QUESTION:
I know you have covered the EPA definition of a “spot” area, but based on that have you found most regulatory interpretations to be flexible about the new pyrethroid label changes regarding spraying higher than 3 feet? Also, the general consensus that I have heard about interior ‘spot’ treatments is that it should be less than 15-20% of the area of the room and no larger than a 2×2 foot area. Does that mean it can be less than 15-20% of the room floor area, but still a bunch of 2×2 areas seperated by 1 foot spaces? A lot of my interior spraying is baseboard, behind stuff, around toilet bowl kind of spraying.
On a separate note, in your experience, how many customers/properties does the average work day consist of for a typical pest control company that does primarily maintenance and residential GHP? Thanks!
ANSWER:
The more I investigated the definition of a “spot” treatment the more I realized I had been giving bad information to people for years. I too have always preached that an application of “spot” treatments should cover no more than 20% of the overall surface, and in my mind’s eye I believe I read this somewhere. However, it turns out that EPA’s definitions stops with the requirement that a single “spot” is no greater than 2 square feet, and it does not address how much of the surface area can be covered by spots. However, I have seen a couple of product labels that DO state how much of the surface area can be covered by spots with THAT specific product, so it is vital that you read each product label carefully to be aware of these kinds of restrictions.
Let’s examine your questions. First, it is confusing on that “2 square feet”, which would be 288 square inches in some configuration or another. You mention a spot of 2 ft x 2 ft, but that would actually be FOUR square feet, not two. A 1×2 spot would be 12 inches x 24 inches, or 288 square inches. Other dimensions that would accommodate this definition, then, could be 6 inches wide by 4 feet long, 4 inches wide by 6 feet long, or 2 inches wide by 12 feet long (2 inches times 144 inches equals our magic 288 square inches as a legal “spot”). Now, it is very important to carefully read each Label of the products you use to determine just how that Label allow you to apply the product. You may be allowed to do general surface treatments in certain areas of a labeled site, such as a restaurant, but be restricted to spot or crack and crevice treatments in the food areas. Or, in that food area you may even be restricted to just C&C, and to apply any of that insecticide to an exposed surface could be illegal.
The current issue with the Pyrethroid labeling may bring much of this confusion into focus for us. It also is VERY important to consult with your own local regulatory agency to determine just how they interpret some of this. They may decide what overall percentage of a surface can be covered with spots, as EPA does allow states to be MORE restrictive than the federal regulations, but not LESS restrictive. How close together you are permitted to place those spots does not appear to be defined or stated by EPA, but we do need to use good common sense on this or we are liable to get our hands slapped with new regulations. If we feel sneaky and place our spots immediately adjacent to each other, managing to cover the entire surface with individual “spots”, that clearly is not in the spirit that EPA intended, so keeping some distance between spots is more responsible.
On your second question regarding how many accounts to service each day, this depends greatly on what kinds of service you offer and the size and difficulty of each account. When I worked in pest control (we called it “control” back then) our company offered turf and ornamental treatments along with the structural, so each monthly or quarterly stop at a residence might involve treatments of shrubs, trees, and other ornamentals as well as treatments around the structure for ants, spiders, etc. This certainly increased the time per account, and for large properties with a lot of trees could GREATLY increase the time spent there (along with the monthly fee for doing all of it). You might have some accounts where you need to get through locked gates or past outside pets, and dealing with these issues adds to the time it takes to provide the needed service. Another issue is how well your route is set up. Are you working in a small geographic area each day or do they have you running all over town, driving 20 minutes or more between stops?
This is what makes it hard to tell you a good average, but 10 accounts per day could be realistic or you might get in 18 accounts if they are small and easy to get into.
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