QUESTION:
With the change on pyrethroid labels of not applying any product to drains or sewers, how do you suggest treating grease traps in kitchens to prevent buildup of the large species of roaches like American cockroaches, and to prevent migration from these areas to the floor drains in the kitchen when water levels in the grease traps drop due to low water usage keeping the lines filled? I do school kitchens and can tell when the lines are getting low on water because I will start seeing the large roaches in the floor drains and when I open the grease traps for inspection. There are periods such as winter and summer break where there is no kitchen activity for a month or more. I am almost certain that the migration is coming from the grease trap because I will start seeing their presence in the grease trap down on the city sewer side before seeing them in the school side.
ANSWER:
One important point to make on the Pyrethroid labeling issue is that you can continue to use the pyrethroid products as they are labeled. Once the labels on the packages change to comply with the new restrictions then those new guidelines are what must be followed. However, the new labeling guidelines do NOT require that applications within storm drains or sewers or other kinds of drains be discontinued and removed from the pyrethroid labels.
What the new EPA requirements state is that IF the product label does not currently allow application INTO “drains or sewers”, but does allow use “around or near floor drains”, then that label must add new wording that specifically prohibits use directly into the floor drains or into any sewer or outside drain where the material could end up in a sewer or storm drain. The effort here is to add a level of protection against off-site movement of the pyrethroids that could allow them to end up in aquatic sites.
On the other hand, if the product already has directions for use in drains or sewers then here is the exact new wording that will appear on the pyrethroid labels, and it is the last 6 words that are important: “Do not apply directly to sewers or drains, or to any area like a gutter where drainage to sewers, storm drains, water bodies, or aquatic habitat can occur, EXCEPT AS DIRECTED BY THIS LABEL”. With this you will continue to be allowed to treat sewers, storm drains, and directly into floor drains if the Label already has those directions on it. I would assume (that awful word “assume”) that manufacturers would intend to retain existing wording on this use.
Therefore, a product like DeltaDust, which is labeled for sewers, underground passages, and floor drains should continue to have this application on the label, but will have the additional new wording that emphasizes the need to keep it out of drains that would carry it to nearby aquatic sites. Grease traps are a tough one to deal with, in part because they may often be the neglected unsanitary situation in commercial kitchens. Consider the use of one of the bio-cleaning products that will help to break down and eliminate the grease in the trap. One of these is the Invade BioBullet from Rockwell Labs, which is a solid block that can be placed directly into the trap to help digest the grease for up to a 3-month period. This could be an excellent add-on service you can offer to these kinds of customers.
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