Labels: How PMPs Can Make a Molehill Out of a Mountain

Pest management has always been a blend of science, technology and art. Technical skills and knowledge are important to outsmart the pests, but if you cannot effectively communicate with clients and package services that customers want to purchase, your business won’t grow. It’s never been easy, but these days there are entirely different levels of complexity. On top of those basic pest management skills, companies now need to be savvy with a number of safety requirements, legal issues, risk assessments, third-party auditors, a whole host of IT issues and even virus disinfection. In fact, with all the noise these days, it seems some of the pest management basics get ignored.

One aspect of pest management that requires the consumption of large amounts of data is reading and understanding pesticide labels. If you’ve worked in the industry longer than a week you’ve probably heard, “The label is the law.” While accurate, this phrase downplays so many things, including that the law is written in technical jargon, often changes without notice and sometimes isn’t all that clear to begin with.

Labels and Safety Data Sheets (SDSs) have gotten progressively harder to keep up with since my entry into the industry in the early 2000s. The company I work for has 182 pesticide products that we use. The average label length is about five pages long and contains about 4,000 words. For nearly 200 products, this is a mountain of information to be familiar with, and a very similar word count as reading CS Lewis’s “The Chronicles of Narnia” (all seven books) twice! Or, for fans of J.K. Rowling’s more verbose prose, this is as long as the first five books of the Harry Potter series. That pile of literature does not include the accompanying SDSs, which average about seven pages and 2,200 words apiece!

Not surprisingly, there are several companies offering access to their up-to-date databases of product labels/SDSs as a billable service. While these databases do have an appealing ring to them, pest management companies still need to find ways to transfer that knowledge from the database into the end user’s (i.e., applicator’s) head. This is where owners often go astray, thinking that having up-to-date labels on their website is the end goal. It’s not! Having competent applicators should be the goal. What follows are some tips for managing and training on the tangled thicket that is pesticide labeling.

THE LONG FORM OF THE LAW. If the label is the law, then it’s worth explaining how it’s laid out. Pesticide labels have a variety of parts that generally appear in the same order, regardless of manufacturer. Many of these components require an explanation. After all, we aren’t born knowing what the signal word CAUTION means. When an applicator is reading the label, they often want to know how to use the product. The directions for use are found towards the back of the label. This means if you pick up a label and read it like a book you may be experiencing some brain fog by the time you finally make it to the directions for use, if you find them at all! Products labeled for use in different categories, like termiticides and general use products, are even trickier. Technicians need to pay attention to the section headings. I do a demonstration with all new employees where I ask a question about how to treat for ants with such a product. The first 10 pages of the directions for use are explicitly for termite work and don’t apply to ant treatments, but every person we’ve hired spends a large amount of time searching that area of the label, until I explain the layout.

TRAIN AS THEY SAY, NOT AS THEY DO. Assume that most technicians, as well as supervisors and managers for that matter, don’t spend enough time reading and understanding pesticide labels. How can a trainer determine what an employee knows and what they don’t? Fortunately, technicians document how materials are applied on their service reports (big data strikes again!). Depending on how your documentation is stored and retrieved, it’s likely possible to search through all your service reports and find applications that don’t quite look right. If you are smiling right now, you probably haven’t looked at your documentation lately! When reviewing documentation, it’s safe to assume some unfortunate things have been recorded. For example, the EPA has been explicit about not making misleading safety claims about pesticides. Try searching your technician’s comments for the word “safe.” It will likely be enlightening and open some training avenues.

“CHANGE IS INEVITABLE, PROGRESS IS OPTIONAL.”

This quote is attributed to the inspirational speaker Tony Robbins, who may have been referring to pesticide labels for all I know. It certainly fits! Even if you manage the nearly impossible feat of getting everyone up to speed on all the products you use, guess what? The labels will change, and quite frequently! Of the 182 products I track, in the last seven months, 27 of them had new labels and/or SDSs published to the manufacturer’s website.

Many may not be aware just how often “the law” gets minor tweaks that no one seems to talk about. It may be wise to nomi- nate one of your more organized employees as a “label czar” to at least keep track of your regularly used products, and to thoroughly read any labeling looking for easily overlooked changes after a new version is released. Better yet, get on the bandwagon to encourage manufacturers to make getting these updates easier! Automatic updates, with changes highlighted, would be both a change and progress.

CLIFFSNOTES FOR BROAD-SPECTRUM CONCENTRATES? This next tip will probably put me at odds with some risk-averse folks out there — but if they are truly risk-averse they won’t challenge me on it. I’ll go ahead and share it, as it has been largely beneficial in my experience.

Here is a fundamental truth: The amount of information in pesticide labels is immense (and growing) and time spent reading labels is relatively small (and possibly shrinking). This truth is putting the pest management industry in the awkward position of feeling like an irresponsible student who stayed up too late partying instead of finishing their homework.

One possible solution is to make a cheat sheet. A couple of years ago, I put together reference sheets for commonly used pesticide products that listed out need-to-know information, such as required PPE, reapplication intervals, dilution/application rates, and labeled sites outdoors/indoors. Using such a reference, an applicator can correctly find accurate information for how a product is to be applied in a fraction of the time. Beware, some caveats will likely apply (and now your organized employee just got another responsibility).

FINAL THOUGHTS. I may have made pesticide labels seem insurmountable, but in truth, there is a lot of repetition in the way they are constructed. Teaching people how to comprehend this “art form” and find what they are looking for is an attainable goal without paying people to read the entire “Chronicles of Narnia” (twice!) while sitting in their truck! If you are a smaller company it is probably wise to avail yourself of some of the resources out there like PCT’s label training or possibly one of the third-party database providers. Just remember, if progress is optional, we should be opting in!

VanderWerp is a board-certified entomologist and the manager of education and training for Rose Pest Solutions, based in Troy, Mich. Rose is part of the Copesan network of local service providers.

Copesan is an alliance of pest management companies with locations throughout North America. To learn more, visit www.copesan.com.

December 2020
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