EPA And ASPCRO: Fiddlers On The Roof

Just as the fiddler on the roof sang "Tradition, Tradition," the U.S. Environmental Protection Agency and the Association of Structural Pest Control Regulatory Officials (ASPCRO) have relied on tradition for termiticide labeling and regulation. In most cases, the manufacturers (registrants) are equally culpable in perpetuating the tradition of termiticide labeling. From their point of view, the easiest route to product registration is label cloning. Anyone who has looked at more than one termiticide label readily recognizes the amazing similarities among product labels.

Currently there are three broad classifications of termiticides: repellents, non-repellent toxicants and baits. Despite the fact that the first two categories have completely different modes of action, the product labels are similar. The only class of termiticides that has different labeling is the baits — for obvious reasons. However, if one looks closely at bait labels, they too bear remarkable similarities. So why are products that vary significantly in their mode of action and effectiveness being similarly labeled? TRADITION!

SAME LABELS, DIFFERENT PRODUCTS? How 10 or more products can have the same label is a curiosity. The manufacturers have designed new product lines so why are they still cloning chlordane labels? It’s analogous to putting a 1999 Mustang 5.0 on a Model A chassis. The following "traditional" label statements are found, in some fashion, on all termiticide labels:

"Apply 4 gallons of solution per 10 linear feet per foot of depth to provide a uniform treated zone."

"Retreatment for subterranean termites can only be performed if there is clear evidence of reinfestation or disruption of the treated zone due to construction, excavation or landscaping and/or evidence of the breakdown of the termiticide-treated zone in the soil."

Regarding the rate of application statement, this has been the mainstay of termiticide labeling and regulation. As an industry, we have lived with this traditional application rate for almost 50 years. By all accounts, the basis for this rate of application was derived using gut instinct during the early chlordane days. If truth were known, had chlordane (1.0 percent) been applied at one-quarter of the traditional rate of application, it would have lasted 30+ years.

Chlordane and the subsequent first generation of termiticides were designed to establish a continuous repellent barrier around the structure. The second generation of soil-applied non-repellent termiti-cides, e.g., imidacloprid and fipronil, allow termites to readily pass through the treated zone and then perform as toxicants to kill the termites. This, then raises the question as to why the application rate for repellent and non-repellent termiticides should be the same.

Perhaps these second-generation products are effective at much lower rates of application. Perhaps they do not have to be applied as a residual with the expectation of five years efficacy. Perhaps they are equally effective as spot treatments. We’ll probably never know because tradition has mandated that they be applied at the same rate of application as the repellent products.

There have been a few label changes that permit some flexibility in the rate of application. However, research rarely has demonstrated that these modified application rates significantly affect the distribution of the termiticide in the soil. In theory, this is a great concept but every treatment site is different with regard to soil type, adsorption and absorption rates, compaction and many other variables that affect the distribution of the product in the soil. Thus, it is difficult at best to determine what should be the ideal application rate.

IT’S NOT JUST THE LABELS. As labeling has changed during the evolution of the new termiticides, the industry has lost the ability to practice the art of termite control and has been forced to perform prescriptive treatments. Labels and regulations regarding termiticide applications are exhaustive to read, and in many cases, difficult to understand.

Product similarities do not stop at the label, i.e., many state regulators choose to regulate all termiticides same way. If the label does not tell you how to do it (and most of them do so in great detail), some state regulators take it upon themselves to regulate you into doing it. Traditionally, i.e., in the good old days of chlordane, soil sampling was a method of measuring compliance with the label regarding application rates. This technology has been applied to the new products even in the absence of reliable science. This is another example of how a standard is universally applied to termiti-cides. This measure of compliance should not be applied to all products for several reasons: the products have different rates of degradation; products perform differently in different soil types and under different environmental conditions; and this is not a measure of effectiveness in controlling termites.

Soil-applied termiticides are different products, just as termite baits are different products. Most of the products contain different active ingredients, have different modes of action and have varied effectiveness. But labels and regulations do not differentiate and do not permit the applicators to deviate from the standards imposed by these documents.

Many state regulators maintain that their responsibility is to protect the consumer and the environment and their highest performance standard is whether the applicator performed the service in accordance with the label and state regulations; of lesser importance is whether the applicator protected the consumer’s property from termites. Why isn’t the gold standard of performance if the structure is still being damaged by termites?

LET PCOs DO THEIR JOBS. I am not opposed to labeling and regulations, but they must give the termite technician the latitude to perform services in the way that best protects the consumer’s property and the environment. Labeling for a new termiticide should be predicated on the attributes of the product being registered, not on tradition.

Why are the standards for termites different than those for cockroaches, ants and other household pests? Is it because of the value of the property? How valuable is human life when one considers the problems associated with cockroach-induced asthma? Is it a concern over large volumes of product being introduced into the outdoor environment? How much concern is there about applying products in the household environment? Why don’t general household pesticides have extensive prescriptive labels, as do termiticides? Why isn’t "zero" the standard of performance for cockroach control?

We are in the business of pest management and as professionals we should be given the responsibility and the latitude to manage termites in the same way we manage ants and cockroaches.

It is time to change tradition and if nothing else, create a new tradition of open-mindedness, creativity and individuality. The facts are that all termiticides are different and pest management professionals have the skill and knowledge to provide effective termite management services without undue restrictions imposed by today’s labels and regulations.