Pyrethroid label requirements tweaked again

Last year I posted a story about the new pyrethroid insecticide label requirements being sent to pesticide manufacturers by the U.S. Environmental Protection Agency. The requirements were designed in 2009 to reduce the risk of drift (wind carried contamination) and runoff (stormwater-carried contamination) of these commonly used insecticides. Since last spring, when pesticide manufacturers were officially informed of the new standards, the EPA has continued to dialog with both regulators and the pest control industry.  The results of this dialog are now out, and the final product is a big improvement, in my opinion.

The new EPA label requirements will
continue to allow pyrethroid applications
to eaves and protected sites around homes
where mosquitoes and other pests
may be resting.

At issue were applications needed to control certain overwintering insects like brown marmorated stink bug and kudzu bug, both of which aggregate on the sides and eaves of structures prior to entering the home or other building.  Under the 2009 rules, outdoor applications to the sides of structures were limited to crack and crevice applications or building foundations up to a height of three feet only.  In addition, all outdoor applications to impervious surfaces such as sidewalks, driveways, patios, porches and structural surfaces (such as windows, doors, and eaves) were to be limited to spot and crack-and-crevice applications, only.

After consultation with the National Pest Management Association (NPMA), the Association of Structural Pest Control Regulatory Officials (ASPCRO) and the State FIFRA Issues Research and Evaluation Group (an EPA advisory group also comprised of regulatory officials), the EPA agreed to make further changes to the original label requirements to allow for better control of overwintering insects.

While restrictions on insecticide applications to impervious surfaces and prior to expected rainfall have not changed, there are some big changes on applications to structures, as published in a January 10 letter to pesticide manufacturers.  The three changes are summarized as follows:

• Now applications of pyrethroids may be made to the exterior of buildings where the treated surfaces are underneath eaves, soffits, windows or doors that are protected by coverings, overhangs, awnings or other structures that protect the residues from rainfall;
• application bands up to one inch-wide may be applied to cracks or other potential pest entry points;
• and applications may be made using a coarse, low-pressure spray to portions of surfaces that are directly above bare soil, lawn, mulch or other vegetation.

The purpose of these requirements is to prevent pyrethroid pesticides from entering storm water and getting into streams, something that is most likely when pyrethroid sprays land on impervious surfaces like asphalt or concrete.

In addition to giving back to PMPs the ability to use pyrethroids against overwintering pests these new regulations should help applicators control nuisance and public health mosquitoes that frequently rest on the sides of buildings and around doorways.  This was, in my view, a potentially serious public health issue with the 2009 rules.

So what will be the big change to the way your company applies pyrethroids after the dust is all settled? The new labels will prohibit power spraying driveways and over sidewalks, garage doors and any vertical building surfaces over pavement. Assuming the manufacturers follow these guidelines closely, labels should allow low-pressure sprays to the sides of structures over vegetation or soil and in sites protected from the rain, in addition to cracks and crevices.

Congratulations to the EPA and to those regulators and NPMA experts who took the time to look for ways to keep the pyrethroid label requirements reasonable while continuing to protect the environment. This is one of those examples of how the system sometimes works in everyone's favor--except, in this case, the pests'. 

Catching the new drift on pyrethroids

For years agricultural pesticide applicators have been required to measure and record wind and weather at the time of spray applications. Wind matters in agricultural applications because of the potential for pesticide drift--the movement of pesticides from their intended target to undesirable sites such as other farm fields, homes, schools and natural areas. Weather matters because excessive rainfall can result in poor adhesion of sprays to plant or soil surfaces and pesticide-contaminated runoff--another form of drift.

In structural pest control, drift has always been an issue also, but on a much smaller scale.  For structural pest control indoor applicators, drift can occur in the form of splashback during both spot and crack and crevice liquid insecticide applications indoors. It can also occur with dust applications (I still remember my dismay, as a young and inexperienced applicator, when a compressor fan kicked on, blowing the pyrethrins dust I had just applied to a cockroach-infested motor back in my face). Outdoor applications can "drift" under windy conditions, or when rain washes residues from the application site to streams or lakes.  In fact, pesticide runoff is the reason that EPA has moved recently to change labeling requirements on new pyrethroid insecticide labels.

