What's going on with pest control in Texas?

Who wants to go to a committee meeting?  Especially if you're not on the committee? So if visitor counts are any indication, either things are pretty slow in Austin these days or the Structural Pest Control Advisory Committee is a hot ticket right now. Most visitor chairs around the room were full at last month's meeting in the Texas Department of Agriculture (TDA) headquarters building.  

Bad picture, I know.  But here's proof that
the SPCAC was hard at work last month
at the Texas Department of Agriculture
offices in Austin.

October 30 was the first followup meeting to last spring's lively session focused mostly on TDA Structural Pest Control Service's (SPCS) enforcement activity.  It's no secret that many in the industry feel that "the bad guys" (shady pest control companies operating under the radar and outside the rules in Texas) are not being sufficiently policed by regulators since the former Structural Pest Control Board merged with the Texas Department of Agriculture and formed the new SPCS division.  Based on what I heard at this meeting, I think the TDA has heard those complaints, and is responding, especially when it comes to fumigations.

Several inspection issues were brought up and solutions suggested at the meeting.  Pretreatment notifications have historically been a slow and cumbersome process with inspectors often not receiving word of a planned termite pretreatment until it was starting or already completed. According to official Mike Kelly, the department wants to bring this process online for increased speed and efficiency. This will allow pest control companies to go online to report a pretreatment appointment, and will allow inspectors to get electronic notifications of all planned pretreatments twice a day.  Current rules require operators to call, email or FAX notifications to the department. Last year there were 6,275 notices of termite pretreatment and 1,076 fumigation notices received...a lot of office time.  This change in procedures could save significant staff time handling notifications. Lots of smiles around the table!

Most of us were especially interested in a followup report from last spring's discussion of a May 2013  apparent violation by a fumigator that occurred in Boerne, TX and was detailed at that time by committee member Warren Remmey.  Mike Kelly of TDA explained some of the circumstances around the event including lack of evidence to verify that the fumigator was actually carrying gas cylinders when delivering tarps to a home in an unmarked truck (a violation of SPCS rules). After the meeting the inspector on the site, Kelly reported, the fumigator claimed that the reason no notification was filed was because a truck carrying gas was delayed with mechanical problems, and he didn't know when it would arrive--skeptical looks around the table. Nevertheless the tarps that were installed on the day of the incident remained in place over the house more than a week before the gas arrived and the SPCS was finally notified, and attended the fumigation. 

No citations were issued in the case (no smiles around the table), but Kelly reported that steps have been taken to improve training and enforcement of fumigators by their inspector staff.  For one thing, Larry Riggs of Ensystex, a former regulator, has agreed to help provide fumigation training for inspectors.  Dr. Rudy Scheffran at the University of Florida will also host four inspectors at his fumigation training school in Florida this year. TDA has also formed a task force to advise the agency on fumigation-related issues. Debbie Aguirre of Elite Exterminating, Corpus Christi, has been leading the group. Since the April 11 meeting, TDA has conducted 11 fumigation inspections.  The committee thanked Kelly and the staff for responding to concerns from the last meeting, especially the training initiatives for inspectors. The committee was smiling again.

After this Debbie Aguirre presented suggestions from the task force for changes to the structural fumigation requirements.  One of the major problems her team has identified is that companies often subcontract or sub-sub-contract fumigation jobs, and its not always clear who is the responsible party is when communicating instructions to the customer and when planning the job. TDA staff have agreed to review the fumigation committee suggestions and bring back legally suitable language for a second review by the SPCAC.  

Kelly also announced that TDA is planning to eliminate fees for CEU course sponsors.  Currently anyone organizing a CEU class must pay TDA a $48 fee for each CEU provided.  Kelly says the department has determined these fees were not necessary and will be eliminated.  I sensed CEU providers all over the state smiling at this one.

Also bringing smiles to all the PMPs on the committee was a proposal to change the long problematic rule on advertising.  A problem with this rule has been that the rule was written to require licensed companies to not use false or deceptive advertising. The current wording makes it difficult for the department to penalize unlicensed operators from making false or deceptive claims online or in newspaper.  The advertiser would have to be actually observed making a pest control treatment to be penalized under the existing rule.  Two new paragraphs will be added to the section expanding the rule to apply to anyone offering to perform pest control services. In addition all advertisements must include the official business name as listed on the business license. The committee objected to an additional requirement to include the business license number on all advertisements, and it was removed.  

