Mar 9, 2012 – Pyrethroids And Interpretations
QUESTION:
I wonder if you can shed a little more light on the Pyrethroid issue. I am still somewhat confused when it says we can treat a foundation up to 3 feet. That means to me that we can go around the outside of a structure from the soil upwards to 3 feet - correct? And, we can spot treat around windows and doors correct? The EPA offers the interpretations that we are permitted to spray a 1-inch band around doors and windows, but our standard spray tips will go well over that 1 inch band. How does the EPA expect us to adhere to only 1 inch? Also, is there a database of some kind that lists non-pyrethroid products for us to use? I really don't know how somebody can work this trade in California with all the restrictions they have!
ANSWER:
You pose some good thoughts here Steve, and I suspect a lot of people will need some time to become comfortable with these new statements on the labels of all pyrethroid products. One thing we need to accept is that these restrictions on pyrethroids are now in place (as your new material purchased is labeled in this manner) and they are not going away. If anything, this success in getting EPA to restrict pyrethroid uses will probably encourage the anti-pesticide groups to now work on other kinds of pesticides as well.
View past Ask Mr. Pest Control questions.
I wonder if you can shed a little more light on the Pyrethroid issue. I am still somewhat confused when it says we can treat a foundation up to 3 feet. That means to me that we can go around the outside of a structure from the soil upwards to 3 feet - correct? And, we can spot treat around windows and doors correct? The EPA offers the interpretations that we are permitted to spray a 1-inch band around doors and windows, but our standard spray tips will go well over that 1 inch band. How does the EPA expect us to adhere to only 1 inch? Also, is there a database of some kind that lists non-pyrethroid products for us to use? I really don't know how somebody can work this trade in California with all the restrictions they have!
ANSWER:
You pose some good thoughts here Steve, and I suspect a lot of people will need some time to become comfortable with these new statements on the labels of all pyrethroid products. One thing we need to accept is that these restrictions on pyrethroids are now in place (as your new material purchased is labeled in this manner) and they are not going away. If anything, this success in getting EPA to restrict pyrethroid uses will probably encourage the anti-pesticide groups to now work on other kinds of pesticides as well.
The EPA sent manufacturers and formulators a canned set of statements that needed to be added to the labels or all pyrethroid products, so no matter what the trade name of the product these new statements should be consistent. For outdoor liquid applications to surfaces of a structure you now must apply only spot or crack and crevice treatments, EXCEPT FOR applications to the building foundation up to a maximum height of 3 feet above the soil. If you are using a product where this application already is not permitted then it still is not permitted, but if you previously could wash down the entire exterior wall you no longer can. You now must keep the application at or below 3 feet above the soil, and make this application continuous around the structure.
I also strongly encourage everyone to discuss these new label statements with your own local regulatory inspectors. Since some of this obviously is open to interpretation it is they who would interpret it in the manner that they expect you to adhere to. It's really important to have this line of communication with the local regulatory agencies, and in California the County Agricultural Commissioners field inspectors are well known for working positively with our industry.
With respect to that 1-inch band around windows, keep in mind that a "spot" application is defined very briefly by EPA as an application that covers "no more than 2 square feet" of that surface. Two square feet is 288 square inches, so my belief is that the EPA does not state what the dimensions of that spot must be - perhaps it is 1 foot by 2 feet, or perhaps it is 4 inches wide by 6 feet (72 inches) long. EPA also does not state how far apart "spots" must be placed, so these are questions to ask your local regulator, because they well may have their own interpretations on how large the spot can be or how far apart you must place them. Some product Labels DO state what these are, so please carefully read every label before using the products.
I think that the concession on allowing that 1 inch band probably has more to do with the "crack and crevice" statement than the spot treatment. A true C&C application means the liquid goes INTO a crevice and none of it appears on the exposed surface. Treating around exterior doorways and windows is likely to produce some level of runoff on the surface, so this allows this slight runoff to occur if you used a crack and crevice straw to inject the material into the framing.
All of the Univar sales representatives have received a listing of ALL insecticides, categorized by their chemical families, so please contact your local Univar office and sales reps to get this information. There are a great many excellent NON-pyrethroid insecticides available now, and in fact most of the new products that have come to our industry in the past 10 years or so are not pyrethroids. I will say that my own review of the labels of these products does not show many perfect alternatives if you are looking for a residual material that allows the same overall surface treatment that some pyrethroid labels allowed in the past.
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