The new pyrethroid label standards by the US EPA are now out, and should be on every pest control service manager's required reading list. Unfortunately, they are not that easy to find, nor understand. I recently had the opportunity to sit in on the webinar update on these new standards by Jim Fredericks of the National Pest Management Association. NPMA has been working hard to keep up with these new standards and Jim did a nice job summarizing the new use directions you will be seeing shortly on all pyrethroid pesticide labels.

Digital handheld wind meters are relatively inexpensive,
accurate and can have powerful options such as wind
direction, temperature and relative humidity.

Two weather-related issues appear in these new requirements. First, for pre-construction termiticide applications only [see update in the May 1 comment below], the new labels will say,“Do not make on-grade applications when sustained wind speeds are above 10 mph (at application site) at nozzle end height.”  This means that anyone doing pre-construction termiticide treatments will have to have some method of measuring wind speed [as far as I can tell wind speed measurement is not required for general pest spray applications around residences and businesses].  There are at least three ways I know to estimate wind speed accurately:

• Purchase and use a digital wind meter, like the one in the accompanying image.  Today's units range in price from $20 to $200, depending on features. They can include barometric pressure, relative humidity, temperature, altitude, etc.
• Get a old-fashioned Dwyer handheld windmeter for about $25. This tough and dependable unit (doesn't need batteries) works on air pressure to elevate a small plastic ball, providing a simple wind speed measurement.
• Go to an online website that provides windspeed data for your location, such as  http://www.intellicast.com/National/Wind/WINDcast.aspx. The problem is that the wind speed at your local airport may not be the same as at the account where your applications are made.

Second, the new labels will prohibit any pyrethroid spray, granular or dust applications made when it's raining. In areas where rain is frequent, or constant at certain times of year, this may be inconvenient (and who's to say when it's really raining?), but the intent is clear.  When it's raining, insecticides will not adhere well to surfaces and are prone to running off the target site into storm drains or streams.

Finally, anyone doing outdoor applications (especially termite pre-treatments) should consider adding spaces on your business' service forms for weather data, like wind speed and precipitation. If you're an honest applicator who goes by the book, this sort of information can only help you if called upon to defend an application.  An on-site reading taken from a handheld wind unit always trumps NOAA area weather data, and could save your rear in a legal case.  

New EPA pesticide sales report available

It's been several years since EPA issued one of its reports on annual pesticide sales and use.  I find these statistics interesting, if for nothing more than quoting in general talks on pesticides or for literature reviews preliminary to asking someone for money.  So I am glad to see that budget cutbacks haven't completely eliminated this service, and we have some more recent figures to study (2006-2007). 

If you had to guess what pesticide was used more than any other by the Government/Industry/Commercial sector, what would you guess?  The answer, according to this report is the herbicide 2,4-D, followed by the popular glyphosate, or Roundup®.  Insecticides barely make the top ten list, with malathion and sulfuryl flouride (Vikane®) coming in at positions 9 and 10, respectively.

The report illustrates the dramatic decline in organophosphate use, as well as the overall decline in pounds of insecticide used by the commercial/governmental sector.  Interestingly, the overall amount of pesticides used in the home and garden sector has been pretty steady over the past 20 years. 

The value of the pesticide market in the U.S. for 2007 was $12.5 billion.  Within the commercial/governmental/industry sector (which you belong to) the pesticide market was worth $1.9 billion, and the insecticide market by itself, $709 million.

To read the entire report, click here http://www.epa.gov/opp00001/pestsales/

PBO in the news

A recent study in the March issue of the journal Pediatrics [vol. 127(3): e693-e700] reports on a correlation between pre-natal exposure to the common synergist piperonyl butoxide (PBO) and delayed mental development among 3 year-old children.  In a review of the article, e! Science News reported the author as saying that the drop in IQ points [among children whose mothers had higher PBO exposure] is similar to that observed in response to lead exposure.  Megan Horton, of the Mailman School of Public Health and lead researcher, said the drop, while not severe enough to affect a child's overall function "...is  educationally meaningful..."  Going a little further out on a limb, she added that it "...could shift the distribution of children in the society who would be in need of early intervention services".

The results of this study should be considered preliminary, and certainly indicate the need for more research.  Similar to the study on ADHD that I reported on last year, the data shows a correlation, but does not indicate a cause and effect relationship.  Further studies may or may not substantiate the correlation.  Furthermore, the authors note that this is the first study to ever look at the health effects of PBO on humans (previous studies, presumably having been done only on laboratory animals).

