Florida Takes the Least Harmful Way ... Definition of Terms in FIFRA and Florida IPM 

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Subject:   Lyndon, Do You Know How Florida uses FIFRA to Define IPM?-------
Date:        Thu, 03 Feb 2000 17:19:20 -0500
From:        Stephen Tvedten <steve@getipm.com>
Organization:     Get Set Inc. (www.getipm.com)

To:     Lyndon Hawkins <hawkins@empm.cdpr.ca.gov>
          State of California, Department of Pesticide Regulation
          Integrated Pest Management

Dear Lyndon, I thought you might like to know how Florida defines the words "pesticide and/or economic POISON", with "the way Florida has interpreted FIFRA in their pest control statutes entitled Chapter 482". I also thought I would like to point out to you some interesting points in these definitions:

(14) "Integrated pest management" means the selection, integration, and implementation of multiple pest control techniques based on predictable economic, ecological, and sociological consequences, making maximum use of naturally occurring pest controls, such as weather, disease agents, and parasitoids, using various biological, physical, chemical and habitat modification methods of control, and using artificial controls ("registered" pesticides) only as required to keep particular pests from surpassing intolerable population levels predetermined from an accurate assessment of the pest damage potential and the ecological, sociological, and economic cost of other control measures.

(21) "Pesticide or economic poison" means any substance or mixture of substances intended for:

(a) Preventing, destroying, repelling, or mitigating any insects, rodents, nematodes, fungi, weeds, or other forms of plant or animal life or viruses, except viruses or fungi on or in living man or other animals; or

(b) Use as a plant regulator, defoliant or desiccant.

You will notice Lyndon, that the Florida does not define the words "pesticide and/or economic POISON" as being a substance or substances that can or will actually CONTROL pest problems. Nor will the Florida law allow anyone to say even the LABELED use of these "registered" POISONS is "safe". Whereas the federal law clearly allows the use of unregistered CHEMICALS and many other items to actually CONTROL pests using IPM. The Florida law then states that: ONLY if these MULTIPLE IPM methods/chemicals (or safe and effective alternatives to your "registered" POISONS) FAIL to keep the PARTICULAR pest problem from reaching INTOLERABLE population levels can artificial controls (your "registered" pesticides or economic POISONS) be used.

By the way Lyndon, my use of many hundreds of alternative (IPM) chemicals and/or (IPM) techniques and/or (IPM) tools/products are all clearly natural pest controls that have been used to CONTROL insects since the beginning of time. That is why we have successfully and safely CONTROLLED all pest problems inside and outside in over 350 schools using only various multiples of my many (GRAS and/or food grade) pest CONTROL materials/chemicals. Why is it STILL "illegal" to use common sense and/or safe and effective IPM techniques to actually and safely CONTROL pest problems in California?

Respectfully, Stephen L. Tvedten