production rates (acres treated per hour) needed

to complete the project.

Rem

ote

Cri

tica

l

Med

ium

X

Contract specifies minimum required production rates for each

project area. Contractor routinely surpasses the required

production rates. The number of aircraft used in each project

area is tailored to the production required to complete that

project area on time.

Lo

w

No pre-application survey of area prior to

project for aerial hazards

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Contract requirement that all application pilots are

responsible for the reconnaissance of each area

before treatment.

Imp

rob

able

Cat

astr

op

hic

Med

ium

X

Observation aircraft pilots also recon each area prior to and

during treatment and remind application pilots of hazards each

time they re-enter a block with a load.

M

ediu

m

Fuel

Starvation

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Monitor quantity pumped during fueling, monitor flight

time and distance to services

Rem

ote

Cri

tica

l

Med

ium

X

Contractor has two levels of verification. 1) A meter is

installed on the fueling hose, the results of which are given to

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

installed in all cockpits and the pilot compares the two

figures. 2) Second verification through the single point

fuelding system which indicates when a tank has been filled

to the selected level. Loads are calculated after considering

ferry distance. M

ediu

m

Bad fuel (more likely in portable fuel

systems)

Rem

ote

Cri

tica

l

Med

ium

Ensure fuel is tested for type and quality prior to fueling.

Monitor quantity pumped. Ensure fuel filters are changed

as required by manufacturer.

Imp

rob

able

Cri

tica

l

Med

ium

X

Conractor only pumps fuel to application aircraft through it's

own fuel filtering and delivery system which is sampled

regularly.

M

ediu

m

Availability

Sense of urgency & pressure to perform

(pilot, manager, organization)

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Involve Supervisor, Program Manager & flight Manager in

all stages of planning and risk assessment.

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Environmental conditions for spraying are relaxed with

disruptants compared to liquid sprays; thus urgency to perform

is decreased. Contractor provides more than adequate

numbers of application aircraft and skilled application pilots to

meet specified production rates.

Program manager/COR will not tolerate performance

pressure to outweigh safety considerations M

ediu

m

Tendency to over utilize single

vendor/pilot & maximize flight hours due

to limited availability of other aircraft Rem

ote

Cat

astr

op

hic

Seri

ou

s

Flight Managers & Program Manager need to be involved

in flight hour/duty day monitoring. Adhere to contract

specifications regarding flight hour/duty limitations.

Imp

rob

able

Cat

astr

op

hic

Med

ium

X

Contractor provides extra aircraft to exceed the production

rates thus limiting the pressure to push duty times. Flight

hours/duty day times are monitored for each pilot and are

discussed daily so pilots can manage their loads to remain

within the duty limitations. M

ediu

m

System - Environmental (FHP Aerial Application)

Weather / Time of

Day

High wind, high temperatures, low

humidity (pesticide drift)

Freq

uen

t

Mar

gin

al

Seri

ou

s Contract specifies thresholds for allowable winds,

temperature & relative humidity, cease operations when

drift conditions exist

Occ

asio

nal

Mar

gin

al

Med

ium

X

Size of disruptant particles (flakes or SPLAT drops) is large

enough to minimize drift; humidity is not a factor.

Lo

w

Page 30: 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

30

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

High wind, low humidity, high

temperatures (affect on aircraft

performance) Freq

uen

t

Cat

astr

op

hic

Hig

h

Contract specifies performance requirements, conduct

load calculations/weight & balance; cease operations

when conditions out of parameter

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

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

certified to carry so overloading is not a factor.

M

ediu

m

Thunderstorms, lightening, hail, high

winds

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Suggest pilots utilize on-board, real time weather

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

program managers monitor weather stations provided at

airport office, use observation aircraft to help monitor

weather conditions

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Contractor has installed real time weather on all application

aircraft, mobile base has it's own DTN weather station,

observation pilots monitor weather conditions and program

manager also monitors weather.

Se

rio

us

Typically morning operations & in

shadows/glare conditions

Freq

uen

t

Cat

astr

op

hic

Hig

h

Preflight briefing to raise awareness

Pro

bab

le

Cat

astr

op

hic

Hig

h

X

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

and conclude at 4:00 PM well before sunset. Contractor plans

applications on North/South spray lines whenever possible to

mitigate shadow/glare problems. Se

rio

us

Topography or

High Altitude

Turbulence

Freq

uen

t

Cri

tica

l

Hig

h

Time application based on anticipated prevailing winds,

cease operations if unsafe/out of parameter

Rem

ote

Cri

tica

l

Med

ium

X

Med

ium

Terrain - box canyons

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Plan project/treatment block such that application

flight lines allow egress; brief pilot

Rem

ote

Cri

tica

l

Med

ium

X

M

ediu

m

High Altitude - density altitude

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Perform load calculations for departure and

destination

Rem

ote

Cri

tica

l

Med

ium

X

M

ediu

m

Remote Areas or Poor

Road Access

Lack of communications

Pro

bab

le

Cat

astr

op

hic

Hig

h

Test radio communications prior to project

implementation

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Contractor aircraft all have a minimum of dual coms with an

audio panel. Communications are checked prior to the

leaving the ground for each load. Occaisional issues with

agency/state ground to ground communications (poor cell

coverage) have been overcome by using observation pilots to

convey messages to ground personnel in blocks.

M

ediu

m

Long response time in event of search and

rescue

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Mishap Response Plan to address search and rescue

procedures, observation aircraft may be used to assist

guiding rescue vehicles/personnel to accident site; utilize

AFF

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Contractor utlizes Aventech satellite based real time AFF;

observation aircraft function as "eyes on application aircraft".

Se

rio

us

Page 31: 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

31

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Fuel starvation, proper fuel unavailable

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Monitor flight time/fuel consumption, utilize fuel trucks or

have optional fuel sources identified

Imp

rob

able

Cri

tica

l

Med

ium

X

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

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

pilot check concurence of aircraft fuel added by comparing the

loader meter with the pilot's on board meter. Initial radio

contact with base after take-off confirms fuel on board.

Contractor utilizes their own fuel trucks.