The paper brings up an interesting issue with regard to the pest control industry.  What criteria should we use to make decisions about the kinds of pesticides we use in our business?  Should a new study impact the way we use chemicals?  Or should we always just follow the lead of the EPA when it permits or restricts use of a pesticide? 

Ultimately, and from a legal point of view, the EPA is our guide.  The EPA has hundreds of toxicologists trained to look at studies such as these and determine whether there is enough data to justify a change in label requirements.  However, the process of revoking a use, or a pesticide, can take years. 

The biggest question I had about this study concerned the mothers' exposure to PBO.  Piperonyl butoxide in itself is not toxic to insects.  Rather, it is added to a few insecticides--most notably pyrethrins--to prevent insects from detoxifying the actual insecticide.  It turns out that pyrethrins, by themselves, are great at quickly knocking down, but not killing, most insects.  Adding PBO to pyrethrins merely keeps insects down for the count. 

Most pyrethrins formulations, including a number of over the counter (OTC) consumer products, contain PBO in low concentrations--usually less than 5%.  In recent years, however, some professional products have included higher percentages of PBO (e.g., 60%).  I've never fully understood the reason for the popularity of this mixture, given that PBO is non-insecticidal and that only small amounts of it are needed to synergize pyrethrins.  From what I can gather informally, PBO mixtures are being used increasingly by frustrated PMPs for bed bugs.  But I've always been under the impression that only a small percentage of residential pesticide applications by professionals used PBO.  It was surprising to me therefore to read that PBO was detected in 75% of personal air samples collected in the study. 

The study assumes PBO was used as a synergist with permethrin; however, permethrin is not normally sold with PBO.  Unless a lot of New York PMPs are using this combination (perhaps in bed bug applications?) I am skeptical that this use pattern is common throughout the country.  It's also possible that the PBO is coming from use of OTC products by the householders themselves.  Or there might be some non-pest control source of PBO.  In any case, it seems like one of the first regulatory steps would be to find out where PBO exposure is coming from. [Any insights in this regard from readers would be welcome!]

In the meantime, in my opinion it would be prudent to consider limiting use of products with high percentages of PBO in accounts with pregnant women or infants.  I'm not convinced yet that PBO is posing a health risk to the unborn or very young; but in most cases there are good alternatives. Our industry should be placing highest value on customer safety, so why don't we take a proactive lead on this one?

Ohio's request for potent bed bug insecticide denied, again

For some reason, Ohio has been one of the hardest hit states with bed bugs. Even the governor has gotten involved, petitioning the EPA last year for a special exemption to allow the use of an older carbamate insecticide, propoxur, for bed bug control.  This exemption, also called a Section 18 Emergency Exemption after the FIFRA section that authorizes it, is something that EPA does not give out easily.

Propoxur, as it turns out, is still pretty effective against bed bugs.  In Australia, for example, PMPs regard one of the propoxur-containing products as most effective.  In another study using presumably resistant bed bugs from Sri Lanka, propoxur provided the best control compared to DDT and malathion.

Much to the dismay of Ohioans, their Section 18 request was turned down last summer.  The EPA was asked to reconsider, and in a letter dated January 11 Lisa Jackson, the EPA Administrator, responded.  In her letter Jackson denied the use of existing stocks for bed bug control, and steadfastly maintains that her agency believes the product poses an unacceptable risk for children.

In an interesting concession, Jackson told the governor that EPA would consider allowing the use of propoxur in senior residences, where the risk of exposure to children would be minimal: 

As I explained in my June 2010 letter to you, EPA cannot grant Ohio's broad request because the Agency's risk assessment indicates an unacceptable risk to children . Nonetheless, I committed the Agency to work with Ohio and others to identify comprehensive alternative approaches to address bed bug infestations . As we also discussed in September 2010, EPA is willing to allow the emergency use of propoxur in senior residences in ways that would ensure children are not exposed. EPA staff has discussed this proposal with Ohio officials and have asked them to submit a revised request reflecting this proposal, but Ohio has not yet done so. We continue to hope the state will submit a revised Section 18 request to help provide relief to a highly impacted population.

She also noted that EPA is reviewing new data that might affect the way EPA determines how much exposure to propoxur or other insecticides that children might receive as a result of crack and crevice applications.  So the door is still open for EPA to backtrack should political pressure trump science, as it sometimes does.

