Problems & Solutions - George Rambo: Answers to Your Tough Pest Questions

Q: I often find labels confusing and contradictory. For instance, some of the termiticide labels state that holes can be drilled up to 24 inches apart while others say 12 inches. Then, there are state regulations that indicate 12 to 24 inches. Which do I select in developing protocols?

A: Welcome to the world of right and left hands. As we always state, "the label is the law...unless the law in your state says differently." We have had several label changes and new labels in the termiticide arena during the last few years. It always makes sense to read the labels carefully, no matter what you think you know. Then, if there are any questions ask both the company representatives and the regulators in your state (or states you may work in). I recently have found that some state regulations do not reflect the new label directions especially regarding the drilling of holes in slabs. This is an interesting situation since state regulators lobbied EPA so strenuously to change labels in this particular direction. It seems they would have made an effort to coincide EPA changes to their regulations. However, as I stated, the label is your direction. More importantly, go with the most conservative interpretation of that label direction, even if your state regulations allow some different direction. They will catch up.

Q: I work in a state that does not require me to hand labels and MSDSs to customers when I apply a pesticide or begin a service. Should we do this anyway?

A: This is an area in which I feel the industry should take a strong stance — and that stance should be to offer information. IPM programs almost always include labels of materials to be used (they must be submitted with a proposal or be available for the account for reference). Commercial accounts almost always want to know because of worker right-to-know laws. Who is left out? The homeowner. In some states, as you noted, this information must be given to the customer when service starts and when any changes of pesticide are made (e.g., treat a house with a pyrethroid then switch a few months later to a boric acid product). You have to provide information on this change.

My opinion is that we as an industry provide; here is what we are going to use and/or here is where you can get information. Do this in writing, such as a information sheet with your phone number or hot line for pesticide questions, your Web site with button to click on for pesticide information, NPMA Web page, manufacturers Web address, suppliers, etc.

If you decide to provide information like this make sure: 1. The technician or sales people have the current label and MSDS you are using. Note there is a date on label usually at the very end of the label that says when EPA registered that label or label change. You may have on your trucks materials that have different information then the most "current" label; 2) There is a corporate policy for handling this distribution and inquires; 3) There should be a discussion and point of information such as the above with the customer at the point of the sale, and maybe when the tech shows up the first time; 4) Check manufacturers’ Web sites for the most current information (most all have PDF files that are downloadable for you to keep current; and 5) If you provide on line account information including the pesticide used you should have a link to your web page that allows them to access pesticide information.