M

ediu

m

Unimproved landing strips or helipads

with poor dust abatement and/or poor

surface condition Rem

ote

Mar

gin

al

Med

ium

Contractor must obtain permission from airport manager,

airstrips must be accessible to vehicles, therefore mostly

utilizing developed airports (may use unimproved landing

strip only in event of emergency).

Imp

rob

able

Mar

gin

al

Med

ium

X

Contractor utlizes only public-use airports with hard

surfaced runways and ramp areas.

Lo

w

Biological Window

Prioritizing treatment timing based on pest

phenology above safety

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Contract specifications include adequate number of

aircraft to accomplish mission within biological window,

brief daily emphasizing safety over production, adhere to

flight and duty limitations

Rem

ote

Cri

tica

l

Med

ium

X

Contractor provides extra pilots/aircraft to exceed the

production rates thus limiting the pressure to push flight

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

for each pilot and are discussed daily so pilots can manage

their loads to remain within the duty limitations.

M

ediu

m

Airspace

Working within Military Operating Area,

potential mid air collision

Pro

bab

le

Cat

astr

op

hic

Hig

h

Contact flight service station or ATC to determine if active

and, if so, may request traffic advisories from the

controlling agency prior to entry; address during

premission planning and briefing

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

No MOAs within operating areas in 2019; government

personnel coordinate with military to deconflict MTRs

Lo

w

Working within or proximity to Military

Training Route, potential mid air collision

Pro

bab

le

Cat

astr

op

hic

Hig

h

Address during permission planning and briefing; keep

alert (application aircraft and observation aircraft);

contact flight service station to determine if active and, if

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

actual route width ; not all MTRs are published on

sectionals... obtain copy of AP1B for phone numbers to

military installations and contact schedulers to deconflict

MTR

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Government pre-clears all missions that intersect MTRs with

appropriate contacts in AP1B; maps posted in mobile office

showing MTRs with appropriate buffers overlaid on treatment

blocks.

Se

rio

us

Unable to establish TFR for

applications projects

Pro

bab

le

Cat

astr

op

hic

Hig

h

Post applications projects as NOTAM, remain aware of

potential for other aircraft to enter project area

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Observation aircraft constantly monitor the area for other

aircraft traffic and advise/warn application pilots

Se

rio

us

Military training operations distracting

application aircraft

Occ

asio

nal

Cat

astr

op

hic

Hig

h

COR/Project Manager & National Airspace Coordinator to

communicate "training" problem to military, describe

distraction to application operations and risk

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Se

rio

us

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32

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Inability to post NOTAMs due to FAA

office closures and difficulty identifying

contact point Occ

asio

nal

Cat

astr

op

hic

Hig

h

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

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

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

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

your communications base, 3) give operational details

(location, date/timing, duration of work); problems in

filing should be elevated your safety manager and FAA

superiors

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Observation pilots are responsible for checking NOTAMS and

DROTAMS prior to daily operations.

Se

rio

us

Working in proximity to/or within FTA or

TFR

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Typically avoid, however, Project Manager may request

permission to work within FTA or TFR if possible and

absolutely necessary, coordination between dispatch,

application pilot, and aerial supervision is required;

ability to "XM download" to on board GPS will help with

TFRs.

Rem

ote

Cri

tica

l

Med

ium

X

M

ediu

m

Restricted Areas (artillery firing, guided

missiles or aerial gunnery)

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Typically avoid, however, if necessary permission to enter

may be coordinated through ATC; know intercept

procedures, reference in contracts/prework and include in

daily briefings.

Rem

ote

Cri

tica

l

Med

ium

X

None of the spray activities will require flight in restricted

areas.

Lo

w

Prohibited Areas (e.g.. lack of coordination

prior to entering Camp David, White

House, Presidential Ranch…)

Rem

ote

Cat

astr

op

hic

Seri

ou

s

For all intents and purposes "permanently off limits" - try

to avoid.

Rem

ote

Cri

tica

l

Med

ium

X

No spray activities in prohibited areas in 2019

Lo

w

Mid Air collision while working within or

crossing Class B, C, D Airspace

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Observation and application aircraft remain aware of

other traffic, pilot request clearance, maintain

communication with ATC or tower as required

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Contractor aircraft all have a minimum of dual coms to

facilitate communications with local airports, regardless of the

airspace type. Both application and communications/safety

pilots are high time facilitating the ability to communicate

effectively while flying. Se

rio

us

Airspace in general - near miss/collision in

congested areas

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Communicate with & utilize observation aircraft, ATC,

etc... see and avoid, consider TCAS to warn of

transponding aircraft in proximity to application aircraft

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Columbus, OH area - meet with tower personnel at Port

Columbus Int. and OSU airport prior to treatment to

coordinate communications during project activities

Se

rio

us

Airstrip

Availability,

Condition and

Services

No alternative or suitable landing

location for emergency situations

Pro

bab

le

Cat

astr

op

hic

Hig

h

Identify emergency landing zones in advance (fields,

open areas, meadows)

Rem

ote

Cri

tica

l

Med

ium

X

Contractor delineates non-congested areas for off site landings

in every congested area. Google earth photos with these

delineations highlighted are provided to each pilot.

M

ediu

m

No alternative fuel source

Occ

asio

nal

Mar

gin

al

Med

ium

Call FBO/airport ahead of time to determine fuel

availability, use alternate airport or fuel tender

Rem

ote

Cri

tica

l

Med

ium

X

Contractor communicates fuel needs to FBO well in advance of

project and checks again several days before arriving for work.

Lo

w

One-way landing/departure

Pro

bab

le

Mar

gin

al

Seri

ou

s Be aware that preferred approach/departure based on

wind may not be an option, be aware of the potential for

oncoming air traffic Pro

bab

le

Neg

ligib

le

Low

X

Lo

w

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33

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

No windsock at landing zones

Freq

uen

t

Mar

gin

al

Seri

ou

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

available, ground support can call pilot with conditions

prior to landing, hang flagging Rem

ote

Mar

gin

al

Med

ium

X

Contractor utilizes only public-use airports with hard surfaced

runways and ramp areas as well as windsocks.

