[Technically Speaking] And They Do Nothing

Author’s note: My May 2007 Technically Speaking column titled “Anyone can kill pests” included a “top 12 list” that should have been credited to Jeff Tucker, BCE. The list comes from a presentation Tucker has taught since 1990. I sincerely apologize for neglecting to credit Tucker for this information. — Richard Kramer

There are so many things the U.S. Environmental Protection Agency and federal and state governments could do to protect the public from the potential hazards of pesticides and they do nothing. They do nothing except consider further regulation of our industry, other pesticide applicators and the products we use.

Don’t misunderstand — I am not opposed to regulation of our industry. However, I am opposed to over regulation, particularly when it is for the wrong reasons. EPA currently is considering revamping the training and certification requirements for pesticide applicators. This probably is not bad, since these regulations have not been revisited to any significant degree since the creation of EPA in 1972.

For instance, the proposed changes would affect:

• Testing requirements for all applicators.
• Standardization of categories and testing.
• Direct supervision requirements.
• All commercial and occupational applicators. Any application of restricted-use and general-use products to properties other than their own would be subject to training and certification requirements.

The major difference in this last point and the regulations under FIFRA as they currently stand is that existing regulations address only restricted-use products. If every applicator of general use products must be certified or under the direct supervision of a certified applicator (something else yet also to be redefined) this could be unduly burdensome.

THE REASONS? The basis for this change escapes me. State regulatory agencies have done an outstanding job of minimizing pesticide hazards through the existing certification and training programs. The industry (e.g., NPMA, state associations, and PCT magazine) have provided extensive training materials and programs to ensure the safe handling and application of pesticides. Most of the pesticide “incidents” we hear about result from uncertified individuals, private applicators (not farmers) and homeowners. So where is the problem?

The problem is the consumer market and open public accessibility to the same products we must be trained and certified to apply. And they (EPA) do nothing. It amazes me that our customers and the public in general believe that we have the “special stuff” and that we can do things with the products that they can’t. Most of the misapplications and poisonings that I’m aware of resulted from the open access of untrained and uncertified individuals to concentrated pesticides. And to this day, 35 years after its inception, EPA does nothing to mitigate this problem other than classify a few products as RUPs — products that, perhaps with a little ingenuity, could be acquired by consumers.

FOOD FOR THOUGHT. Here are a couple of novel ideas for EPA to consider (instead of further regulating our industry):

• Require all over-the-counter products be sold ready to use, e.g., diluted or in small unit doses.
• Enforce the language (distributors and retailers) only for sale to and use by certified applicators.

Another related topic is the continued focus on insecticides and rodenticides as the “bad” pesticides. I live in Maryland, which has some of the most restrictive regulations regarding pesticide applications in schools. And we have a small collection of parents who are convinced that insecticides — even cockroach and ant baits — will severely impair the health of their children. In fact, I recently was told that the treatment (baits) for cockroaches was worse than the disease (cockroach allergies).

And they do nothing about the disinfectants (EPA-registered pesticides) used in their schools — I guess because they are not insecticides. Many find it acceptable to use these products as insecticides (a misapplication) because while virtually every insecticide application in a school requires notification, use of a disinfectant doesn’t. Some of these individuals should spend more time reading the labels and MSDSs for these disinfectants — it makes my hair stand on end.

Other topics that get me excited are global warming and ozone depletion and their relationship to pesticides. In the grand scheme of things pesticides (even methyl bromide) are a drop in the bucket when compared to such environmental pollutants as carbon monoxide and carbon dioxide, which have a significant impact on ozone depletion and global warming — and they do nothing.

The United Nations Environmental Program Methyl Bromide Technical Options Committee spent more than 10 years wrestling with replacements for methyl bromide. Meanwhile, our own EPA and other government agencies do nothing to curb carbon monoxide emissions. And speaking about environmental insults and global warming, local governments allow the continued destruction of forested lands to build homes and shopping centers.

Unless I have my biology wrong, photosynthesis converts carbon dioxide (reportedly the major culprit in global warming) to oxygen yet they do nothing about the destruction of forested lands. I stand corrected: They require a one-for-one planting of a sapling for every tree removed.

I think it is time for EPA to focus on issues that create significant environmental impact and for a change do nothing about further regulating our industry and the products we use. 

The author is president of Innovative Pest Management, Brookeville, Md. He can be reached at 301/570-3900 or via e-mail at rkramer@giemedia.com.