Maybe the saddest part of this story is that, according to governmental authority, children don't visit grandma anymore.

U.S. EPA celebrates the 40 year mark

Like Hurricane Katrina and climate change, and the honey bee decline today, the Cuyahoga River fire in 1969 caught people's attention about the state of our environment like headlines never did.

I was in high school when the Environmental Protection Agency opened its doors 40 years ago today. That might not seem like something a high school student would be interested in, but as a budding environmentalist, passionate outdoor enthusiast and Earth Day organizer, I was very interested.

At the time of the late 60's protection of the environment was not a high priority for our government. Concerns about waste disposal, clean air and water, pesticides and wildlife were growing and regularly reported in newspapers and magazines. Thanks in large part to the EPA, there is much to celebrate about the state of our U.S. environment. Streams run cleaner, food is (arguably) safer, the air is much clearer in most parts of the country, and standards for pesticide safety have never been higher. The bald eagle is back, as are peregrine falcons and ospreys and brown pelicans.

We're certainly not without challenges and controversies today. Rapid climate change has even our best scientists perplexed about causes and solutions. Fisheries continue to decline. Pockets of unhealthy air persist. Toxic chemical waste proliferates, even with (or because of) our technological advances to computers. Trash in our streams seems worse than ever thanks to our ubiquitous plastic. Oil hasn't run out, though we see the limits to fossil fuel based energy more clearly than ever. Worldwide, more species have vanished, or are threatened, than we might have guessed 40 years ago.

With all the popular hue and cry about shrinking big government, I for one am thankful that our country had the foresight forty years ago to set up an independent agency to guard our natural heritage.

I know that government itself needs its watchdogs, and EPA is no exception. Nevertheless, I fear that in our scramble to cut budgets, we may forget the progress of the past 40 years, and lose sight of the need for an independent arm of government with an interest in the future of our world at its heart. A strong environmental ethic is exactly the export we need in this era of global exploitation of the environment. Just look at the Aral Sea (formerly USSR, today Kazakhstan and Uzbekistan) and the Yangtze River valley (China) and many of the other environmental disaster areas if you need a reminder of what unrestrained environmental exploitation looks like.

Here's a toast to all the dedicated workers at the EPA who have worked so hard to please Congress and Presidents past, while keeping their eyes on the prize of a cleaner world.

Understanding School IPM 2015

In late 2008 the IPM Institute of North America, a private institution dedicated to promotion of integrated pest management, and the University of Arizona, announced publication of a new national pest management strategic plan for IPM in public schools. Called School IPM 2015, this plan has generated both a lot of interest and some controversy over the past few months.

On the surface, School IPM 2015 is merely the latest in a long stream of relatively obscure documents called “pest management strategic plans” (PMSPs) submitted to the U.S. Department of Agriculture and the U.S. Environmental Protection Agency.These plans are designed for use by the USDA and EPA to identify research, education and regulatory priorities for IPM projects. They are frequently referenced by agencies, like Texas AgriLife Extension, when applying for federal grant funds. The PMSP can help justify the need for IPM projects, and provide evidence for stakeholder support of specific research and extension efforts.

Usually PMSPs mostly gather dust and generate little public interest outside a small cadre of researchers and decision makers. However, School IPM 2015 is catching the attention of a larger, more diverse audience. For one thing, at 286 pages it is the largest, most ambitious PMSP ever developed. Also perhaps, for most Americans the target of the plan, our school children, is of much greater concern and hits much closer to home than, say, a national strategic plan for pest management of broccoli.

The title of the plan refers to its stated goal to develop a plan of action that will “achieve full implementation of IPM in all [U.S.] schools by 2015.” Why such an ambitious goal? According to the document, pest management practices in schools are sorely in need of improvement, with over 50 studies documenting deficiencies, including poorly managed pest infestations and unsafe, illegal or unnecessary pesticides use.

Federal agencies, such as EPA, USDA and Centers for Disease Control have recommended IPM use in public schools for years. Currently 33 states have some IPM requirements for schools, with several states moving toward adopting regulations affecting pesticide use in schools. Nevertheless, most experts agree that the vast majority of schools in the U.S. are a long way from full adoption of IPM.

