More than a year ago, the state of Maryland passed a law mandating Integrated Pest Management in schools. In September 1999, the regulations implementing the law took effect. The most notable aspects of this regulation are as follows:
• All parents of elementary schoolers must be notified 72 hours prior to pesticide applications in public schools.
• Excepted from notification are containerized baits (gel and granular baits require notification).
A GOOD EXAMPLE? Reportedly, Montgomery County, which has been cited for its reduction in pesticide use, is one of the leaders in IPM within Maryland. Last spring, my wife, who works in a Montgomery County elementary school, discovered an American cockroach infestation in her office. Her school requires that the school principal as well as the head of building services be notified. In turn, they notify the county pest control office. In the adjoining classroom there was another pest problem, an ant/termite look-alike, at the threshold of the exterior door.
Several days after my wife reported the infestation, a pest management individual from the county arrived to distribute sticky traps and to make a few applications with Spray 9. My wife asked him what product he was using. Unaware that she had extensive knowledge of pest control, the individual implied that the Spray 9 would kill the cockroaches.
After reading the label on the Spray 9 bottle, my horrified wife exclaimed to him, "But this is a disinfectant, not a pesticide!" The label contained the following information:
• Active Ingredients:
• n-alkyl dimethyl benzyl ammonium chloride 0.15%
• n-alkyl dimethyl ethylbenzyl ammonium chloride 0.15%
• Inert ingredients (contains detergents and grease-cutting agents) 99.7%
• Keep out of reach of children
• Signal word: Caution
• Hazards to humans and domestic animals. Caution. Causes moderate eye irritation. Avoid contact with eyes and clothing. All treated items that come in contact with this product must be rinsed with potable water before reuse.
• When spraying avoid contamination of food.
• It is a violation of federal law to use this product in a manner inconsistent with its labeling.
A COMPARISON. The label on one of the most widely used baits in structural pest management says the following:
• Active ingredients, fipronil, 0.01%
• Inert ingredients, 99.99%
• Keep out of reach of children
• Signal word: Caution
• Hazards to humans and domestic animals. Keep gel away from foods and food-contact surfaces. Harmful if absorbed through the skin. Causes moderate eye irritation. Avoid contact with eyes, skin and clothing.
• It is a violation of federal law to use this product in a manner inconsistent with its labeling.
Despite the similarity of the labeling on these products, the bait containing fipronil cannot be used in Maryland schools without notification. Furthermore, Spray 9 can be applied directly to all exposed surfaces, whereas bait applications must be to spots and/or cracks and crevices. What is wrong with this picture? The Maryland law is wrong, however, it is more wrong to knowingly violate laws governing pesticide use.
BREAKING THE LAW. The "pest management strategy" used by this individual circumvented Maryland law. The use of Spray 9 did not require 72-hour notification because it is considered a disinfectant and not a pesticide. Obviously the school’s exterminator has found away to avoid notification and get the job done. This approach to circumventing notification requirements is flawed in several ways:
• Spray 9 is not an insecticide and has no demonstrated efficacy in controlling cockroaches.
• There are no directions on the Spray 9 label that indicates how an exterminator should apply it in a classroom.
• Spray 9 contains active ingredients that are applied at a total concentration of 0.3% in comparison with baits and even sprays that are applied at 0.05% directly into cracks and crevices.
Pest management professionals should consider the consequences of such practices carefully. Consideration must be given to the practices we use. We cannot pull any product off the shelf that we think will kill bugs and apply them in order to beat the law.
Many of us could find products in our garages that we could apply to kill cockroaches, e.g., solvents, lubricants, disinfectants, acids, bases, mineral spirits, etc. Since no law or label prohibits such applications, one could justifiably argue that there is no reason not to use these products, particularly if their use avoids the need for notification.
As pest management professionals, we are ethically and legally bound to follow state and federal laws. We have an ample arsenal of products that can safely manage pests within schools. If their use is deemed essential, we should submit to the notification requirements regardless of how onerous they seem. We should:
• Apply only registered pesticide products inside buildings;
• Follow label instructions regarding site of application, application techniques, mixing, etc.;
• Comply with all state and federal laws and regulations;
• Maximize the use of nonchemical strategies, e.g., vacuuming, sticky traps, exclusion, etc., in sensitive accounts;
• Educate the customer, and;
• Encourage good sanitation practices and the removal of clutter.
The intent of this article is not to discourage PCOs from being creative in solving problems. But we must be creative in solving pest problems, lead by example and abide by the law.
The author is technical director of American Pest Management, Takoma Park, Md. He can be reached at rkramer@pctonline.com or 301/891-2600.