Lo

w

Effects of prevailing wind

Freq

uen

t

Mar

gin

al

Seri

ou

s

Know local conditions, retrieve automated weather

Freq

uen

t

Neg

ligib

le

Med

ium

X

Contract aircraft all have Garmin 496's with AWOS weather

data so the pilot can monitor all weather conditions.

Lo

w

Terrain/

Obstructions

Operations below 500' in either

helicopter or fixed-wing, potential to

impact terrain or obstruction - aerial

application typically 50-200 feet above

tree tops Fr

equ

ent

Cat

astr

op

hic

Hig

h

Contract specifications require FAA part 137-qualified

pilots. Maintain situational awareness, identify emergency

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

briefing, review aerial hazard map, contract specifies

reconnaissance of area prior to treatment

Rem

ote

Cri

tica

l

Med

ium

X

Contractor requires a minimum of 5000 hours of flight time

and 2500 hours of aerial application time for all application

pilots.

M

ediu

m

Animal activity

Potential for serious injury/aircraft damage

from birds

Occ

asio

nal

Cri

tica

l

Seri

ou

s

Know flyways, observation aircraft and ground support

to communicate avian activity if present in area

Rem

ote

Cri

tica

l

Med

ium

X

M

ediu

m

Potential for serious injury/aircraft

damage from wildlife on runway

(common at remote and county airports)

Occ

asio

nal

Cri

tica

l

Seri

ou

s

Ground support to clear runway, communicate activity

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

around runway perimeter

Rem

ote

Mar

gin

al

Med

ium

X

M

ediu

m

Containment &

Handling

No spill plan for fuel & chemicals, no

label and SDS for pesticide, no PPE

Rem

ote

Mar

gin

al

Med

ium

Contractor is required to have spill plan, contract requires

spill plan, follow pesticide label regarding PPE

Imp

rob

able

Neg

ligib

le

Low

X

Lo

w

Insufficient cleaning of tanks and delivery

components between projects, when

changing chemicals (env. hazard) Rem

ote

Cri

tica

l

Med

ium

Agency and state contracts require that all tanks and

pesticide delivery systems must be thoroughly cleaned

and free of rust, residues, and particulate matter, such as

grit and sand and will inspect all tanks before they are

filled with insecticide or water.

Imp

rob

able

Mar

gin

al

Med

ium

X

Contractor disruptant dispersal systems are specific to the

product they are designed to carry, thus cross contamination

of chemicals cannot occur. All dispersal systems are cleaned

prior to the contract and cleaned daily during operations.

Lo

w

Human exposure due to treatment

areas not posted

Rem

ote

Mar

gin

al

Med

ium

Treatment areas are posted on public lands only (not

necessary for private landowners requesting treatment),

roads may be closed on public lands at discretion of site

manager

Imp

rob

able

Neg

ligib

le

Low

X

No human healt hazards associated with mating disruptants

that contain the gypsy moth pheromone as the active

ingredient.

Lo

w

System - Personnel (FHP Aerial Application)

Pilot and/or vendor

Minimal local experience/unfamiliar with

area

Freq

uen

t

Cat

astr

op

hic

Hig

h

Preflight briefing, review aerial hazard maps, conduct

reconnaissance flights

Freq

uen

t

Mar

gin

al

Seri

ou

s

X

Contractor is generally familiar with all the project areas

because of work history (1998 to 2017)

M

ediu

m

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34

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

No current State Applicator License

Rem

ote

Mar

gin

al

Med

ium

Contracts require current State Applicator License… obtain

certification within all states where project is planned, be

aware that project may cross state lines

Imp

rob

able

Neg

ligib

le

Low

X

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

pilots and ground support are checked.

Lo

w

Minimal flight hours/mission hours

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Contract specifies number of hours by mission type

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

make/model), check flight log files & be aware possibility

exists for these to be falsified/unable to verify

Rem

ote

Mar

gin

al

Med

ium

X

Contractor requires a minimum of 5000 hours of flight time

and 2500 hours aerial application time. The firm works to

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

personnal minimums.

M

ediu

m

Inordinate attention to application,

impacting aerial hazards (new hazards

installed often, e.g. cell towers)

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Agency and state contracts provide aerial hazard maps of

known hazards, some states will GPS hazards prior to

project implementation, contract requires "all application

pilots are responsible and required for the reconnaissance

of each area before treatment"

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

This remains a serious concern because new hazards (e.g.

met towers) can pop up overnight and can be difficult to see

from the air during recon flights.

Se

rio

us

Coerced into uncomfortable situation

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Not all pilots equally skilled, do not pressure into

uncomfortable situations (encourage all to speak up)

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Contractor pilots require a minimum of 5000 hours of flight

time and 2500 hours aerial application time. The firm works

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

their personnal minimums. Program manager/COR does not

push for performance. M

ediu

m

Inadequate briefings from Project Manager

Occ

asio

nal

Cri

tica

l

Seri

ou

s

Address in work plan; contract requirement to hold

preseason, premission/daily, postmission briefings

Rem

ote

Mar

gin

al

Med

ium

X

Daily briefings and work planning session conducted in

conjunction with contractor and state

M

ediu

m

Lack of awareness leading to fuel

starvation

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Proper preflight planning, Project Manager & pilot

monitor flight time

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

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

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

pilot check concurence of aircraft fuel added by comparing the

loader meter with the pilot's on board meter. Initial radio

contact with base after take-off confirms fuel on board

M

ediu

m

Self-medication

Occ

asio

nal

Cat

astr

op

hic

Hig

h

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

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

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

operating equipment

Rem

ote

Cri

tica

l

Med

ium

X

M

ediu

m

Incomplete preflight inspection

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Pilot to utilize preflight check list, FAA requirement

Rem

ote

Cri

tica

l

Med

ium

X

M

ediu

m

Accepting unreasonable risk,

"barnstormer" attitude

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Preflight briefing to establish tone for the day, "aviation

program first, pest management second"

Rem

ote

Cri

tica

l

Med

ium

X

The contractor's firm has a strong culture of safety;

"barnstorming" attitude not tolerated.

M

ediu

m

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35

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Pilot incapacitated

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Contracts specify that pilot may be relieved of duties (in

event of sickness, under influence of alcohol or drugs,

insufficient rest/time off)

Imp

rob

able

Neg

ligib

le

Low

X

Contractor always has alternate pilots listed and carded so

replacement can be made if required. This lowers the

pressure to perform when sick.