Also in response to requests to provide more information about enforcement actions, Stephen Pahl introduced new staff members including new chief counsel Martina Berrera, a former prosecuting attorney and judge.  She has been with the department for two months and is eager to get to know the industry and work to address concerns. She replaces outgoing counsel David Gibson.   

The SPCS includes both "Program staff", including inspectors, and "Enforcement staff". Program staff are required by law to conduct 480 inspections of non-commercial applicators, 200 use observations of structural licensees, 950 commercial business inspections.  In addition they must inspect approximately 250 school districts each year.  Also program staff must respond to complaints (46 so far in FY2014). Not all violation cases investigated by program staff get turned over to enforcement.  In 2014, we learned, program staff forwarded 40 cases involving unlicensed activity to Enforcement. For schools with unlicensed activity a non-compliance advisory letter is usually sent without a fine.  For violations at commercial businesses and non-commercial locations, Enforcement may issue a Notice of Violation (NOV), a warning, or take no action (e.g., when a business has shut down or the complainant may not be willing to pursue the case).  

Numbers of consumer complaints (46) have decreased significantly this year from prior years (ave. 181 per year 2011-13).  Although the agency reports that the number of consumer complaints have been decreasing for the past 12 years, this year's large drop appears due largely due to the department no longer accepting consumer complaints about poor service or failure of a company to control pests. Now the only complaints accepted for investigations are those involving possible infractions of the rules or law. As I see it, this amounts to a significant change in policy, redirecting the agency away from  consumer advocacy, to being a law enforcement agency only.  These changes appear to be necessary given tighter budgets over the past several years.  Mostly blank faces on the committee.

Visitors who attend these committee meetings do get an opportunity to comment if they wish.  Don Ward left a comment from the Texas Pest Control Association suggesting that SPCS host a class for pest control office staffers to appraise them of what they can and can't say and do.  He also indicated TPCA support for the advertising changes. Bryan Springer with Bevis Pest Control, Houston, commented that with all the regulations and safety requirements in place, the safety record of professional fumigation is good.  Harvey West of Coastal Fumigators, Houston, encouraged SPCS to provide and train inspectors to carry fumigant gas measurement devices to ensure accurate dosing of commercial fumigations.  He also urged the department to do something to discourage the practice of allowing spot treatments for drywood termites to suffice for passing real estate transactions.  Spot treatments are notoriously unreliable for eliminating drywood termite infestations in homes.

The committee adjourned after approximately a three hour meeting.  Smiles all around. 

A Who's Who of WDIs

Recently I received an inquiry from a Texas pest control company wanting to know if there was a list of official wood destroying insects (WDIs) in Texas. Since there are some specific instructions in state regulations governing WDI inspections, you would be excused for thinking that there might be an official list. But if there is, I can't find it.  If you go to the relevant section of the Texas Administrative Code, the rules say "The purpose of the [WDI] inspection is to provide a report regarding the absence or presence of wood destroying insects and conditions conducive to wood destroying insect infestation."  However, the rules don't specifically define what consists of a WDI.

So in lieu of any official list, here is my list of the important WDIs in Texas.  If you're from another state, the list is likely to be similar, although the relative importance of each of these pests varies from region to region.

Termite wings provide good diagnostic clues to the type of
termites infesting a home. Reticulitermes wings are smooth,
without hairs, and have two heavier veins along the leading
edge of the forewing.

• Subterranean termites (Reticulitermes species. Note: when the word "species" is written after the genus name, it refers to multiple different species within the genus). Knowing the exact species is not important for a professional doing an inspection, but keep in mind that there may be some differences (e.g., swarming times or potential for destruction) among the different termite species.  The most economically important termite species in Texas, and the U.S., is Reticulitermes flavipes, the eastern subterranean termite. These termites are called "subterranean" because they need contact with the soil, and almost always maintain their nest underground while foraging on both underground and above-ground wood.  Inspections should focus on looking for alates (swarmers) and the presence of mud tubes extending from the soil into the structure.  Alates can be confirmed as Reticulitermes by their forewings, which bear two strong, dark veins along the leading edge.  Wood damage from this and other Reticulitermes species consists of galleries chewed into the spring wood, following the growth rings. Also, because they are subterranean, gallery walls will be covered with specks of "mud", a combination of feces, saliva and soil.  



Formosan alate wings are covered with fine hairs, visible
under magnification.



