TECHNICALLY SPEAKING: An Open Letter to Sen. Barbara Boxer

Talk about picking a no-lose situation, U.S. Sen. Barbara Boxer (D-Calif.)! The legislation you introduced last year, which proposed to ban the preventive application of any pesticide containing a known or probable carcinogen, a category I or II nerve toxin or a pesticide of the carbamate, organophosphate and organochlorine class as identified by the U.S. Environmental Protection Agency (EPA) on property owned or managed by the Department of Defense (DoD), fits the bill. Your implication that DoD uses these products in their pest management program and "nukes" pests with these "horrific" products until they glow, thus, endangering the welfare of children, military personnel and the environment, is a gross injustice to one of this country’s leaders in pest management.

Why is this a no-lose situation for you and your colleagues? The DoD already is and has been for almost 30 years, in compliance with the proposed legislation. As a senator, you also know that DoD personnel cannot lobby against your amendment and, therefore, the legislation faces little opposition except from your more astute colleagues who took the time to investigate pest management practices within DoD.

Madam Senator, I can speak about the DoD pest management program from experience, having served for 22 years in the U. S. Army as an entomologist and pest management professional. I will share with you some facts about the DoD pest management program that, perhaps, my military and DoD civilian successors cannot.

Since 1956, the DoD pest management program has been shaped by more than 1,000 pest management professionals serving on the Armed Forces Pest Management Board (AFPMB). The mission of the AFPMB is "to ensure that environmentally sound and effective programs are present to prevent pests and disease vectors from adversely affecting DoD operations." This mission has been fulfilled in the most environmentally sound manner and with every consideration given to the safety (i.e., use of least-toxic materials) of military personnel and their dependents, including their children.

CERTIFICATION AND TRAINING. DoD established a training and certification program for pest management professionals before EPA was conceived. The DoD training program requires one year of on the job training and nearly four weeks of classroom training at a DoD training center. No civilian or government agency requires a more rigorous training program. Further, a four-day recertification course is required every three years at a DoD training site. The training program was founded on the principles of Integrated Pest Management, which has been taught at least as far back as 1979 when, for three years, I was an instructor at the Academy of Health Sciences at Ft. Sam Houston in San Antonio, Texas. A DoD goal has been to have 100 percent trained and certified pest management professionals. While this goal has not yet been met, DoD far exceeds the percentage of certified individuals compared to other government agencies.

REGULATORY COMPLIANCE. DoD has always been a leader in regulatory compliance. As early as the mid-1970s, we were inspecting military pest management operations throughout the U.S. and overseas for compliance with FIFRA and the new regulations promulgated as a result of the formation of EPA. Emphasis was, and continues to be, placed on proper storage and handling of pesticides, development of installation IPM plans and use of pest management strategies and products which minimize hazards to humans and the environment.

PESTICIDES. Regarding class I and II carcinogens, I am not aware, from my military experience, that DoD approved any products for use that fit this characterization (i.e., unless it was after the fact), nor did they permit their use on DoD property. The military ceased preventive pesticide applications more than 20 years ago. Organochlorines have not been used on military installations since chlordane use was suspended on April 15, 1988. The AFPMB’s Pesticides Committee, typically consisting of 15 pest management professionals, closely reviews research and toxicological data on products being considered for use by the DoD. In fact, many federal agencies procure pesticide products through the Defense Supply Agency, which takes its procurement direction from the committee.

RESEARCH AND DEVELOPMENT. The following are some R&D accomplishments made by DoD:

Mosquito Abatement: Much of the technology for mosquito abatement programs was derived from USDA and DoD research and field experience dating back to WWII. Much of the ultra-low volume techniques and equipment for adult mosquito abatement was developed by or for military operations. Not surprisingly, the goal of these developments was to minimize environmental impacts while conserving the fighting strength of our troops by protecting them from vector-borne diseases.

Repellents: Most of these products were and continue to be exclusively developed under the direction of AFPMB’s Repellents Committee and by DoD research initiatives. DoD synthesized active ingredients for repellents, developed the toxicological and efficacy data and field tested most of the products commonly used today. Repellents offer better protection than area-wide spraying against vector-borne diseases, e.g., Lyme disease, malaria, dengue, etc., as well as from annoying insect bites. The use of repellents significantly reduces the introduction of other pesticides into the environment and the risk of nonelective exposure to these products.

Reduced Risk Pest Management Strategies: DoD has been a longstanding proponent of reduced risk pest management strategies that minimize the use of pesticides. The DoD has led in the development of heat treatment. The Department has supported the concept of precision targeting which uses pest monitoring and computer technology to determine the foci of pest infestations and then targets the application of small amounts of pesticide to remedy the problem.

EPA PARTNER. The DoD was one of the first partners with EPA to commit to the implementation of reduced risk pest management strategies and a reduction in pesticide use. In 1995, the DoD made a commitment to reduce pesticide use by 50 percent by the year 2000, a goal that was exceeded and achieved well ahead of schedule.

Unfortunately, Madam Senator, I think you are trying to make a name for yourself at the expense of a premier pest management program that has always looked after the well being of its constituents. If you want to do something constructive and leave a meaningful legacy, please support legislation which ensures the continuous funding and operation of USDA’s Medical and Veterinary Research Laboratory, Gainesville, Florida, which supports the DoD pest management program and develops IPM technology for the structural pest management industry.

The author is technical director of American Pest Management, Takoma Park, Md. He can be reached at 301/891-2600 or via e-mail at rkramer@pctonline.com.