TECHNICALLY SPEAKING: Labels: “The Weakest Link”

Hopefully, everyone has tried to read a label. If so, all the fine print makes it fairly obvious that the labels on products today were written by lawyers. The fact is, however, that although most product labels are approved by company attorneys, considerable help has been provided by the U.S. Environmental Protection Agency in crafting the copious instructions on product labels.

It appears that both are trying to provide for every possible contingency. From the corporate lawyer’s perspective, it is to protect the company from potential litigation. From EPA’s perspective, it is to protect the environment and humans from catastrophic events. But our industry is left with the arduous task of deciphering these instructions in an attempt to comply with the label and the law.

What frightens me is how few technicians really know what is on product labels. It is expected that every technician will read the label before he/she applies a product. It is questionable, however, as to how many actually do it. Generally, “there is not a enough time” because production is the way “success” is measured. Even if technicians do read labels (six to eight pages of fine print), few will fully understand them. Thus, many technicians rely on how they were trained to use a product but not necessarily what the label says.

Relying on memory and/or training when using a product is poor, if not illegal, practice because labels are always changing, e.g., site of application, application rates, target pests, use patterns, etc. Thus, it is imperative that technicians be provided new labels and, in my opinion, management invest the time to insure that technicians fully understand labels. This can be accomplished through training, testing, field observations, etc.

The following are key elements of the label with which technicians should be familiar when using a product and these subject areas should be addressed when conducting training sessions on labels:

SITE OF APPLICATION. It is a misapplication to apply a pesticide to a site that is not on the label. Check the labels on all the products you are using; many have changed with regard to sites of application (i.e., they list fewer sites).

Some state legislation mandates IPM in schools and perhaps in the future there will be a federal mandate. In most cases, the ensuing regulations permit only the use of pesticides that have schools listed as a site. If you provide pest management services to schools, check the label prior to using any product — you may be surprised to learn that schools are not on it. In the future, there will likely be fewer labels listing schools as a site.

Ensure that technicians are familiar with the terms “food-handling establishment,” “food areas” and “non-food areas.” Definitions of these terms are not always clearly stated on the label, so careful consideration should be given to products that make specific recommendations regarding these sites.

APPLICATION RATE. The application rate is the concentration at which the product is applied. This is an interesting topic for discussion. Products can be applied at less than the labeled rate of application, but they cannot be applied at a higher rate. There are two conditions under which products cannot be used at less than the labeled rate:

• The label prohibits less than label rates of application — one of the few cases is termiticide pretreatment application rates.
• State law prohibits less than label rates of application.

In my opinion, less than label rate of application is not a good pest management practice. Most manufacturers have determined the most efficacious rates of application for their products against a variety of pests and there is no reason to second guess their recommendations. In addition, lower rates of application can induce accelerated resistance in some pests, such as German cockroaches, filth flies and mosquitoes.

METHOD OF APPLICATION. Most labels make frequent reference to crack and crevice and spot treatments. However, while these terms are used frequently within the industry, there are technicians who do not understand what they mean.

“Spot application” is probably the least understood term. Years ago this term was defined in a Federal Register Notice as “noncontiguous areas no greater than two square feet in size.” The notice was silent on how far apart these spots had to be, e.g., 1.0 mm, 1 inch or 1 foot. Some labels have addressed this issue by stating that spot treatments can consist of no more than 20 percent of the treated area.

On the other hand, while the term “crack and crevice treatment” is better understood, products are still frequently misapplied. Regarding the use of baits, this does not mean lining the interior edge of the cabinet with bait — it means injecting the bait directly into a crack or crevice. Likewise with liquid applications, it does not mean aiming the pin stream at a crack and crevice; it means using a plastic extension tip and applying the product into the crack and crevice.

Probably the most abused method of application is indoor aerosol and ultra-low dosage applications. This requires technicians to calculate cubic feet, a task many cannot do accurately, as well as to determine a flow rate for the application equipment. Unfortunately, most of these applications are being made based on what “feels right.” During a personal injury trial, I heard two applicators say that they were instructed to treat office areas until there was a haze in the air. This is a frightening scenario that occurs more often than most of us are willing to admit.

CONCLUSION. The day is coming when regulatory agencies will take a greater interest in the products we use. Reading and understanding labels is one of the most important aspects of how we conduct ourselves as pest management professionals. It is imperative that we follow the instructions on the products we are using so that the day never comes when we hear those infamous words, “You are the weakest link. G’bye!”

The author is technical director of American Pest Management, Takoma Park, Md. He can be reached at rkramer@pctonline.com or 301/891-2600.