Drywood termite wings are often dusky and have at least
three strong veins along the leading edge of the forewing.

• Formosan subterranean termites Coptotermes formosanus. This is an exotic termite species that has established in parts of Texas, but is also found in other parts of the South and in parts of California. One of the principal means of its spread appears to be via recycled railroad ties.  The Formosan termite belongs to the same family as Reticulitermes termites, and shares some of the same characteristics, including subterranean nests and mud spattered galleries; hence, it is also technically a "subterranean" termite. Identify Coptotermes by its nighttime swarming habits and its large, yellowish-colored alate.  The wing veination is similar to Reticulitermes, but the wing membranes are covered with fine hairs.  Workers are not easily distinguished from our other subterranean species, but soldiers have a teardrop-shaped head, contrasted with the rectangular head of Reticulitermes workers.  Galleries are similar to other subterranean termites, but Formosan termites produce "carton", a dense, honeycombed structure made from mud and wood pulp cemented together with saliva and feces.  
• Drywood termites (Cryptotermes and Incistitermes species) The so-called drywood termites are distinguished from subterranean termites by their above-ground nests and lack of contact with the soil. Because they live in wood, which usually has lower moisture content than soil, drywood termites are very efficient conservers of water. The most obvious sign of this skill are the fecal pellets they produce. Unlike the wet, smeared feces of subterranean termites, drywood feces are hard, dry pellets.  In the drywood termite rectum all water is squeezed from the feces by six rectal pads, leaving small (1/32 inch-long), six-sided pellets. Finding these pellets is hard proof of a drywood termite infestation. In addition, drywood termite galleries do not follow the grain of the wood, but may extend across multiple annual rings. Alates fly at night and have three strong, dark veins at the leading edge of the forewing. Drywood termites are most common in warm, high-humidity regions, such as the Gulf coastal areas, and parts of southern California.  They may be found in other parts of the country, however, when brought in on furniture or infested lumber. 

  

  Lyctid powderpost beetle adults (left) are distinguished from
  the common pantry pest, red flour beetle (right), by their
  round eyes and two-segmented antennae.  

• Lyctid powderpost beetles (family Bostrichidae, subfamily Lyctinae). These small, cylindrical beetles are usually brought into homes in infested hardwood trim or flooring, or in infested furniture. They are one of the most important WDIs in Texas. If you're not in the habit of looking carefully for signs of these beetles during a WDI inspection, you're opening your business up to a potential legal mess. The presence of these beetles in new homes has become highly litigious, as the owners look for someone to blame for their new, beetle-infested home. It's critical to look carefully at all hardwood trim, including wainscoting, baseboards, windowsills, cabinetry and wood flooring.  On horizontal floors or trim, sawdust usually accumulates in volcano-like piles surrounding the adult beetle emergence hole.  On vertical wood, small piles of very fine, almost silky, frass will accumulate on cabinets, edges or floors underneath the emergence hole. Adults can be distinguished from the similar-appearing red flour beetle by their darker color; globular, protruding eyes; 2-segmented antennal club and enlarged hind coxae.   



Carpenter ants are easily identified by their large size, single
node between abdomen and thorax, and smoothly rounded
thoracic profile.  Many Texas species are bi-colored, like this
specimen; but color alone can be misleading.

• Carpenter ants (Campanotus species). This insect is usually listed as a WDI; however in Texas carpenter ants are not very likely to do structural damage. They are more likely to occur in small colonies in wall voids and in insulation, but rarely as destroyers of sound wood. Some species of carpenter ant, like C. modoc and C. pennsylvanicus, are well-known wood destroyers, especially in the Pacific Northwest and in the northeastern states. They have given all carpenter ants a reputation as wood destroyers. For this reason, and because they are not difficult to report, I would recommend including carpenter ant evidence on a WDI inspection report.  The similarly-colored (but physically very different) acrobat ant, is not reported to eat or damage wood, therefore I would not report it as a WDI.  Carpenter ants are relatively easily identified by their large size, polymorphism (different sized workers in the same colony), single node and smooth curved thoracic profile. Inspectors should also be on the lookout for carpenter ant frass, which is the colony's trash dump.  Frass piles may include wood, insulation, dead insects, and sometimes pupal cases.  Any unusual debris piles that contain insect fragments are likely carpenter ants.



The old house borer is a medium-sized beetle (0.6 to 1 inch)
with two raised bumps and a mustache-shaped ridge on
the pronotum (shield behind head).

