TECHNICALLY SPEAKING: Termites – Who's In Control?

No matter whom you talk to inside or outside our industry, the most controversial topic is always termites. A book could be written about the trials and tribulations of termite control. I think I can say this without rebuke: There was no more pivotal time in the termite industry than April 15, 1988 — the last day chlordane could be used for termite treatment. A lot has transpired in the past 14 years and I’m still uncertain who’s in control.

MANUFACTURER. What once was a methodical and predictable research effort to find new products and different termite management strategies has turned into a tower of Babel. We have repellent termiticides, non-repellent termiticides, termite baits, and borate wood treatments all claiming to control termites — and in most cases they do. Several manufacturers are taking shotgun approaches to termite control by combining an array of materials, while others maintain a hard and fast, “one size fits all” strategy. Instead of relying on prescriptive treatments, it’s time we look at products and how they fit our business strategies and our customers’ needs.

RESEARCHER. One would hope that the research community — both university and government — would help answer the many uncertainties of termite control, however, most research tests — and subsequently, debates — the virtues and shortcomings of the various products. Yet questions regarding basic termite biology and behavior, which is crucial to termite control, remain unanswered. This results from the fact that most research is manufacturer driven and reflects their parochial interests. We as an industry must fund research if we want answers to these more basic questions.

REGULATOR. In particular, the Environmental Protection Agency (EPA) has maintained its “cookie cutter” mentality. If you have read one product label on any of the repellent and non-repellent termiticides, you have essentially read them all (at least with regard to application instructions). EPA will point to the manufacturers, however, the manufacturers have learned that to register a product, choose the path of least resistance — and use an already registered label. In our industry cloning is nothing new. One exception to this cloning has been the baits, which cannot be applied at 4 gallons per 10 linear feet per foot of depth. However, I’m not sure they didn’t try — why do you think the recommended spacing of bait stations is 10 feet apart?

Nowhere in the acronym “EPA” do I see a letter indicating they are a consumer protection agency, however, with termite products, the Agency seems to be expanding its role. A question posed by an EPA spokesperson at a recent state training course piqued my interest: if baits are used as a pretreatment, how do you know they are working? Obviously, as with liquid pre-treatments, if you get termites in the house subsequent to treatment, it failed. I believe the implication is that liquids are more reliable as pre-treats than baits. In today’s market, and despite Federal Trade Commission and state’s Attorneys General investigations, I doubt this is the case. (See additional comments about this under the “builder” heading on page 118.)

Post-construction treatment is an area where EPA has stuck its head in the sand. This is so incongruous considering the Agency’s position on pre-treatments. The obvious reason — property owners requiring post-construction termite treatment typically have an infestation and deserve the most comprehensive and effective treatment. Years ago EPA had an opportunity to address post-construction termite treatments with the PR notice on termiticide labeling. Failure of the Agency to take a position on minimum treatment standards for post-construction termite infestations left the door open for substandard treatments, e.g., low concentrations and application rates. In fact, I have known of two companies in our area that openly used a compressed air sprayer to treat the perimeter of structures for termite infestations. At the time, the state’s hands were tied regarding enforcement action.

Efficacy seems to be an issue of paramount concern to EPA as indicated by the PR notice and now its interest in the efficacy of baiting systems. Yet, I’m still befuddled by their selective use of the U.S. Forest Service studies for the registration of termiticides. Their focus remains on pre-treatments as evidenced by their reliance on the concrete slab test for the registration of liquid termiticides. Why not have the ground board tests be the “gold” standard? It is certainly the more challenging of the tests and it more closely replicates post-construction treatments, i.e., when property owners have termite infestations.
Perhaps it’s because until recently most of the registered products would not have been registered if the ground board data were used as the standard, i.e., 100 percent control in three of four sites for five years. Perhaps this standard could be achieved by using higher concentrations and/or rates of application. While this may have been in the Agency’s self-appointed mission of consumer protection, it would not be in consonance with their mandate of environmental protection.

This left many states with no choice but to institute minimum treatment standards, particularly regarding post-construction treatment. This has created quite a stir in Georgia, which has minimum standards with a provision that the property owner can waive the standards, providing there is a compelling reason not to do a complete treatment. Some companies are using the waiver as a means to only perform exterior treatments with the new non-repellent termiticides.
 
BUILDER. One other player in this quagmire is the builder, who insists on paying no more than $75 for a pretreatment. For the most part, the FTC and states’ Attorneys General investigations were a joke. During the “investigations” pre-treatment in our area skyrocketed from $0.05 per square foot to $0.12, half of what it would cost to buy the least expensive product for the job. This pricing continues, despite the fact that the LABEL IS THE LAW and they all now have minimum pre-construction standards. It’s time for the builder to share the liability for pretreatment failures, and not for just one year. Why bother to treat at all (and some don’t) if there is only a one-year guarantee? Why not make termite protection part of the HOW program (if it still exists), which is basically a 10-year guarantee?

PEST PROFESSIONAL. If EPA and state regulatory agencies are going to take such a proactive interest in this aspect of our business we need to be involved with all of these players. We need to ensure that they fully understand the complexities of termite control. As professionals we should embrace the idea of leveling the playing field through enforceable labeling requirements for pre- and post-construction termite treatments. Furthermore, we should embrace the idea of strict enforcement of those labeling requirements.

In your termite business, who is in control? My hope is that you are.

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