Lo

w

Fatigue

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Contract specifies duty limitations and rest periods;

contract specifies contractor not allowed to do other

projects until completing current agency or state project;

assure enough personnel to support aircraft and project

schedule

Rem

ote

Mar

gin

al

Med

ium

X

Contractor provides extra aircraft and ground crew to mitigate

excessive work requirements.

M

ediu

m

Complacency

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Be aware that experienced pilots may tend toward

complacency… conduct morning safety briefings,

retain situational awareness throughout day

Rem

ote

Cri

tica

l

Med

ium

X

Contractor works to maintain a positive culture of safety which

includes candid discussion each day between all members of

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

M

ediu

m

Agency or State

Personnel

Exposure to increased risk by boarding

unauthorized aircraft (FAA part 137 not

carded for personnel transport) Rem

ote

Cri

tica

l

Med

ium

Most fixed-wing application aircraft seat pilot only,

federal and state personnel may not fly in restricted

category (FAA part 137) aircraft

Imp

rob

able

Mar

gin

al

Med

ium

X

Contractor application aircraft seat the pilot only so there is

no risk of agency personnel boarding the application aircraft.

Chase aircraft are Part 135 certified for passenger transport if

needed. Lo

w

Minimal experience with mission type

Pro

bab

le

Cri

tica

l

Hig

h

Include expert aviation and pest management

personnel in project planning, briefing and

implementation; train and mentor new employees

(subordinates and supervisors)

Occ

asio

nal

Cri

tica

l

Seri

ou

s

X

All FS personnel are experienced with this type mission and

current on training for roles on the project. State personnel

are also experienced with this type mission.

M

ediu

m

Undue pressure upon employees or

contractor to perform by Program

Manager/Supervisor Occ

asio

nal

Cat

astr

op

hic

Hig

h

Utilize crew resource management, all are

empowered to stop an unsafe act

Rem

ote

Cri

tica

l

Med

ium

X

Contractor and government safety plans empower each

staff member to come forward with any safety issue.

Program manager/COR will not exert pressure to perform.

"Its just a bug" is the mantra when pressure begins to build.

M

ediu

m

Exposure to risk for personnel if

participating in observation flight

Freq

uen

t

Mar

gin

al

Seri

ou

s

State and federal employees never ride in application

aircraft under FAA part 137 but may in observation aircraft

(federal requirements: pilot carding per FAA part 135,

monitoring personnel on board must be qualified Fixed-

wing Flight Manager or Helicopter Manager); consider

utilizing AFF to monitor operation

Freq

uen

t

Neg

ligib

le

Med

ium

X

Although chase aircraft are Part 135 certified and FS carded to

carry passengers, the project rarely if ever loads a passenger

in these aircraft. Field personnel, AFF and DGPS downlads are

used to monitor operations.

Lo

w

Fatigue (air or ground personnel)

Pro

bab

le

Cat

astr

op

hic

Hig

h

Outline project schedule within the RFP, proposals to

address how intended to meet production

requirements/assure adequte rest, recommend RFP

provide vendor weekly opportunity to specify changes to

state or ageny for review; Positive safety culture will

encourage adequate rest for all, appropriate number of

aircraft assigned to project; Responsibility of Project

Manager to ensure adequate rest for all personnel (crew

resource management)

Rem

ote

Mar

gin

al

Med

ium

X

Flight hours/duty times for pilots is closely monitored and

enforced. Government personnel follow the same schedule

as contractor, so their duty time is also limited to 14 hours

per day with a mandatory rest day on the 7th day of

operations.

M

ediu

m

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36

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Complacency (air or ground personnel)

Occ

asio

nal

Cri

tica

l

Seri

ou

s

Be aware that experienced project personnel may tend

toward complacency… conduct morning safety briefings,

retain situational awareness throughout day (crew

resource management)

Rem

ote

Mar

gin

al

Med

ium

X

M

ediu

m

Condoning unreasonable risk

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Complete Risk Assessment for each project; preflight

briefing to establish tone for the day, "aviation program

first, pest management second"

Rem

ote

Mar

gin

al

Med

ium

X

M

ediu

m

Training Lack of educational opportunities for

pilots and pilot operators that help

reduce aircraft and drift accidents Rem

ote

Cat

astr

op

hic

Seri

ou

s

Consider including in contract specs that all

application pilots must attend Professional Aerial

Applicator Support System (PAASS) certification

course

Rem

ote

Mar

gin

al

Med

ium

X

Contractor pilots complete at least one PAASS

certification course annually.

Lo

w

Minimal experience in areas with sporadic

application programs (particularly in west,

occasionally in east)

Freq

uen

t

Cat

astr

op

hic

Hig

h

Agency to support and fund aerial application and

safety training for all agency and state personnel,

implement mentoring program, share expertise

across regions

Occ

asio

nal

Mar

gin

al

Med

ium

X

All agency personnel are current on training and have high

experience with application programs

Lo

w

Lack of aviation awareness training and risk

management in general

Freq

uen

t

Cat

astr

op

hic

Hig

h

Consistent with the goals of the Aerial Application Safety

Council, develop and provide aerial application training

program (e.g., ACE training for agency & state personnel)

Occ

asio

nal

Mar

gin

al

Med

ium

X

All agency personnel are current on training and have high

experience with application programs

Lo

w

Flight Following

Personnel (typically

dispatch on FS

contracts, FS land)

Lack of mission understanding and

scheduled activities

Rem

ote

Cri

tica

l

Med

ium

Notify Dispatch of planned activities and provide Project

Aviation Safety Plan (PASP) for Agency contracts and Work

& Safety Plan for any state contracts in proximity to

National Forest

Rem

ote

Mar

gin

al

Med

ium

X

Flight following conducted on site by project personnel

Lo

w

Inconsistent flight following procedures

(for federal projects)

Occ

asio

nal

Cri

tica

l

Seri

ou

s

Agency follow established protocol… address flight

following procedures in PASP/communications plan

Imp

rob

able

Neg

ligib

le

Low

X

Flight following conducted on site by project personnel and

according to procedures outlined in PASP

Lo

w

Dispatch unavailable/inability to

communicate to center

Pro

bab

le

Cat

astr

op

hic

Hig

h

Establish flight following in the field using ground

personnel in treatment area - specify in communication

plan and utilize a combination of communication

methods (e.g., ground to ground, air to ground, cell

phone)

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Traditional radio flight following conducted by project

personnel on site at mobile bases. AFF required in

alpplication and chase aircraft and utilized as back-up.

