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Subject:   Florida Defines the words "Pest Control"-----
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 find it interesting that Florida legal statute for pest control (Chapter 482) interprets FIFRA or the federal law by carefully defining "pest control" in several specific ways, but, for the purpose of discussion, let us look at just (20) (a):

(20) "Pest control" includes:

(a) The use of any method or devise or the application of any substance to prevent, destroy, repel, mitigate, curb, control, or eradicate any pest in, on, or under a structure, lawn, or ornamental; (Lyndon, you notice they say ANY - not just your dangerous and I believe ineffective "registered" pesticide POISONS!)

Lyndon, if a licensed pest control operator is allowed to practice his or her "art of pest control" in accordance with this pest control definition, he or she can obviously use whatever means they feel appropriate to do so. Lyndon, this definition clearly does not limit a PCO's "art of pest control" only to their labeled use of your "registered" POISONS! If a licensed PCO chooses to use any of the above unregistered means or alternatives, they are obviously responsible to do so in a safe and effective manner.

If however, if the Pest Control Operator (PCO) decides they will choose to use only your "registered" pesticides or economic POISONS to "control" pest problems, they obviously can avoid their responsibility to actually do what they are paid to do, which is to safely and effectively control pest problems. As long as the PCO only applies your "registered" POISONS in direct accordance with the "registered" POISON's label directions, you "regulators" historically have and probably will continue to "determine" that the "registered" POISON applicator is not responsible for the resulting failure of your "registered" pesticides or economic POISONS to actually and/or safely "control" any pest problems , or for the resulting ECONOMIC LOSSES, or for the resulting CONTAMINATION, HEALTH PROBLEMS, DEATHS, and/or for the ENVIRONMENTAL HARM your "registered" POISONS have continually created.

Well Lyndon, I prefer to continue to safely and effectively CONTROL any/all pest problems using mANY, safe and effective alternatives. As I have said and written you mANY times - I will not use any of your dangerous, ineffective, "registered", volatile, POISONS. My "art" works far more effectively and safely than your "registered" POISONS, so why would I change? One day however, many people will call upon you to ask why you insisted that a licensed PCO in California could only "legally control" pest problems using only your dangerous "registered" POISONS. What will you say to them then?

Respectfully, Stephen L. Tvedten.

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