Spring Pest Management Training 2013

Skunk and armadillo control is one of the topics covered in
this spring's pest management training.

I thought I would share an upcoming training opportunity that might be of interest to Insects in the City readers around north Texas. Next week, March 7, is the Spring Pest Management Seminar at the Texas A&M AgriLife Center at Dallas. This year's program should be a good one, and (if you need it) will provide you with all the CEUs you need for another year, whether you are a certified non-commercial applicator through TDA, or licensed through the Structural Pest Control Service with categories in pest control, turf and ornamental, and weed control.

This year's speakers include Janet Hurley, providing an update on the new pyrethroid rules, Charles Adams with Sherman ISD speaking on skunk and armadillo control, Ross Eckstein from Syngenta covering weed control, Dr. John Rowland with Bayer Environmental Science talking about insects of urban landscapes, and me, talking about mosquito control.  Three of our speakers are new to the seminar series, so this will be a great opportunity to get fresh insights and new IPM information.  I'm especially interested in the skunk and armadillo talk from Charles Adams.  Charles has many years of experience in school IPM and running his own wildlife control business. I've listened to Charles teach, and he really knows his wildlife.

Registration is online and can be accessed here--type in keywords "Spring IPM".  For a copy of the program brochure, click here.  Cost is $70 if you get your application in by March 4, otherwise it's $85 at the door.  Lunch (brisquet and chicken BBQ) is provided.  Hope to see you there.

Tawny crazy ant name proposal hits streets

Tom Rasberry points out one of the early known
infestation sites of Nylanderia fulva close to the
Houston ship channel in Houston, TX (2004)

The crazy ant first discovered in Texas by PMP Tom Rasberry, may be getting a new common name.  As I reported in an earlier post, the way for a new name was opened with the recent publication of research firmly identifying the ant variously known as the Rasberry crazy ant, hairy crazy ant or Caribbean crazy ant (depending on what state you are from).  As it turned out, the ant was decidedly NOT the Caribbean crazy ant, Nylanderia pubens, but another species originally described from Brazil, Nylanderia fulva.

This week the Entomological Society of America's (ESA) committee on common names approved a new common name which has received lukewarm support.  The last step before formal acceptance of the official common name (which I and most entomologists will likely start using) is for the proposal to go before ESA membership for comment.  The proposal is located at http://www.entsoc.org/PDF/2013/names/tawny-crazy-ant.pdf, and does a pretty good job of detailing the background of the controversy and listing authorities who both support and oppose the new name.

If you are an ESA member, this is your last chance to let your voice be known. Please submit any comments by March 13, 2013 to Greg Dahlem, the committee chair, at dahlem@nku.edu.

Interestingly, there are colleagues of mine from Texas A&M who both support and oppose the new name.  Dr. Bart Drees (Texas A&M AgriLife Extension) supports the name change, and Dr. Roger Gold (Texas A&M University) opposes it, along with (not surprisingly) the Rasberry family.  Dr. Gold thinks "tawny" a little dull, and argues that a more descriptive name is needed.  He suggests "Brazilian crazy ant," to commemorate where the ant was first discovered.  I think I like Brazilian crazy ant better than tawny crazy ant; but I have another name to propose.  I suggest we call it the "troublesome crazy ant".  I'm sure that's one name most of the people who encounter this tiny invader could agree on.

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'. 

Critiquing insecticides as a last resort

Pesticides may not always be the worst environmental choice
when considering pest control options, according to a
recent scientific society position paper.

Two weeks ago I wrote about a recent position paper by the Entomological Society of America and its sister societies, American Phytopathological Society and the Weed Science Society of America. The paper critiqued some popular integrated pest management (IPM) concepts, including the idea that IPM programs should use only "least toxic" pesticides.  The same paper also addressed the widely adopted idea that pesticides should only be used "as a last resort" in an IPM program. Today I wanted to elaborate on use of pestcides as the last resort.

The concept of "last resort" pesticides is tricky because it's meaning is open to different interpretations. On the one hand, using pesticides as a last resort could mean that pesticides are used only when pest numbers or damage from exceed some pre-determined threshold. The use of thresholds is usually invoked in combination with a pest monitoring program and with an integrated control strategy including non-chemical tactics such as habitat modification, sanitation and quarantine. This is a proven IPM approach that has been used since the earliest days of IPM.  As the Societies' position paper points out, however, this is not the only possible interpretation.

Many agencies and regulators have interpreted the "last resort" imperative to mean that when a pest problem occurs, all non-chemical controls must first be attempted. Only when all else fails, should pesticides be considered. There is a subtle but important difference in these two interpretations. In the latter case, thresholds are made secondary to a process of trying first one non-chemical control, then another and then another, before finally turning to a pesticide. Such delaying tactics, according to the statement, can lead to unacceptable pest buildups and damage.

