Aug 22, 2012 – Refining A Word

QUESTION:

When the newly revised labels on pyrethroid products state that a PMP cannot service a "gutter", are they refering to a curbside gutter alone, or the gutter attached to the roof of a house also?

ANSWER:

That is a good question Frank, and it's an answer I cannot give with any confidence. However, in reading the specific wording from EPA my opinion is that it is referring to curbside gutters since it references, in the same sentence, "where drainage to sewers, storm drains, water bodies, or aquatic habitat could occur". 

However, in a separate part of that paragraph the new wording also states that "application is prohibited directly into sewers or drains", so it could easily be argued that the rain gutter around a roof line is easily defined as a "drain". This shows the problem with the use of vague terms like "gutter" or "drain". Is it referring only to floor or sink drains or anything else that captures water and directs it someplace else? 

We also have to ask if the roof rain gutter would be considered an "impervious" surface on the exterior, which would prohibit applications to it. Since the use of pyrethroids on exterior structural "surfaces" is now restricted to crack and crevice or spot application, and in general horizontal surfaces cannot be treated at all since rainfall could wash off the pyrethroid, I would suggest that we err on the side of both caution and the spirit of these new restrictions and not spray into rain gutters. 

This is a good example of a question that should be directed to your local regulatory inspectors. They would be the ones to enforce these new label statements and should be the ones to give you their interpretation of the gray areas. 


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