[Technically Speaking] Be Sure To Look Before You Leap!

I remain one of the strongest advocates regarding our industry taking the lead in mosquito abatement. Getting involved in mosquito control is something new for most pest management professionals and it can involve different regulations, certifications and use patterns for products. To avoid regulation and label violations it is essential to be aware of these differences.

It is imperative that someone in your company is certified for the type of applications you perform and that you have the appropriate licenses. Because regulations vary from state to state, this article only attempts to point out some of the common problems associated with this issue.

DIFFERENT CERTIFICATIONS. Most of us are certified in category 7: Industrial, Institutional, Structural and Health-Related Pest Control. Keep in mind that some states use a different number to identify this category and there may be subcategories within the category, e.g., general, termite, rodents, birds, etc. Category 8, Public Health Pest Control, may come into play in some states and certification in this category may be required to perform mosquito control.

While Category 8 may appear to be the way to go, it may not be that simple. For instance, in Maryland, under the current regulations, certification in this category is limited to private applicators who work for government agencies and pest management professionals cannot be certified in this category.

Some states permit certified applicators in Category 7 or Category 3, Turf and Ornamental Pest Control, to perform adulticiding, e.g., residual spraying on the exterior of structures and ornamentals. However, certification in these categories may not permit larvaciding that involves the application of an insecticide, e.g., insect growth regulator or bacteria, to water or areas that may discharge into bodies of water. This is the case in Maryland, where regulations currently require certification in Category 5, Aquatic Pest Control, to make larvacide applications.

One of the major issues discussed at the recent NPMA Legislative Day was a federal requirement (Clean Water Act) to obtain a National Pollution Discharge Elimination System (NPDES) permit under the Act prior to applying larvacide and adulticide within close proximity of a body of water. NPDES permits are obtained through EPA or the authorized state agency. Currently this restriction only is being upheld in certain western states. Stay tuned to NPMA for further developments — violating the CWA can be a costly mistake.

Unless you are engaged in the turf and ornamental business, mosquito adulticid-ing may expose your operations to other requirements, i.e., posting and notification. Each state has different posting requirements for outdoor applications and frequently performing mosquito abatement involves not only applications to the exterior of the structure but throughout the landscape. These types of operations increase the likelihood of drift so it is essential that notification requirements for adjoining properties be followed.

There is no question that mosquito control plays by a set of different rules. Be proactive and check regulations and with your state regulatory agency before performing mosquito abatement operations.

WHAT ABOUT THE LABEL? Labeling is the other side of the coin. For the purposes of this article, I have reviewed several products labeled for adult and larval mosquito control, and my comments reflect on their labeling and not all products labeled for the same use patterns.

• "Do not apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark. Drift and run-off from treated areas may be hazardous to aquatic organisms in neighboring areas."

• "In the state of New York, do not apply within 100 feet of coastal marshes or streams that drain into coastal marshes."

These statements were taken from pyrethroid insecticides labeled for adult mosquito control. Most, if not all pyrethroids, are highly toxic to fish and other aquatic organisms and care must be taken to ensure these products, even small amounts, do not enter bodies of water. The New York statement is extremely conservative, stipulating applications cannot be made within 100 feet.

Most label statements regarding drift are less restrictive, thus the onus is on the applicator to ensure the product doesn’t contaminate surrounding waters. Two ways this can be accomplished is to maintain an adequate buffer zone and by not applying when there is any wind. Typically applications made early in the day avoid this problem.

• Of the three products reviewed, all indicated the following, "Do not apply this product or allow drift to blooming crops if bees are visiting the treatment area." One of the three products stated, "However, dried residues of this product are non-toxic to honey bees."

Bees are major pollinators and in many areas of the country colonies have been decimated by a number of natural organisms, such as the Veroa mite. We can ill afford to have bees killed as the result of pesticide applications. As with aquatic organisms most if not all pyrethroids are highly toxic to bees, at least until they have dried. Other than spraying when there is no wind, avoiding the problem with bees is somewhat easier. Select a product that will not affect the bees once it has dried and applying it when the bees are not active, i.e., after sunset.

• "Do not apply this product when weather conditions favor drift from the target area."

• "Do not make outdoor broadcast applications to turf and ornamentals when wind speed is 15 miles per hour or greater."

Pesticides applied when wind speeds approach 15 miles per hour will drift off the target area. My advice is not to make this type of application unless the wind speed is less than 5 miles per hour. This minimizes the risk of pesticide drift.

• "This product is restricted for use in the state of New York. Only for sale to, use, and storage by Certified Applicators."

The label implies this is a restricted-use pesticide in the state of New York. If you select a product of this type and intend to use it in New York, be sure to comply with the use regulations for EUPs and the record-keeping requirements.

• The one larvacide reviewed contained one statement of environmental concern, "Do not apply to waters that drain into public waterways."

The label on this product indicates it only can be applied to contained bodies of water. It cannot be applied to storm drains, catch basins, drainage ditches and similar bodies of water that may drain in-to public waterways, e.g., lakes and rivers.

CONCLUSION. Mosquito abatement is a great business opportunity for our industry and the media is providing a lot of the advertising. If you leap into the game, make sure you play by the rules.

The author is technical director of American Pest Management, Takoma Park, Md., and can be reached at rkramer@pctonline.com.