From my perspective, this approach was used last summer in my community during an outbreak of mosquito-borne, West Nile virus (WNV). While medical doctors in our city were worried that too many human cases of WNV had already occurred, and that aerial pesticide spraying was needed break the epidemic, those in the community with deep misgivings about pesticide use were insisting that not enough had been done in the areas of public education, breeding site removal, and larvaciding. They requested that the cities and county wait until everything that could conceivably be done before resorting to spray planes.  They were essentially invoking the "last resort" concept.

While this approach may seem reasonable on the surface, it's consideration resulted in delay and ultimately nearly 400 (serious) human cases of the virus in my county alone.  A predetermined threshold (say, to commence aerial spraying when education, source reduction and ground sprays fail to prevent mosquito infection rates from reaching levels likely to result in human cases) would have alerted the community that preventive tactics had already failed, and more aggressive controls were needed.

The ESA position paper provides links to a number of similar cases where following the "last resort" approach led to out of control pest problems and higher control costs. Many of these examples illustrate that waiting to control a pest may result in missing the ideal time to treat, and may ultimately result in the need for higher concentrations and more applications of pesticides to control a pest infestation.

Finally the position paper points out that the "last resort" concept implies that pesticides are always the worst choice, which is not true. Non-chemical techniques are sometimes more expensive, require more labor and energy, and result in lower levels of control than chemical pesticides. An example cited from Texas was conventional tillage to control weeds in arid farmland.  A study showed that herbicide use not only was more effective in conserving critical water, but it was less costly.

Rather than talking about "using only least toxic pesticides as a last resort", I believe we remain truer to the original spirit of IPM if we talk about "minimizing risks" and "using pesticides only when necessary" to prevent or control damaging levels of pests. Integrated pest management has never been easily distilled to a simple formula or prescription.  Each pest and situation is unique and deserves a flexible approach to do the right thing. This flexibility of IPM is both its greatest strength and, perhaps, its greatest weakness.  Flexibility is a weakness because IPM is difficult to codify, and develop rules for that fit all situations. But flexibility is a strength because IPM is adaptable to many settings--not just agriculture for which it was originally developed.

TDA meets with its advisory committtee

While the bright lights and news cameras focused on Austin politicians introducing their latest bills at the 83rd Regular Legislative Session, the Structural Pest Control Advisory Committee met quietly this week with leaders of the Texas Department of Agriculture's Structural Pest Control Service.  The focus of the meeting, as always, was to provide TDA administrators with feedback on new ideas for how to streamline operations and minimize pest and pesticide risk to the public.

The flu season may have explained the low turnout at this quarter's meeting (the first time I recall no public comments), but committee members still found stuff to discuss, especially with regard to the first draft of TDA's proposed penalty matrix.

So what's a penalty matrix? It sounds boring.

I guess a penalty matrix is pretty boring unless you're the one being penalized. The SPCS has always used some form of matrix, or chart, to assign penalties to different possible violations of the Structural Pest Control Act and its regulations.  Under the law, the TDA Administrator is given leeway in assigning penalties to violators, up to a maximum fine of $5,000/violation/day and/or license suspension, revocation or denial. The matrix provides a transparent and objective means of pre-assigning penalties for different violations.  While not constraining the Department from giving a higher or lower fine, it sets guidelines for fair penalties if you, say, fail to provide an inspector with a valid applicator's license.

The draft guidelines list approximately 70 possible violations and puts each into a table of low (S1), medium (S2) or high (penalty) violations.  Within each of these three tables an offense can be categorized as minor, moderate, or major. Penalties increase in each of these columns from the first to third instances of violations over a five year period.  So there are three tables, each with three rows and three columns of penalties.

For example, failing to have your company's TPCL number on any vehicle in which you do pest control business is considered (in this draft) to be an S1-Moderate violation. You would expect to receive a $150 fine for a first violation.  That fine would increase to $300 and $450 fines for the second and third violations.

Moving up the scale, failure to provide an accurate or complete WDI Report is an S2 Moderate violation, worth $750 for a first offense.  Operating out of category (say doing weed control without a weed license) is considered an S3-Moderate offense, and will cost you $1000 for a first offense.

While assigning penalties to a long list of crimes may sound a little like a job for Les Miserables Inspector Javert (Russell Crow in the latest movie musical version), having the matrix is to everyone's benefit. It makes the TDA's job easier and more objective, and it adds transparency to the process. Anyone can look up the matrix online and know exactly what to expect for a given violation.

The committee's job in all of this? Review all the assignments and penalties and give our input. It's not as fun as it sounds.