• Old House borer (Hylotrupes bajulus). The round-headed borer family, to which the old house borer (OHB) belongs, consists mostly of larger beetles with long antennae.  Most infest only dying or recently killed trees, so pose little long-term threat to a structure (although they may emerge from infested wood in the first year or so of a new home).  The OHB is an exception to the low-threat rule because of its ability to re-infest homes after its first emergence. Most infestations occur in homes up to 10 years old, but they can also infest and re-infest older homes.  According to Dr. Harry Moore, retired WDI expert from North Carolina State University, the OHB prefers wood with moisture content between 15 and 25%.  This moisture level is higher than normal in all but the more humid parts of the country.  Adult beetles are distinctive, emergence holes are oval in shape and 1/4 to 1/3 inch maximum diameter. Frass consists of very fine powder and tiny, elongate, blunt-ended pellets.  Infestations of OHB are most common in the humid Piedmont areas of the mid-Atlantic seaboard; however they can be found in homes throughout the eastern U.S.  Infestations are relatively rare in Texas.



Bostrichid beetles are mostly a minor WDI pest.  The rasp-like
pronotum and cylindrical body with abruptly angled wing
tips are characteristic of this family.

• Anobiid and other Bostrichid beetles.  Any emergence holes in structural wood or trim, of course, should be reported on a WDI report.  However, when the other pests listed above are ruled out, most of the remaining culprits will belong to miscellaneous species of anobiid (ANN oh BEE id) and bostrichid (boss STRICK id) beetles. Nationwide, anobiid beetles are the more important group.  These beetles feed on sapwood of both hard- and soft-woods.  They leave circular exit holes 1/16 to 1/8 inch in diameter, and produce a fine powdery frass with conspicuous pellets.  Adults of these beetles are relatives of the cigarette beetle and have a similar with a oval to cylindrical shape and downward pointing head, hidden from above.  Anobiid beetles thrive in wood with higher moisture content (15-30%) and probably for this reason, infestations in Texas are uncommon except in damp crawl spaces.  Some of the smaller holes bored by anobiid beetles may be confused with Lyctid powderpost beetles, but the frass is distinguished by the presence of rough pellets.
       Bostrichid beetles (with the exception of the Lyctid powderpost beetles) are generally incapable of re-infesting wood. Holes made by emerging adults are round and 3/32 to 9/32 inch in diameter.  Frass is tightly packed inside tunnels and tends to stick together.  Most bostrichid beetles have several rasp-like teeth on the front of the pronotum, presumably to aid in collecting and packing frass in the galleries.  One of the most common ways bostrichid beetles are introduced into homes is via wicker baskets and furniture.

Look out for signs of drywood termites

Drywood termites are not a common problem in many parts of Texas, except along the coastal bend areas from Port Arthur to the lower Gulf coast. Nevertheless, drywood termites can show up anywhere in the state. For this reason, PMPs should always be on the alert for signs of these insects.

Drywood termites belong to a different insect family (Kalotermitidae) than the more common subterranean termite (Rhinotermitidae). One of the differences in this family is that all colony workers are immatures, and there is no true worker caste. Another difference is these termite's ability to conserve water and live with no direct soil contact.

One of the best clues that drywood termites are present in a home is the presence of many tiny, six-sided fecal pellets that are ejected from the colony by the termites, or which spill from damaged wood that has been exposed by probing or carpentry activity. The pellets themselves are easier to spot than the ejection holes; but once found, ejection holes can be used as a portal to inject foam or liquid termiticides into infested wood.

Fecal pellets are often less than 1 mm long, and vary in color from light tan to reddish to black. Surprizingly, the color of the pellets seems unrelated to the color of the wood on which they feed. Look for pellets along molding in living areas, when conducting attic inspections, and around window areas. Wings are another sign of drywood termite activity. Look for termite wings in window areas or spider webs in the corners of attics or rooms.

Just because you've never seen drywood termites in your community before doesn't mean they aren't there. Away from the more temperate, humid areas of the state, where they swarm and spread naturally, most drywood termite infestations are imported by humans via furniture or construction lumber. Because these termites reproduce and feed more slowly than subterranean termites, it may take many years for the colony to mature and begin producing swarmers.

Drywood termites are a good example of a pest that may or may not be seen frequently in your area, but one that all pest management professionals should know something about. Keen eyes and an ability to spot things out of the ordinary are skills that will help separate you from your competition.