Lo

w

Flight following personnel fatigued or

complacent

Occ

asio

nal

Mar

gin

al

Med

ium

Ensure adequate rest; follow agency protocol for duty

limitations, recommend similar for state contracts

Rem

ote

Mar

gin

al

Med

ium

X

M

ediu

m

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37

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Poor frequency management/frequency

congestion

Occ

asio

nal

Mar

gin

al

Med

ium

Coordinate with dispatch or communication technicians

to obtain additional frequencies and set up portable

repeaters if necessary

Rem

ote

Mar

gin

al

Med

ium

X

Contractor provides two discrete frequencies to enhance

communications and eliminate congestion.

Lo

w

Lack of staffing on weekends or outside of

flight hours

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Brief dispatch on operational periods, ensure

dispatcher staffing or flight following personnel

Rem

ote

Mar

gin

al

Med

ium

X

Project personnel conduct flight following on site at mobile

bases.

Lo

w

Jurisdictional/boundary awareness and

inability to maintain flight following

Occ

asio

nal

Cri

tica

l

Seri

ou

s

Circulate flight plan to all dispatch centers in project

area, communication plan includes all necessary

frequencies/brief pilot, assure handoff from one center

to next

Rem

ote

Mar

gin

al

Med

ium

X

Project personnel conduct flight following so hand off from

one center to another does not occur

Lo

w

Maintenance

Inspector (aircraft &

support vehicles)

Not current on maintenance issues for

specific aircraft that could lead to

accidents

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Regularly check for new Airworthiness Directives, stay

current on required training

Rem

ote

Cri

tica

l

Med

ium

X

M

ediu

m

Insufficient number of inspectors may lead

to fatigue, complacency, accepting or

transferring unreasonable risk

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Ensure adequate staffing, Project Managers attend aircraft

inspections

Rem

ote

Cri

tica

l

Med

ium

X

Project manager plans to attend carding in 2016

M

ediu

m

Oversight &

Coordination in

General

Lack of mission understanding among

RAOs/RASMs, FAOs, state directors, etc…

Pro

bab

le

Cat

astr

op

hic

Hig

h

Project Managers participate in key aviation or program-

related meetings, industry and user group events to

liaison/promote safety and efficiency; have current unit

aviation management and safety plan with key review

/approval routing for signature

Rem

ote

Cri

tica

l

Med

ium

X

RAOs/RASMs reviewed & approved aviation mgmt plan

M

ediu

m

Lack of trend information helpful in

preventing incidents/accidents

Pro

bab

le

Cri

tica

l

Hig

h

Expand knowledge & how to use SAFECOM system, should

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

gypsy moth cooperative suppression projects); periodically

query, review and report any trends

Rem

ote

Cri

tica

l

Med

ium

X

M

ediu

m

Lack of safety awareness and need to

further develop safety culture within

state and federal agencies Pro

bab

le

Cat

astr

op

hic

Hig

h

Encourage initiatives through the Aerial Application Safety

Council that foster interagency safety awareness (e.g.,

through training, presentations at annual meetings, close

coordination with other state and federal aviation staffs)

Rem

ote

Cri

tica

l

Med

ium

X

M

ediu

m

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38

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Lack of (or minimal) interagency

coordination on aerial application projects

that span private, state, and federal lands

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Host annual interagency coordination meetings (e.g.,

Gypsy Moth Program Managers Meeting includes all state

and federal agencies involved with gypsy moth)

Rem

ote

Cri

tica

l

Med

ium

X

This project spans private, state and federal lands and all

parties are briefed, well informed and involved in planning.

Lo

w

Contracting CO, COR/COTR turnover leading to lack of

mission understanding and shortage of

personnel performing oversight

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Include expert aviation and pest management personnel

as COTRs during contract development and

administration; train and mentor new employees (future

CORs, COTRs)

Rem

ote

Cri

tica

l

Med

ium

X

CO has previous contrract experience with pest suppression

contracts, contract specs were reviewed and approved by FS

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

years experience; Overlap of previous COR and current COR

provided mentorship on this contract

M

ediu

m

Short time frame from contract advertising

to implementation (impacts operating

season, quality of contract, limits

desirable/qualified bidders and awarded

contractor readiness)

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Begin drafting contract early enough to ensure that a

quality contract has been developed, draw highest

number of qualified bidders possible

Rem

ote

Cri

tica

l

Med

ium

X

Contract awarded 3 months prior to implementation

Lo

w

System - Technology (FHP Aerial Application)

AFF Not required in all projects, dispatch

centers do not have visual display of

application aircraft relative to other

aviation operations

Freq

uen

t

Cat

astr

op

hic

Hig

h

Utilize observation aircraft to monitor operations and alert

other aircraft that may approach project area, consider

including AFF requirement in state and agency contracts

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

AFF will be utilized in all application and chase aircraft and

monitored by project personnel; AFF is in addition to radio

flight following

M

ediu

m

Possible AFF antenna conflicts with

other antenna on aircraft

Rem

ote

Cri

tica

l

Med

ium

Maintain separation between antenna per manufacturer,

check that AFF is working prior to take off

Imp

rob

able

Neg

ligib

le

Low

X

Lo

w

When in use AFF may lead to a false sense

of security if user thinks dispatch always

knows location OR if dispatch thinks all

aircraft are visible Occ

asio

nal

Cat

astr

op

hic

Hig

h

Be aware that all aircraft are not visible to flight following

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

traffic control" (intended to augment radio

communication); maintain positive radio communication

at all times

Rem

ote

Cri

tica

l

Med

ium

X

M

ediu

m

AFF system failure in aircraft or on ground

at computer

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Always maintain positive radio communication, radio

checks/position reports are still required (may be at

greater time interval, 30 minute checks instead of 15

minute) per communications plan

Rem

ote

Cri

tica

l

Med

ium

X

Standard 15 minute radio check-ins will be maintained on top

of AFF.

