Questions have been asked of the California Department of Pesticide Control since Fontana Unified School District declined to consider a pesticide free IPM program because of the Department of Agriculture's opinion about only utilizing registered pesticides to eliminate pests.  The California Department of Pesticide Regulation has remained silent and not responded to these issues:

Subject:               Letter of 6/19/98
    Date:                Sat, 20 Jun 1998 19:06:20 -0400
   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

On 6/19/98 Lyndon Hawkins wrote:

Linda:

Thanks for the email.  My FAX number is 916-324-4088.   I talked to Steve a year ago or so and he sent me his IPM manual.  I  have not revewied it for awhile, but I am definitely concerned with two aspects of any pest management procedure, strategy or product.  If there  is a chemical (microorganisms are included) where claims about pest  control are made, the substance must be properly researched and  registered.  I looked at the homepage you referred to and it stated on products instructions for mixing and applying to a pest  situation.  Under certain products, there was a statement "not sold as an insecticide"  My understanding is that this type of product would  have to be registered.

Larry is correct in not using any unregistered products in a school  environment, particularily from an legal and potential liability  standpoint.

Response:

June 20, 1998

Dear Lyndon Hawkins:
 

Your above e-mail of 6/19/98 has been handed to me for reply. For the record, I believe that Mr. Larry Wilkie is already using most of the unregistered products I recommend - but, he is not currently using them for pest control.   I have, via copy of this e-mail, asked Linda Pascarella to give you a copy of my latest Chapter 13 to review.  Bear in mind, this work is in process of being revised, changed and corrected.  You will note I have tentatively mentioned Mr. Jim Mitchel at the end of this chapter that as yet has not been copyrighted or printed.

The question I continue to ask both Mr. Mitchel and you is very simple, "Is it really 'illegal' in California to use non-toxic or GRAS materials or techniques to control or eliminate pests or must you only use dangerous 'registered' poisons that do not control pests but do kill and/or injure children, pets and the environment?"

A dirty garbage container can produce 1,000 flies and 2,000 maggots in a week.  Is it really "illegal" to wash your can in California?  Obviously, in cleaning your can with unregistered soap and water (that you already have on hand} you will also "inadvertently" control odors and kill/control the flies and the maggots present and prevent future filth fly populations better and safer than any "registered" pesticide poison ever has.

For the record, I do not sell any products, but I do suggest people use other companies' products, e.g., dish soap, to safely control pest problems.  The companies that manufacture and sell hundreds of safe products, e.g., dish soap, really do not want their harmless (non-toxic or GRAS) products to be registered or to be called dangerous pesticide poisons, nor do I believe that is necessary under FIFRA - EPA has already exempted hundreds of safe products that control pests from the poison "registration" process.

The real question regarding the "registration" of pesticide poisons currently being used in California "legally" is clearly addressed in detail in Chapter 13 - I believe there really are no currently "registered" synthetic, pesticide poison "products" - there are, however, a few "registered" active poison ingredients and a lot more "extended and still untested/unresearched" active poison ingredients and a whole lot more of totally unregistered, unresearched and untested "inerts".  But no currently "registered" synthetic pesticide (total poison formula) or "product" is even looked at, considered or researched or tested in total.  Therefore, all currently "registered" synthetic pesticide poisons are all unregistered poisons and they are all obviously totally unresearched, yet all "legally used in California."  Therefore, your e-mail statement: "If there is a chemical (microorganisms are included) where claims about pest control are made, the substance must be properly researched and registered" is very interesting to me.

I currently recommend over 1,500 (non-toxic or GRAS) products including dish soap and water to safely control many pest problems.  No one considers dish soap and water to be very dangerous, yet no synthetic, "registered" pesticide poison currently being "used" in California to "control pests"  can legally or honestly make the claim they are as safe as dish soap and water.  No synthetic, registered" pesticide poison that I know of currently being "used legally" in California to "control pests" can make the claim that the entire poison formula has even been put on the label to be looked at, much less has been properly researched; in fact, even most of the active poison ingredients have not been properly researched.  As you are very aware, most "registered" synthetic pesticide poison active ingredients have only been "extended" and never have been "properly researched".