Perhaps the most upbeat news to come out of this quarter's meeting was the announcement that TDA has decided to contract out its examinations to a private firm.  PMPs should see some immediate benefits such as lowering of fees from $75 to $64 per exam. In addition, the number of locations will increase from 13 to 23 offices around the state.  Exam locations will no longer be associated with TDA or other government offices.  And sites will be open five days per week, with registration open 24/7.  This should speed up the process of getting new licensees on the street considerably.  The only down side to the announcement is if you are computer-phobic.  All exams will be online and you will receive score feedback immediately.

The committee also discussed ways that TDA could better reach the public with a simple message that when hiring someone to control pests, make sure they are licensed and qualified. One of the ideas proposed was to make that official message available through the many pest control company websites around the state.  Look for TDA to come up with creative ways to get the word out to the public about the value of your pest control license and your training over the next year.  They may be contacting you for your company's help.

A critique of the IPM gospel

The three largest U.S. scientific associations with strong professional connections to integrated pest management (IPM) recently posted a news release that should be of great interest to anyone in the business of pest control. The Entomological Society of America, Weed Science Society of America, and American Phytopathological Society published a position paper last November that, while it has not received a lot of attention in the press or the industry (let's face it, IPM is not the sexyist topic), takes careful aim at some favorite concepts embraced by the  IPM community.  While the statement may read like heresy to some IPM supporters, I believe their arguments are well-thought out, and worthy of consideration by everyone with a stake in pest control.

First, a little historical background.  The IPM concept was first embraced by agricultural scientists, and later by those involved in urban pest control. The earliest versions of IPM emphasized the use of both chemical and biological methods of pest control. As IPM matured, it accepted that the judicious use of pesticides was desirable, as long as every effort was made to minimize the environmental and safety impacts of pesticide use--an approach still followed by most of those in production agriculture.  

As IPM evolved it was embraced by the environmental community and by regulators, and eventually by urban pest management professionals. Along the way IPM jargon, and the way it was implemented, also evolved.  One of the most influential modern attempts to articulate the IPM concept for human-occupied structures was the 1993 EPA publication, Pest Control in the School Environment: Adopting Integrated Pest Management. In this publication (painstakingly crafted by environmentalists, the EPA and the National Pest Management Association), the judicious use of pesticides was endorsed as long as the "least toxic and most effective and efficient technique[s] and material[s]" were used. This seemed to be a compromise that all parties could live with, and everyone seemed happy.

Over these past twenty years the idea that "least toxic methods" should be part of the definition of IPM has reached the status of gospel. The term "least toxic pesticides" and "least toxic methods" is ubiquitous in IPM policy statements and even governmental rules and regulations. Its authority is rarely challenged by industry, academia or politicians--after all who wants to argue that schools or government agencies or your local PMP should use anything but the least toxic products?

Most of us have been taught to avoid "rushing in where angels fear to tread", but that's just what these three societies did by taking a stance against the "least toxic pesticide" concept.  It's not that my scientific colleagues are against the use of low toxicity pesticides, their argument is with the increasingly common insistence that "only 'least toxic pesticides'"' be used in IPM programs.

I encourage all to read the statement, but their objections boil down to the following:

• The term "least toxic" is too imprecise, and subject to misinterpretation by the public and by professionals alike. I can personally attest that many people wrongly equate "least toxic" with "organic" and "natural" (neither of which have any necessary connection to the least toxic concept--many natural chemicals are highly toxic). 
• Toxicity is not the same as "risk". An active ingredient can be highly toxic, but when diluted or made into a formulation that is highly unlikely to result in a human exposure, its use can be low risk. What consumers and regulators and parents should be most concerned about, when it comes to pesticides, is risk. 
• Least toxic to what? If an insecticide is low in toxicity to bees is it necessarily low in toxicity to dogs or humans or song birds? The least toxic concept presumes that pesticides fall neatly into a gradient of products range from those low in toxicity to everything to those that are high in toxicity to everything. They don't. 
• If only the least toxic products are used, this limits what can be done to manage pesticide resistance. A policy that rejects the possible use of 90%, say, of the available pesticide products leaves a much depleted tool belt, increasing the risk of pests developing resistance to the one or few remaining products. 
• The least toxic products are not always the most effective products. Indeed, if toxicity is the main selection criterion, then effectiveness is by necessity relegated to a secondary role. In many cases this means more applications of the least toxic product will be needed. Fuel, labor, pesticide exposure times and materials costs (none of which are environmentally desirable) will always increase with the need for more frequent pesticide interventions.

In case you think this is much ado about nothing, consider the wording of the Texas Occupations Code where it lays out the requirements for school IPM in my state.  The language of this code has been used as a model for other states' IPM regulations.  It directs the state to "include in standards adopted under this section: (1) a requirement to use the least toxic methods available to control pests, rodents, insects, and weeds..." The potential negative impacts of this language were blunted when Texas state regulators adopted a liberal set of regulations that allowed use of any pesticide in schools, but required schools to justify in writing the use of products identified as higher risk pesticides. In practice, this soft-handed approach has resulted in schools using lower risk insecticide approaches, without restricting choices. Other states and communities have seen regulatory language not so friendly to pesticide choice.