Lo

w

Aircraft GPS Application aircraft flying in wrong area

and/or misapplication of pesticide

Occ

asio

nal

Cri

tica

l

Seri

ou

s

State and agency contracts require all application aircraft

have panel-mounted aerial application GPS; contract

requires application aircraft to return to base if GPS

malfunction

Rem

ote

Mar

gin

al

Med

ium

X

Aircraft monitored on AFF

Med

ium

Observation aircraft unable accurately

navigate to specific treatment area(s)

Occ

asio

nal

Cri

tica

l

Seri

ou

s

State and agency contracts require all observation

aircraft have at a minimum handheld GPS and

"...conveniently located for the pilot"

Rem

ote

Mar

gin

al

Med

ium

X

Contractor observation aircraft all have panel mounted GPS;

treatment blocks plotted on FAA sectional maps and

provided to observation pilots. Lo

w

Inexperienced users pay too much

attention to GPS (head in cockpit)

rather than flying the mission Freq

uen

t

Cat

astr

op

hic

Hig

h

Contract requires that application pilots must

demonstrate GPS proficiency (examples of flight files

working in similar operations)

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Contractor application pilots are all highly experienced

with and proficient in use of SatLoc DGPS

M

ediu

m

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39

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Cockpit clutter/loose equipment in

observation aircraft (handheld GPS with

wires for power and external antenna)

Occ

asio

nal

Mar

gin

al

Med

ium

Properly mount antenna, stow handheld GPS and cables

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

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

remove any protruding brackets that may cause injury)

Rem

ote

Mar

gin

al

Med

ium

X

M

ediu

m

Radios

No communications (in general) air-to-

ground, with other aircraft or dispatch

centers Rem

ote

Mar

gin

al

Med

ium

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

requires radio where there is a control tower at the

airport), describe communications needs in prospectus

and require through contract, describe in work & safety

plan, list frequencies and how to be used in

communications plan, ALWAYS practice see and avoid

Rem

ote

Mar

gin

al

Med

ium

X

Pre-flight radio checks each day

M

ediu

m

Inaccessible radios/controls, difficult to

operate

Imp

rob

able

Mar

gin

al

Low

Break from flight pattern to access radio and make

adjustments

Imp

rob

able

Neg

ligib

le

Low

X

All contractor aircraft have panel mounted radios within

convenient reach of the pilot. All pilots wear helmets with

speakers and boom mikes with push to talk buttons on the

stick for easy access. Lo

w

Panel mounted radios - bump controls

Imp

rob

able

Mar

gin

al

Med

ium

Use keypad/control locks

Imp

rob

able

Neg

ligib

le

Low

X

Lo

w

Flight crew unfamiliar with components

Pro

bab

le

Mar

gin

al

Seri

ou

s

Preflight to include familiarization & programming radios

Rem

ote

Mar

gin

al

Med

ium

X

Med

ium

TCAS

If not using TCAS: potential for midair

collision

Rem

ote

Cat

astr

op

hic

Hig

h

Use TCAS, continue practice of "see and avoid", apply

CRM

Imp

rob

able

Cat

astr

op

hic

Med

ium

X

Observation aircraft constantly monitor the area for other

aircraft traffic and advise/warn application pilots

M

ediu

m

If using TCAS: false sense of security that

all other aircraft have functioning

transponders

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Recognize that all other aircraft may not have functioning

transponders, continue practice of "see and avoid", apply

CRM

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Se

rio

us

If using TCAS: Signal interference,

antenna positioned too close to other

antennas

Occ

asio

nal

Cat

astr

op

hic

Hig

h

Follow manufacturer's installation requirements

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

Se

rio

us

Pesticide Delivery

System

Emergency dump valve malfunction

causing load to dump (misapplication of

pesticide)

Occ

asio

nal

Mar

gin

al

Med

ium

Inspect and assure functioning dump valves for helicopter

& fixed-wing

Rem

ote

Mar

gin

al

Med

ium

X

M

ediu

m

Hose to nozzle detaching, pesticide

misapplication (not aviation hazard)

Occ

asio

nal

Mar

gin

al

Med

ium

Preflight inspection to include examining pesticide

delivery components

Rem

ote

Mar

gin

al

Med

ium

X

M

ediu

m

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40

Pre Mitigation Post Mitigation

Sub-system

Hazard

Like

lih

oo

d

Seve

rity

Ou

tco

me

Mitigation

Like

lih

oo

d

Seve

rity

Ou

tco

me

M

itig

atio

n

Ach

ieve

d

Mit

igat

ion

No

t

Ach

ieve

d

Mit

igat

ion

No

t

Ap

plic

able

Additional Local Mitigation

Po

st M

itig

atio

n

Val

ue

Inability to jettison in event of emergency

Rem

ote

Cat

astr

op

hic

Seri

ou

s

Inspect and assure functioning dump valves for helicopter

& fixed-wing

Rem

ote

Cat

astr

op

hic

Seri

ou

s

X

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

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

can carry (450 lbs); thus the aircraft will never approach its

maximum carrying capacity on this project which mitigates

the need to dump in the event of an emergency.

M

ediu

m

Improper pesticide application rate

Occ

asio

nal

Mar

gin

al

Med

ium

Agency and state contracts specify all aircraft must be

equipped with an electronic flow metering system and

delivery system must be calibrated prior to project

implementation

Rem

ote

Mar

gin

al

Med

ium

X

Contractor application aircraft are calibrated multiple times

each season. Each load provides an additional calibration by

comparing the product loaded with the SATLOC acres applied.

Each pilot has the skills to adjust that calibration between

loads as required. Lo

w

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41

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 OF THE AERIAL APPLICATION OF MATING DISTRUPTION ON PRIVATE, FEDERAL, STATE LANDS

LACK OF KNOWLEDGE OF FSH 6709-11 AND 6709-12 REGULATIONS

BE FAMILIAR WITH FSH 6709-11 AND FSH 6709-12

* NOISE FROM AIRCRAFT ENGINES AND PUMPS

WEARING HEARING PROTECTION. REQUIRED FOR PILOT AND GROUND PERSONNEL

* PROPELLERS IN MOTION

USE EXTREME CAUTION. RESTRICT ACCESS TO AUTHORIZED PERSONNEL ONLY. DO NOT APPROACH AIRCRAFT UNTIL PROPELLER IS STOPPED. ASSURE PILOT RECOGNITION BEFORE APPROACHING AIRCRAFT.