One of the most important aspects of a successful PMSP is that it must accurately represent the views and priorities of key stakeholders. For School IPM 2015 a core group of approximately 23 extension educators, consultants, environmentalists, pest management professionals, industry representatives and government officials were involved in developing the plan. Nevertheless, in recent weeks, some key stakeholders are crying “foul!”, saying their interests were not represented on the panel.

The National Pest Management Association is the largest trade association for pest management professionals in the U.S. The NPMA recently complained that they were not invited to review the plan before its release. More recently, RISE (Responsible Industry for a Safe Environment), a lobby group that represents pesticide industry, has raised concerns about the plan’s fairness, claiming that it reflects an anti-pesticide bias.

The IPM Institute and other plan drafters are heading back to the drawing board next week to join RISE, NPMA and others to see how the plan can be modified to more accurately reflect all stakeholder views. At stake will be whether the EPA, which has yet to approve the plan, and USDA agree that it lays out a sound approach to the challenge of how to best implement IPM in all the nation’s schools, and that it accurately summarizes key school IPM stakeholder views.

In addition to the issue of bias, questions about whether the 2015 goal is attainable and how to know when full implementation of IPM has been reached, will certainly be a source of lively debate. Indeed even Texas, with its comprehensive school IPM regulations and dedicated regulatory and Extension team, has been working for 14 years to persuade schools to understand and adopt IPM procedures. Few of us would say we have yet reached full implementation. In light of the Texas experience alone, six years seems an awfully short time to attain full IPM implementation nationwide. In my opinion, setting a later, say 2025, date would be both challenging and attainable.

Regardless of the obstacles, one thing that all parties seem to agree on is that national adoption of IPM is a worthy goal. We should all be glad that School IPM 2015 has gotten us talking how we will get there.

Note: The full School IPM 2015 document can be a daunting read at its full 286 pages. You can download an executive summary or the full plan at: http://www.ipminstitute.org/school_ipm_2015.htm

Fipronil to go over and out?

The EPA is considering whether to cancel registrations for granular labels for fipronil products, according to a recent email sent this week to some Extension faculty, USDA researchers, state government officials and customers by Bayer Environmental Science representatives.

According to the email, "In 2001, EPA granted a 5-year conditional registration for broadcast granular products containing fipronil insecticide such as TopChoice® for fire ant control. Since that time, the conditional registration for these products has been extended until May, 2009. The EPA has recently indicated their intention to cancel the registration for fipronil broadcast applications when the conditional registration expires."

If so, this would mean that popular insecticides like TopChoice^® and Over N Out^® would go away, probably for good. Top Choice^® is currently the best option for control of mole crickets in the southern U.S., and both these products find use as a once-a-year treatment for fire ant control.

Although the EPA is not talking on the record about the reasons for a possible cancellation of registration, the official I spoke with noted that the agency has been concerned with the ecological impact of fipronil, especially in aquatic environments. The persistence of fipronil in the environment, and possible biomagnification in some food chains are additional issues for the agency. A review of the ecotoxicology of fipronil by Tingle et. al in 2003 will give you some idea of environmental and health concerns with this product.

Whether granular fipronil remains on the market will depend on how strong a case Bayer Environmental Science can make as well as input received from end users. As far as I can tell the registration of fipronil for termite and ant control is not currently at risk, and may never be. Fire ant baits certainly offer a strong alternative to fipronil granules for fire ant control. But turfgrass managers will miss fipronil as an option for mole cricket control.

The scientific issue at stake is what use pattern might result in fipronil toxicity issues in aquatic environments. It has been well documented that effluent from treated rice fields can impact many aquatic invertebrates and even fish (see for example Gunasekara and Troung 2007. and Stehr et. al 2006) Less well known is how much fipronil might be leaching from treated golf courses or home lawns. As a pest management specialist I would hate to lose fipronil as a tool for turfgrass management. But as an environmentalist and one who realizes the importance of water quality to our quality of life, I don't want to see pesticides eroding the health of our streams and estuaries. Let's hope the EPA uses sound science to make the right decision.

Arsenical Herbicides on Way Out

I normally don't cover weed control topics. But this is one with enough potential impact on Texas PMPs, I thought I would pass it along. This week the U.S. EPA announced that all registrations of the organic arsenical herbicides, including the popular Dallisgrass killer, MSMA would begin being phased out. Residential uses of MSMA and its relatives will be phased out beginning by the end of 2009.

