Date: Fri, 03 Mar 2000 19:30:41 -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 read part of an article I found in Vol.8, No.2, or the February, 2000 issue of The Service Technician entitled Field report - Creative Solutions by Doug Seemann. The part I found extremely interesting is as follows:
"Natural" pesticides. A challenge for pest management professionals eliminating pests without pesticides surfaced when Africanized bees moved into Texas and parts of the southwestern United States. Researchers found that if dishwashing detergent (or some other emulsifier) was mixed into a foamy solution and applied to bees, they died almost immediately. In fact, a soapy water solution applied to and enveloping nearly any insect was equally effective.
When one considers the previously mentioned definition of a pesticide, clearly these uses of soap made them pesticides. The problem was that these pesticides did not have an EPA number or a pesticide label. The definition of the word pesticide, and therefore certified applicator, became fuzzy.
Battles between individual state agencies and PCOs ensued. Most states realized that the use of these soaps and other non-pesticide methods was in the public’s best interests as well as EPA’s intent; they chose to ignore the use of soaps, as long as those uses were recorded on service records. The states did, however, argue that these uses constituted the business of pest control, requiring the applicator or supervisor to be certified.
Pesticide manufacturers started to produce pesticides labeled as natural because the public equated the word natural with safe, and therefore, in their opinion, not a pesticide. Diatomaceous earth and boric acid became the most popular of these natural non-pesticide pesticides. Two companies took this concept one step further and found that certain essential oils, extracted from plants (where they protect the plant from insect attack), could be used to kill insects. Best of all, they were exempt from EPA testing requirements and registration because they were considered food items.
EcoSMART Technologies produced a line of pest control products that were all based on one of these essential oils. (Only because) They wanted to keep cockroaches classified as a public health pest by EPA on the label, requiring the addition of an EPA number.
The other company was a large established corporation, Woodstream, best known in the pest control industry as a rodent control product supplier. They selected another essential oil and incorporated into a wasp spray. The product had its name, "Poison Free," printed on the label with EPA’s blessings. The highly promoted product turned out to be as effective as the other conventional ("registered" POISON) wasp sprays, and resulted in two sister products, a "Poison Free" flying insect spray and a "Poison Free" crawling insect contact killer.
These EPA-sanctioned, but unregistered products are now available; however, they are among the first of the official non-pesticide pesticides in the industry and if effective, will undoubtedly result in a wave of similar products. Let’s call this "third generation pest control".
THE NEXT FRONTIER. When school districts heard about new "all natural" products, they responded enthusiastically. A number of districts stated that if these products would be used, no pre-notification or posting would be required.
The public is demanding these types of products and they have already received the endorsement of some environmental groups. There has long been an argument from the industry that IPM does not exclude pesticides. They are one small, but important component of a much larger program. With these new non-pesticides it is possible to offer a true poison-free program.
Well Lyndon, when (in your opinion) will California begin to act in the public's best interest, and join the ranks of "most states" that currently allow the use of unregistered GRAS and/or food grade alternatives to safely and effectively control pest problems?
Respectfully, Stephen L. Tvedten
(Editor's Note: Oddly enough, this is how this ListServe started. Lyndon Hawkins and Mr. Mitchell of the Dept. of Agriculture dissuaded a school district from implementing Get Set's non toxic IPM program because soap and water isn't registered. See: Letter to Dept. of Agriculture and Mr. Tvedten's first email to Lyndon Hawkins )
Please!
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