In one professional’s opinion, the pest control industry will continue to be the target of EPA’s pesticide restrictions despite its best practices.
Perhaps the day will come when organizations such as the National Coalition Against the Misuse of Pesticides will truly call it what it really is: the National Coalition Against the Use of Pesticides (but the acronym "NCAUP" wouldn’t be as catchy!). NCAUP is not the only anti-pesticide group — there are many others, e.g., the Environmental Working Group, Sierra Club, Californians Against Toxic Substances and Public Interest Research Groups, all who claim to be environmentalists.
The issues raised by these groups would be much more defensible and, thereby acceptable, if they supported their opinions with sound science. Typically, however, their pesticide witch hunts are based on emotion, testimonials, media hype and shoddy "scientific" studies that never could be published in a refereed journal.
POLITICS OR SCIENCE? Unfortunately, the U.S. Environmental Protection Agency repeatedly has demonstrated its willing ness to yield to emotion, political pressure and junk science in making decisions about pesticides. Considering the amount of data, expense, reviews and Scientific Advisory Panels that EPA requires the manufacturers to go through in registering and defending pesticides, it amazes me that anti-pesticide groups are able to raise a red herring with so little evidence and sadly, that frequently they win the day.
These groups have forced cancellation or significant label changes for products including DDT, chlordane, malathion, diazinon, propoxur and bendiocarb. The latest casualty in their attack on pesticides is chlorpyrifos. My question is: When will it end? Answer: When all the pesticides we currently use are canceled.
Their strategy: Use the Food Quality Protection Act (FQPA) to eliminate uses of urban pest management products. EPA has proposed three strategies for reducing the risk of pesticides under FQPA; however, the manufacturer is charged with deciding how this will be accomplished. The three strategies are:
• Eliminate some uses of an active ingredient — chlorpyrifos and bendiocarb.
• Mandate unreasonable safety precautions on labels — PR Notice on termiticide labeling.
• Refrain from adding any additional uses for an active ingredient.
If you haven’t figured it out yet, the structural pest management industry is the target and we are taking all of the hits. Unfortunately, the structural pest management industry is an easy target because we use products in and around homes, albeit safely and without major incident — i.e., significant health effects and death.
If we examine the events of the past seven years (which happens to coincide with the Clinton/Gore Administration), structural pest management was the writing on the wall.
The harbinger of doom was the final statement in the executive summary of the National Academy of Sciences Study on Pesticides in the Diets of Infants and Children (June 28, 1993) that stated, "Because infants and children are subject to non-dietary sources of exposure to pesticides, it is important to consider total exposure to pesticides from all sources combined."
Two weeks prior to the publication of the report, EPA hosted a meeting of stakeholders, e.g., parents, industry, manufacturers, agriculture, EPA and anti-pesticide advocates. Breakout groups that discussed the risk of exposure of children to pesticides portrayed a bleak picture for the structural pest management industry. Their consensus was:
• A child’s greatest risk of exposure to pesticides was dietary.
• Termiticides were the main route of respiratory exposure. This was only five years after the chlordane label was suspended and chlorpyrifos became the most widely used termiticide in the industry.
• Children were exposed to pesticides by direct contact, i.e., hand to mouth, with pesticide-contaminated toys and furniture.
• The main route of ingestion was from contaminated surfaces, e.g., cooking utensils and cookware.
• Children were contaminated with pesticides from tracking them in from outdoors, contact with treated pests, washing of contaminated clothing and contact with pesticide containers.
Most of these opinions were based on perception. I know of few instances where products applied by PCOs have created the situations these participants perceived to be a problem. Most of the attendees failed to recognize that the greatest risk of pesticide exposure resulted from consumer use of pesticides that put children at the greatest risk.
We are just seeing the tip of the iceberg. Ficam (bendiocarb), one of the best products for bee and wasp control, was one of the first casualties of FQPA. It will be interesting to see how fast the best alternative product, carbaryl (Sevin), bites the dust. My suspicion is not too long.
ACTION AND RESULT. On June 8, 2000, EPA announced Dow AgroSciences’ "voluntary" cancellation of chlorpyrifos for use in and around homes and as a post-construction termiticide. (There were some exceptions made for fire ant and mosquito treatments.) Though it seems preposterous to think that a manufacturer that sells more than $500,000,000 annually of a product would voluntarily cancel it, Dow AgroSciences did just that. Why would the producer of the most widely sold termiticide, over-the-counter consumer product active ingredient and structural pest control active ingredient voluntarily cancel most uses of its product? Given the choice of having your head chopped off with a guillotine or gracefully phasing out your product, the company had no choice.
It is apparent that we have reached the fork in the road where manufacturers take the "path less traveled" and are unwilling to expend any money to register, reregister and defend products for a small niche market such as ours. Their unwillingness will have a significant impact on the availability of products for structural pest management and small-end users, such as mosquito abatement programs, which rely on "me too" registrations.
We are no longer losing individual products, but we are losing entire classes of pesticides. The first to go were the chlorinated hydrocarbons and cyclodienes, followed by carbamates and now organophosphates. This leaves only one major class of pesticides, pyrethroids, which undoubtedly will be the next target of anti-pesticide groups.
Eliminating major classes of insecticides limits our ability to manage resistance in pest species such as cockroaches, flies and mosquitoes. Developing countries also will be affected by product cancellations and may not be able to afford pyrethroids to battle diseases such as malaria.
We need to be prepared for the backlash of these "voluntary" cancellations. Despite EPA claims that "there is no imminent hazard with chlorpyrifos," in the media as well as in the consumers’ eyes, perception is reality. Customers are questioning companies about their past use of these products and undoubtedly, attorneys are licking their chops.
Although chlorpyrifos can be used for applications except post-construction termite treatments (this use ends Dec. 31, 2001), the time to start using alternative products is now. To do otherwise is to court disaster.
Despite the best intentions and practices of pest management professionals and manufacturers, anti-pesticide groups never will be satisfied. I hope that one day science and common sense will once again prevail within our government that is responsible for protecting without bias and prejudice the interests of ALL citizens.
The author is technical director of American Pest Management, Takoma Park, Md. He can be reached at rkramer@pctonline.com or 301/891-2600.
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