I have great sympathy with policy makers trying to encourage homeowners and pest management professionals to use the lowest risk, effective pesticides.  On the other hand, I agree with the ESA/WSSA/APA critique of the "least toxic" concept. The hard part is coming up with better approach that encourages pesticide applicators to use good judgement when selecting pesticides and pesticide formulations to supplement biological and other non-chemical controls.

For their part the societies point readers to the National IPM Roadmap as a source of guidance. The Roadmap was developed ten years ago and used as a guidance document by the USDA in developing a national plan to improve and encourage the adoption of IPM. Significantly, this roadmap does not use the term "least toxic" or "use of pesticides as a last resort", but emphasizes IPM as a process that identifies and reduces risks from both pests and pest management related strategies (including pesticides).

The second target of the society position paper is that idea that pesticides should be used only as "tools of last resort". But that will be the topic of another post.

Pest Prevention by Design

Imagine a community where the newest buildings were pest resistant. It would be a place where architects and engineers worked hand in hand with pest management experts to take pests into consideration during building design and construction. Foundations of these new buildings would be reinforced with termite barriers, kitchen walls could be opened easily for inspection and treatment, access points to electric utility chases would be easily reachable, exterior doors and utility penetrations would be rodent-proof, and birds would find few easily accessible perches or nesting holes. Now imagine schools and government buildings, homes and shopping centers with features that greatly simplified pest control and reduce the need for pesticides.

That's the idea behind the new Pest Prevention by Design Guidelines published this month by San Francisco Environment, a department of the city and county of San Francisco, CA. The principal author and leader of this effort is Dr. Chris Geiger, a trained entomologist and Urban Pest Management Program Manager for the City and County of San Francisco's Department of the Environment. I love Chris' up-front and down-to-earth admission in the report:

"The world is blessed with many charming, pleasurable, glamorous and enticing subjects on which to ponder. Pest management is not one of these."

How true. But of course a world without pest management would be unlivable too.

The format of the report is clean and easy
to follow. The recommendations are based
around 18 building features, and cite technical
references for the guidelines where they exist.

The new publication was and is a team effort, involving a Technical Advisory Committee that included pest management experts, PMPs, architects, and engineers. Universities in the mix included Cornell, Penn State, Texas A&M, UC Davis and Riverside, and the NJ Institute of Technology. The National Pest Management Association was involved, as well as several pest control companies.  My point is, this is not just the wild imaginings of some California tree-huggers (apologies Chris), but a serious effort to start a dialogue between us in the pest control industry and the folks who build both green and not-so-green buildings. The project was funded by the Centers for Disease Control.

I think anyone with an interest in the subject of pest proofing, owes it to themselves to take a look at the report. The authors limited the scope of the document to commercial buildings, and it is far from a perfect or complete document, as the writers will admit. But it's a start.

Looking forward there are several hopes for this project. First, we intended it (yes, I was involved too) to serve as a starting point for better dialogue with architects and engineers--two groups that historically have not been very interested in pest control.  With the current interest in green or sustainable buildings (IPM is actually a part of today's LEED green points rating system) it appears that the time may be ripe to entice these folks to take pest control more seriously. Consider that built-in pest control should mean longer useful lives for buildings, more pleasant and livable indoor environments, cleaner air and less need for pesticides--all admirable green goals.

Second, we hope that the guidelines will be referenced by green building advocates, builders of schools, those in the apartment and hospitality industries, and government officials wanting to reduce the long term maintenance costs of public buildings.  After all, pests are  frequent contributors to building decay and decline--an expensive problem for all.

Last, we intend these guidelines to be a living document. Ultimately it is intended to reside as an editable database, where suggestions and revisions can be made over time. Once a suitable web home is found, it will be easy to update and improve. If, as you read through the document, you see things that can be added or improved, we want to know about it.

I can hear grumbling by some that "if we build pest proof buildings there won't be any work left for PMPs". That I seriously doubt. It's my personal belief that as long as there are people living in buildings, there will be plenty of pests. I think that what this effort does is raise the status and profile of pest management into more of a science and less of a fire station mentality (constantly putting out preventable fires). There will be a need for PMPs to get involved with the building planning and execution process. Yes, if this concept catches on, there might be less for PMPs to do in these newer and greener buildings; but the lost jobs will be the kinds of problems that no one wants anyway--those institutionalized, chronic pest problems that seem to never go away because of filthy conditions or rundown facilities.

As for me, I know I'd rather live in a condominium or apartment, or stay at a hotel, or eat at a restaurant that was built with IPM in mind. Wouldn't you? And that's what pest prevention by design is all about.