If you have any data available that shows the entire poison formulas for all of the synthetic pesticide poison compounds currently "registered" for "use" in California  that clearly shows that all of the poisonous/toxic components have all been "properly researched", I would really appreciate a copy of all this documented research, especially for all of the "registered" synthetic pesticide poisons currently being "used" in the Fontana Unified School System, inside and outside, to "control" pests.  If you do not know the entire pesticide poison formula, it is extremely obvious to me that there is no "proper research" currently available for all or most of the "registered" poisons being used in California to "control" pests, and it is, therefore, clearly impossible to evaluate their potential health hazards and/or risks.  If you can not provide me with copies of all the "properly researched" poison formulations currently being used "legally" in California, I would like to ask you another question: "Why are you concerned about "proper research" for my safe alternatives?"  From any legal or potential liability standpoint, Larry's use of these legally "registered" pesticide poisons in his school
environments has already killed 4 children and has made others sick per the local newspaper and created at least one lawsuit - and Larry, obviously, still has his pests!  Does any of that concern you?

In the over 350 schools using "my" safe alternatives, systems and techniques we have never harmed (much less killed) anyone
and we have safely and effectively removed all of their pests and we have never been sued and  we have never used any "registered" (volatile) synthetic pesticide poisons.  If that makes me "illegal" in California, G-d help California!  As you well know, I have many hundreds of formulas and instructions for mixing and applying non-hazardous materials {that are not sold as insecticide poisons} to control pests; probably "my" most common "formula" is a simple blend of 1 quart of water, 1 tablespoon of any dish soap and 1 teaspoon of any vegetable oil.  This mix will safely kill almost 95% of any and all pests you spray this unregistered mix on, but no one can honestly say this unregistered mix has not been properly researched in virtually every kitchen sink in America.  No sane person would honestly consider the use of dish water would create any legal or potential liability problems for the Fontana Unified School District - like the "registered" poisons already have and will continue to do - without your help!.  The question can simply be asked in reverse: "Would you really wash your dishes in any 'registered' pesticide poison currently being "used" in California or in the Fontana Schools?"

The old IPM manual I sent you to evaluate over a year ago contains only my initial IPM thoughts; the new revision will upgrade all of the  material and content at least 500% and I am currently in process of writing and/or co-authoring several other alternative pest control books that safely and effectively control pests rather than use or sell any dangerous and useless "registered" pesticide poisons.  Based on your original comments to me over a year ago, I still believe that I can legally recommend the use of soap and water as long as I do not sell the soap and/or water   Has this really changed in California?

Do the people of California really have to keep their cans dirty but routinely sprayed with "registered" pesticide poisons to be legal?  Soap and/or water is also "not sold as an insecticide poison", yet virtually every time anyone uses these "unregistered" [safe] products they kill and/or control many harmful microorganisms, odors and/or pests.  That is why most of us wash our food, dishes, floors, garbage cans, tables, counters, pets and ourselves with these "unregistered" (but safe) products that also "are not sold as an insecticide poisons."

By the way, virtually any dust will effectively kill insects by clogging their spiracles; a slight breeze from a fan keeps mosquitoes off you; a line of chalk will stop most ants; a line of Vaseline® will stop most pests; virtually every insect can be simply vacuumed up; caulk and screens will keep most pests from entering, etc.  "My" list of safe alternatives is endless...are all of these safe alternative controls really "illegal" in California?

One last time (for the record), is it really "illegal" in California to use non-toxic or GRAS materials, products, procedures, strategies and/or techniques that clearly "are not sold as insecticides" to safely control or eliminate pests or must you only use dangerous "registered" poisons that do not control pests but do kill and/or injure children, pets and the environment?  Is it really "illegal" to wash your can with soap and water to control flies and maggots in California?   Do you have the "proper research" on the entire poison formulation (including all of the "inerts") for all of the synthetic pesticide poisons currently "registered" in California?  Do you really require that California "IPM" plans can only use "legally" use "registered" poisons to "control" pests?  Do you honestly believe "registered" synthetic pesticide poisons are "safer" and/or that volatile poisons will "protect" school environments better than soap and water?   Are you going to take action against the City and Board of Education of San Francisco for banning the use of "registered" pesticide poisons?  Will you be responsible for all the subsequent deaths, sickness, contamination and increased pest activity your demand that only "registered" poisons can legally be used to "control" pests will cause?  Do the people of California really have to "use" volatile poisons rather than common sense?  There are a lot of people very concerned about the legal aspects your e-mail
seems to be saying, so I would appreciate your answers to all of "my" questions in writing.

      Respectfully,
 

      Stephen L. Tvedten -  steve@getipm.com
      2530 Hayes Street
      Marne, MI 49435-9751

copy:     L. Pascarella      NCAMP
             J. Mitchel          W. Snodgras
             L. Wilkie           CHEC
             M. Moses         NCAP
             D. Rapp            Others
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COMMON SENSE IS NOT TOO COMMON.   VOLTAIRE