* EYE NJURIES WEAR GOGGLES

*

*

* SMOKING AND OPEN FLAME

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

* EYE INJURY FROM DUST AND DEBRIS FROM AIRCRAFT ROTORS

HAVE PERMANENT OR PORTABLE EYEWASH FACILITIES AVAILABLE ON SITE.

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42

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

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43

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.

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44

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.

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45

2019 Organization Chart

Contracting Officer Melissa Johnson

Contracting Officer's Representative (COR)

& Project Aviation Manager Tom Coleman

FS Aviation R8 RAO - Jerry Perry

R8 RASM - Jimmy Keyes

R9 RAO - Bob Madill

R9 RASM - George (Nick) Hough

R9 Aircraft & Pilot Inspectors

Contract Inspectors L. Haavik, A. Hill, D. Leonard

State Cooperators

NC - C. Elder

VA - L. Bradfield

OH - D. Adkins

IN - P. Marshall

WI - C. Foelker

IA - T. Feeley

Forest Dispatch

Block Monitors & Aerial Observers

Contractor

Al's Aerial Spraying

Al Schiffer

Pilots

Ground Crew

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46

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.

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47

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.

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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).

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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

Project Areas Polygon Acres Estimate of

Treatable Acres # Blocks Estimated Start Date

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

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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.

Project Area Airport A/P ID

Address Contact Phone #

NC Piedmont

Danville Regional Airport

DAN

424 Airport Drive Danville, VA 24540

Marc Adelman

434-799-5110

Mountains VA/NC & Study Plots

Mountain Empire Airport

MKJ 8223 Lee Highway Rural Retreat, VA 24368

Brian Burkett 276-783-8805

Central Ohio Zanesville Municipal Airport

ZZV 840 Airport Rd, Zanesville, OH 43701

Jim Witte

740-452-3625

Southern Ohio Fairfield County Airport

LHQ 3430 Old Columbus Rd Carroll, OH 43112

Pat Rooney Lonnie Watts

740-654-7001

Northern Ohio Putnam County Airport

KWX 10218 County Rd 5H Ottawa, OH 45875

Kent Niese 419-523-3910

Illinois Albertus Airport FEP 1255 E Airport Rd Freeport, IL 61032

Darrell Janssen 815-232-1078

Southern WI/Iowa Boscobel Airport OVS 1006 Wisconsin Avenue Boscobel, WI 53805

Steve Wetter 608-375-5232

Iowa Prairie Du Chien Municipal Airport

PDC 37735 US-18 Prairie du Chien, WI 53821

Richard Yeomans

608-326-2118

Central WI La Crosse Regional Airport

LSE 2850 Airport Dr La Crosse, WI 54603

Clint Torp 608-789-7456

Central WI Chippewa Valley Regional Airport

EAU 3800 Starr Ave., Suite 1 Eau Claire, WI 54703

Charity Zich 715-839-4900

North central WI Solon Springs Municipal Airport

OLG 12285 S US Hwy 53 Solon Springs, WI 54873

Neil Mathison

218-348-3176

Northern WI Burnett County Airport

RZN 7410 Co Rd K Siren, WI 54872

Nathan Ehalt 715-349-2181 After hrs: 715- 222-1702

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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

OH David Adkins [email protected] 614.387.0907 W614.282.9867 P614.404.6388

740.869.3150

Brian Burke [email protected] 614.995.1487 614.271.7748 614.995.1487

IA Tivon Feeley [email protected] 515.725.8453 515-669-1402

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

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Kevin Carpenter [email protected] 919.733.2483 x 224

919.218.2531

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

WI

Chris Foelker [email protected] 608.224.4581 608.422.1121 608.852.7191

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

R9 George (Nick) Hough

[email protected] 414.297.1068 414.208.7570

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

WV Timothy L. Brown [email protected] 304.558.2212 304.550.3887

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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.

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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.

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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.

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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

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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

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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.

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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

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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.)

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

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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

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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

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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

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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. .

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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.

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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.

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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

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

Net Contents: Lbs Kg Batch Number:

GM -O™

For Mating Disruption of Lymantria dispar, gypsy moth

SPLAT (Specialized Pheromone & Lure Application Technology) is an amorphous polymer matrix for the sustained release of insect pheromones. SPLAT GM-O provides control by disrupting mating behavior.

For Organic Production

EPA Reg. No. 80286-12 EPA Est. No. 80286-CA-004

KEEP OUT OF REACH OF CHILDREN

CAUTION

See side/back panel for additional precautionary statements.

FIRST AID STATEMENT

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.

IF ON SKIN OR CLOTHING: • Take off contaminated clothing. • Wash skin immediately with soap and water, then rinse with plenty of water for 15-20 minutes.

IF SWALLOWED: • Call poison control center or doctor immediately for treatment 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.

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).

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cylinders, or a combination of both. The flow of SPLAT GM-O product can be controlled with agricultural-type solenoids. Calibrate applications based on volume output and application speed and swath area treated. Do not apply this product through any type of irrigation system. SPLAT GM-O can also be applied manually using other devices like a metered dosing gun. To ensure proper application, consult your pest control advisor, distributor, or ISCA Technologies, Inc.

POINT For ground applications, SPLAT GM-O dollop size can be varied depending on pest SOURCE SIZE, population and duration of control desired. A dense infestation will require a higher density PLACEMENT, of point sources to achieve optimal mating disruption. With aerial applications, there is AND SPACING less control over the variation in droplet size and there will be a range from approximately

300 to 2000 microns in size. When SPLAT GM-O is sprayed on the tree canopy at 46

grams per acre (6 grams AI per acre), the range in droplet size will usually be 300 to 1000 microns. This will provide area-wide, season-long management of low-density populations. To ensure proper application, please consult your pest control advisor, distributor, or ISCA Technologies, Inc.

