MCAG PRE-CONSTRUCTION-DESIGN HACCP PROCEDURES

Revised 02.06.2019

The following measures shall be employed by the contractor in order to avoid or minimize the
potential for the spread of invasive species.

1. All equipment/cargo are inspected prior to loading and unloading of material onto
vehicles that will enter project site. All personnel, vehicles, cargo material, and
equipment shall be inspected prior to entry and exit of the project site at the
designated wash down station as described in Item 3.
2. Equipment and vehicles shall be clean prior to entrance onto project site.
3. Inspector must be trained in HACCP in order to ensure that he/she aware of the
potential species that could be encountered. Visual inspections must be carried out
on the following vector at the wash-down station located at the entrance of the project
site.
A. Personnel (e.g. boots, clothes, backpacks)
B. Handheld equipment (e.g. topographic survey equipment, hand augers,
machete, bush cutter, chainsaw)
C. Materials (e.g. wooden stakes, rebar, PVC pipes, pallets)
D. Heavy equipment (e.g. drill rig, detachable drills, backhoe, mulcher)
E. Truck bed/tray/bucket
o Undercarriage (platform, top of spring shackles, axle)
o Wheels and tires (tire treads, inside wheels and wheel wells, between
brake drum and rim of wheel and between dual wheels)
o Body (front grill, all ledges under bumpers, front and quarter panels and
boxes, ledges of frame cross members)
- Letters that correspond with pathway shall follow proper corrective action to
follow dependent on non-target found.

Corrective Actions:
- Vegetation – Mechanically remove by hand and brush (A, B, D,E)
- Vegetation – Mechanically remove and pressure wash (D,E)
- Soil – Mechanically remove and wash (A, B, C)
- Soil – Mechanically remove and pressure wash (D, E)
- Little Fire Ant – Re contact MCAG EV POC immediately.
- Insects – spot treat in place (A, B, C, D, E)
- Insects, mud tunnels, nests, larvae – Mechanically remove and/or spot treat with
non-systemic insecticide or pesticides.
If non-targets are found during inspection personnel must follow corrective action
deemed appropriate for non-target: wash, pressure wash (psi 90), mechanically clean
or spot treat prior to entering or leaving project site. Keep a daily log of inspections and
note if non-target was found on what type of equipment and type of corrective action
used and provide copy of inspection forms to MCAG Environmental POC at the end of
each work week.

3. Personal vehicles will only be permitted to park in the designated parking area. If
vehicles must enter the Project Site (other than the designated parking areas), they
must be inspected and cleaned as described in Item 3.

4. All vehicles are deemed clean if dirt free with no signs of non‐targets or their signs (such
as tree branches, spider webs, scats, grass, nests, mud tunnels etc.).

5. Washing will occur at the designated wash area and Contractor shall provide location of
wash station. The wash station will be regularly cleared of collected waste sediment
 and potential non‐targets, treated when appropriate and excess debris taken to a landfill
or other approved waste disposal location.

6. A catchment system must be in place to prevent runoff. Mechanical cleaning can be

achieved with a broom, stiff brush, scraper, vacuum cleaner or wet‐vac etc. and will be
collected and disposed. Spot treatment of invertebrates may be necessary using
Piperonyl butoxide (min 0.7 ppm), Pyrethrin (min 0.05 ppm), Permethrin (min 0.075
ppm) or a combination thereof. Other broad spectrum non‐systemic insecticides,
pesticides or herbicides may be substitutes when appropriate. All safety procedures
and guidelines will be observed when handling hazardous materials. All chemical
usage shall be recorded on the NAVFAC Online Pesticide Reporting system and shall
follow all Environmental Protection Agency (EPA) labeling requirement/instructions and
all Guam Environmental Protection Agency (GEPA) usage and certification
requirements. NAVFAC Online Pesticide Reporting System: https://noprs.pestlogics.com

7. Certain materials such as PVC pipes and pallets are considered high risk because
they have cavities where non‐targets can hide. Where possible, these types of materials
should be stored in containers to prevent non‐targets from coming in contact with them.
All construction material and equipment stored at staging areas are thoroughly inspected
prior to transport to the project site. No contaminated materials will be brought on site.

8. All food shall be consumed in the designated break areas or off the project site and
all trash is placed in the correct waste receptacles.

9. Trash shall be emptied regularly, seal bags/containers and remove from site to decrease
risk of attracting non‐target species. Ensure lids on trash containers are properly closed
at all times to prevent non‐targets from entering trash containers.

10. Green waste will be handled by the contractors at designated laydown areas within the
limits of construction. If green waste is produced, Coconut Rhinoceros Beetle and Little
Fire Ant Management Procedures (2016) shall be followed. All processing permits for
solid waste shall be obtained by the contractor.

11. Green waste shall be processed within 30 days of stockpiling in designated laydown
area/s. Contractor shall provide location of laydown area.

12. All green waste shall remain within the project site.

13. Ensure the proper construction and placement of silt/gravel bag fences to avoid runoff
and possible contamination of adjacent sites.

14. Demarcation prior to activities shall be established and verified by biomonitor prior to the
start of intrusive activity. This measure will be implemented during pre-construction,
construction, and operations.

15. All contractor personnel will attend a Department of Navy (DON) sponsored contractor
education program for natural and cultural resources in the project area including
invasive species, special-status species, avoidance measures and reporting
requirements. This measure will be implemented during pre-construction, construction,
and operations.