The decision comes as a result of a 2006 Reregistration Eligibility Decision (RED) that concluded that the arsenical herbicides did not meet agency standards for re-registration. The environmental concerns center around the conversion of these herbicides from the less toxic organic (carbon-containing) form in which they are manufactured, into a more environmentally dangerous inorganic form. The inorganic form has the potential to leach into groundwater and contaminate streams and drinking water.

Unfortunately, EPA announcements seem to be written in a language understandable to only a few. But if you want to read one of the less difficult official announcements, here's where to go: http://www.epa.gov/pesticides/reregistration/organic_arsenicals_fs.html

Dallisgrass is the real problem weed for southern turfgrass, for which there are still no good alternatives to MSMA. According to my colleague, Dr. Jim McAfee, Extension specialist on turfgrass, there are currently no alternatives "except a grub hoe". The EPA counters that good turfgrass maintenance will control these difficult weeds, which may be true once they've been eliminated, but is not easy to do in areas where this weed is well established.

Risks and pesticides

I was reading a new product label this morning and came across a phrase that caught my attention. The label stated that "It is impossible to eliminate all risks inherentlyassociated with the use of this product."

This phrase, undoubtedly drafted by a lawyer and--I suspect--ignored by most users of the product, reminded me of a profound principles of pesticide toxicology and safety testing--one that I think few of us fully understand or appreciate: "It's impossible to prove that a pesticide is absolutely safe."

Science is a wonderful process. It allows us to discover useful things about our world. It forms the basis for new technology, answers our deepest questions about the universe, and brings wonder into our lives. Science, however, has it's limits. One of its limits is that it cannot prove absence of harm with complete certainty. It's the old "you can't prove a negative" argument.

Let me give an example. If my job is to test the safety of a new pesticide, I may expose a variety of organisms to my product to see if anything bad happens. Toxicologists routinely do this in laboratories with mice and rats and bacteria. Some tests are designed to measure acute toxicity, others look for evidence of mutations, others for cancer or other chronic disease. Suppose in the course of my testing all the rats develop cancer. This would be alarming evidence that my pesticide might be a human carcinogen. Evidence is strengthened if there are epidemiological studies that show a pattern of elevated cancer rates in humans exposed to the pesticide during its manufacture or use.

Now suppose there are no signs of cancer or other illness in my animals. Have I proved that my pesticide is safe? No. Science, because of physical and economic limitations, cannot prove safety with absolute certainty. For example, pesticide toxicology studies are not generally performed on people for ethical reasons. And people, despite our many occasional similarities, are not rats. Also, we cannot rule out all possible genetic, environmental or health factors that might influence carcinogenicity.

We know of cases, for example, where pesticides have proved exceptionally toxic to people taking certain prescription drugs. In these cases the drugs interfered with the user's ability to detoxify the pesticides, making them more toxic.

If we insisted that science provide absolute proof of safety, the science would become almost infinitely expensive. The best we can do is require a robust set of testing requirements, and base our decisions on the best available science. In addition, there should be a system of reporting suspicious patterns of health complaints associated with pesticide manufacture and use.

This is exactly what we do in the United States. The U.S. has, arguably, one of the best pesticide registration and approval processes in the world. New pesticides are incredibly expensive to register, in large part because of the safety testing required by the U.S. Environmental Protection Agency. The biggest beneficiaries of this regulatory process are those of us who work with pesticides on a daily basis.

So what's a pesticide applicator to do? Follow the label. The answer is so obvious that we often forget to do it. Labels are written to provide wise protection from the admitted limitations of our science when it comes to safety testing. From the precautionary statements, to the requirements for protective clothing, pesticide labels provide uncertainty protection.

Though they can be extremely uncomfortable in heat (especially in our part of the country), gloves, respirators and chemical resistant clothing, when required on the label, are essential to our safety. It may be necessary to explain this to a customer who balks at an applicator wearing gloves or breathing filters. They can be told that the extra protection is required by law (the label is the law) because, unlike them, applicators are exposed on a daily basis to our pesticide tools. It's not an admission of toxicity; it's a common sense precaution. It's an acknowledgement that we don't take unecessary chances with ours or our customer's health.

We should remember that there will always be risks working with pesticides, as with nearly any other consumer chemical product. That's the surprisingly wise message of the pesticide label.