CLEANING Clean equipment with water and citrus or limonene detergents. EQUIPMENT

STORAGE AND DISPOSAL

Do not contaminate water, food or feed by storage and disposal.

PESTICIDE Store product sealed and refrigerated, if possible. If refrigerated, do not store with food. If STORAGE 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. In case of leak or spill, wipe with paper towel and dispose of waste when product hardens.

PESTICIDE Wastes resulting from the use of this product may be disposed of on site or at an approved DISPOSAL waste facility.

CONTAINER Nonrefillable container. Do not refill or reuse this container. Triple rinse (or equivalent) DISPOSAL promptly after emptying. Then offer for recycling if available, or puncture and dispose of in

a sanitary landfill, or by incineration, or, if allowed by state and local authorities by burning. If burned, stay out of smoke.

WARRANTY AND LIMITATION OF DAMAGES

Read all directions carefully. All statements concerning the use of this product apply only when used as directed. ISCA Technologies warrants that this material conforms to the specifications on the label and is reasonably fit for the intended purpose referred to on the label. To the extent consistent with applicable law, ISCA Technologies makes no other express or implied warranty of merchantability or fitness for a particular

purpose or any other express or implied warranty.

PRECAUTIONARY STATEMENTS

HAZARDS TO HUMANS AND DOMESTIC ANIMALS, CAUTION: Causes moderate eye irritation. Harmful if

swallowed or absorbed through skin. Avoid contact with skin, eyes, or clothing. Wash thoroughly with soap and water after handling and before eating, drinking, chewing gum, using tobacco, or using the toilet. Remove contaminated clothing and wash before use.

PERSONAL PROTECTIVE EQUIPMENT (PPE): 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 HAZARDS: 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.

DIRECTIONS FOR USE

It is a violation of Federal Law to use this product in a manner inconsistent with its labeling. Always consult your pest control advisor, distributor or ISCA Technologies, Inc. for advice regarding the use of SPLAT GM-O.

GENERAL SPLAT GM-O uses the pheromone of the gypsy moth (Lymantria dispar), to disrupt adult moth mating and thus reduce larval damage to trees.

TARGET PEST Gypsy Moth (Lymantria dispar)

AREA-WIDE CONTROL

This product is only for use in wide-area gypsy moth control programs sponsored by government entities. Areas of application include, but are not limited to: forests; residential, municipal, and shade tree areas; recreational areas such as campgrounds, golf courses, parks, and parkways; ornamental and shade trees; shelterbelts, rights-of-way; and other easements. Area-wide or wide-area application of SPLAT GM-O is most effective. The efficacy of any mating disruption strategy will be reduced by the influx of adults from surrounding areas. It is for this reason that mating disruption works increasingly well with larger acreages, where the ratio of exposed borders to overall area treated is reduced. Always make application of SPLAT GM-O in consultation with your pest control advisor, distributor, or ISCA Technologies, Inc. No intentional food uses are permitted. However, an exemption from the requirement of a tolerance is established for residues of (Z)-7,8-epoxy-2-methyloctadecane (Disparlure) on all food and feed crops that occur when it is used to treat trees, shrubs, and pastures and such use results in unintentional spray and drift to non-target vegetation including non- food, food, and feed crops.

ISCA Technologies, Inc. 1230 Spring St., Riverside, CA, 92507 951-686-5008 www.iscatech.com

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 TIMING

APPLICATION CONDITIONS

APPLICATION RATE

PREPARATION FOR USE

APPLICATION

EQUIPMENT

Apply SPLAT GM-O anytime in the two weeks preceding male flight and adult activity.

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.

Apply SPLAT GM-O when the ambient air temperature is above 50°F. SPLAT GM-O will

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.

The application rate of SPLAT GM-O ranges from 23 grams to 230 grams of undiluted

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.

Always check SPLAT GM-O 24 hours before using. If SPLAT GM-O has been stored in a

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.

SPLAT GM-O is applied either aerially or by ground with conventional application systems

pressurized either by centrifugal pumps or positive displacement pumps, pressurized gas

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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 Product Code: Splat GM-O

Recommended Use: For the control of Gypsy Moth, 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.

1230 Spring Street Riverside, CA 92507 www.iscatech.com

Emergency Phone Number: 951 686 5008

Section 2: Hazard Identification

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

Hazard Pictograms:

GHS07

P102 - Keep out of reach of children P103 - Read label before use

Precautionary Statements: P305+P351+P338 - If in eyes: Rinse cautiously with water

for several minutes. Remove contact lenses, if

P270 - Do not eat, drink or smoke when using this product P233 - Keep container tightly closed. P264 - Wash hands, forearms, and exposed areas

thoroughly after handling. P280 - Wear eye protection, protective clothing,

protective gloves P303+P361+P353 - IF ON SKIN (or hair): Remove/Take off

immediately all contaminated clothing. Rinse skin with water/shower

P304+P340 - IF INHALED: Remove person to fresh air and keep comfortable for breathing

present and easy to do. Continue rinsing P312 - Call a POISON CENTER or doctor if you feel unwell P337+P313 - If eye irritation persists: Get medical

advice/attention P403+P233 - Store in a well-ventilated place. Keep

container tightly closed P235 - Keep cool P501 - Dispose of contents/container according to local,

regional, national, and international regulations

SECTION 3: Composition/information on ingredients Active Ingredient

Name CAS # Molecular Mass

Molecular Formula

Chemical Name GHS-US Classification

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 Mass

Molecular Formula

Chemical Name GHS-US Classification

Splat GM-O Not applicable (mixture)

Not applicable

Not applicable

Not applicable H305, H316, H320, 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

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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.

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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

n-octanol/water: Log P: 8.540±0.253 Temp: 25ºC

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,

grease-like consistency Specific Density: 0.93 g/cm

3 Temp: 25 °C

Odor: Waxy, fatty Partition coefficient n-octanol/water:

Data not available

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.

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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.

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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.

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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]

© 2017 ISCA Technologies, Inc. All rights reserved.

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.

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

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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]

© 2017 ISCA Technologies, Inc. All rights reserved.

Page 2 of 2

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.

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


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