What is a "legal" pesticide alternative?
Subject: What is a "legal" pesticide alternative?
Date: Wed, 28 Nov 2001 17:46:53 -0500
From: Stephen Tvedten <steve@getipm.com>
Organization: Get Set Inc. (www.getipm.com)To: Paul Helliker <phelliker@cdpr.ca.gov>
Director, State of California, Department of Pesticide Regulationcc: Christine Whitman whitman.christine@epa.gov
Dear Mr. Helliker,
I just read your response to Mr. Murowski's query (see below). I believe you have once again totally ignored the "what is a "legal" pesticide alternative question", by simply limiting the scope of Mr. Murowski's query to "alternative pest control techniques such as pest control devices" and/or by calling all other alternatives, that mitigate pests in any way, to be "unregistered pesticides". I would ask you if there are any unregistered pesticide alternatives that you would "legally" allow to be used in California, that are not specifically exempted in 3CCR section 6147, entitled - Exempted Pesticide Products?
Of great interest to me, would be your determination that the use of any/all of the various unregistered pest control materials that are being currently being used in the various IPM strategies, e.g., Attraction, Repelling, Prevention, Quarantine and/or Inspection, Exclusion, Physical or Mechanical Controls, Trapping, Habitat Reduction, Sanitation, Storage, Ventilation, Moisture/Humidity Reduction and/or Changing the Conditions Conducive to Infestation, etc., are they all considered by you to be "unregistered pesticides"? Many of these materials are not on your/EPA's exempted pesticide list, nor are they EPA registered pesticides, nor are they registered EPA pest control devices, yet they work very well in mitigating many pest problems. Some of these unregistered alternatives include caulk, paint, soap, varnish, wax, siding and shingles, syrup, various colors, screens, doors, windows, door sweeps, brooms, lights e.g., security, flashing, green, sodium vapor, red, black lights, etc. and/or their removal or repositioning, temperature changes, fans, air curtains, cement, freezers, sealed containers, dehumidifiers, Rinse and Vacs or dry vacuums, chalk, detergents, hair dryers, fire, plants, animals, fragrances, glass, rags, microwaves, nets, radios, pastes, beer, dusts, plain water sprays, chalk, petroleum jelly, routine cleaning and/or dusting, duct tape, washers and dryers, steam, loud noises, hoeing/plowing, hand removal, power washers, smelly shoes, sounds, steel wool, sticky tape, string, sun, surfactants, tools, urine, vinegar, wind, used kitty litter, peppers, electrical shock, reflecting tapes and/or mirrors, wood ashes, etc. (If any of these unregistered alternatives are "legal" to use in your opinion, I would like to know how and/or why you determined that they were "legal" unregistered alternatives and many others are not? How can you "legally" allow the use of all the various unregistered "inerts" and/or stickers, or surfactants, etc. when they are being used with some active POISON ingredient, but then turn around and call them "unregistered pesticides" if they are used all by themselves?)
Mr. Helliker you also note to Mr. Murowski that the DPR: "is responsible for enforcing the most stringent pesticide laws and regulations in the nation and is committed to ensuring that pesticides are used in a safe and responsible manner to protect human health and the environment." You must be aware of the federal law that states that it is illegal to say even the labeled use of any of your "registered" pesticides is "safe". (If you are not so aware, I would be happy to send this to you.)
Your response to Mr. Murowski clearly states that California schools and professionals can only 'legally' use your "registered" pesticides to 'control' pests, if this is true, how on earth can the DPR state: "DPR actively promotes Integrated Pest Management as a pest control strategy that can reduce the use of and dependency on pesticides." If every non-exempt alternative is an "unregistered pesticide" and if "School employees, growers and pest control professionals do not meet the criteria of section 6301 (a) and, therefore, are required to use only pesticide products (POISONS) registered by the director, unless the product (which still is called {an exempted} pesticide) is exempted by 3CCR section 6147." - what remaining "strategy" do you have to reduce the use of pesticide POISONS?
The original intent of FIFRA was to "register" those economic POISONS that were then being used to "control" pest problems. Only the active POISON ingredient was to be (and still is) considered - so up to 99% or more of your "registered" POISON formulation was and is still totally ignored and is unregistered! Many of these unregistered ingredients in this 99% batch (called "inerts"), are far more deadly to people and animals than your active ingredients. (No wonder that it is against the federal law to say that even the labeled use of any "registered" POISON is "safe".)
There are about 10 million insect species, we have named only about one million, there are only about 1,000 species that are considered to be pests - of this group over half have already become resistant to your "registered" pesticide POISONS. When Rachel Carson published Silent Spring in 1962, she was "only" concerned with about 700,000 pounds of pesticide POISON used annually in the USA. We now use 4.5 BILLION pounds of your "registered" POISONS every year in just the USA, trying vainly to "control" pest problems! I would like to point out that in spite of all this needless "registered" contamination, we now lose more of our crops to insect damage than we did before we had any of your "registered crop protection products"!
Using my non-toxic, food-grade and/or GRAS (unregistered) alternatives, I have successfully and safely removed all pest problems inside and outside in over 350 schools. Yet you apparently STILL will not allow their unregistered use. In 1993, EPA, USDA and FDA all agreed to find (unregistered) alternatives to dangerous "registered" economic POISONS. Senator Leahy has recently asked EPA why there has been a 40% increase in annual pesticide POISON usage since that 1993 agreement. One has only to look at your response to Mr. Murowski, to understand why.
You have also previously said if any alternative product mitigates pests in any way, it automatically becomes an "unregistered" pesticide. Common sense should tell you that if something is not a POISON (like food-grade and/or GRAS materials) it can not and should not be considered to be a pesticide POISON.
I have developed, field tested, researched and/or formulated over 2300 safe and far more effective (food-grade and/or GRAS) alternatives that actually control even resistant pest problems. Until you will "legally" allow their use - obviously no school or professional can use any of these safe and far more effective alternatives, and only your dangerous "registered" POISON cocktails can and will continue to be used/misused, in ever increasing amounts to "control" pest problems. Who do you think should be held responsible for all this unnecessary (but, "registered") pollution, and its resulting contamination, sickness and death?
The world is losing between 50,000 and 100,000 plant, insect and animal species a year! In spite of all this terrible environmental loss and with over a half century of ever-increasing use and misuse of all of your (banned, restricted, voluntarily withdrawn and/or STILL) "registered" pesticide POISONS - we have never "controlled" much less eliminated even one pest species! Your continual nerve gas warfare - which you specifically "registered" to "control" pest species is contaminating, destroying and/or harming everything but the pests! Organophosphates were originally designed to KILL and/or sicken people not pests. These nerve gases were specifically designed as peoplecides not pesticides! Yet you would apparently continue to ban even the use of soapy water because it is (in your opinion) an "unregistered pesticide".
I specifically would like you to clear up some of my "misconceptions" regarding the laws and regulations for pest control in California. So, would you please define the word "alternative" and state when/if you will ever allow the use of any safe and far more effective but, unregistered alternatives to control and/or mitigate any pest problems in California? http://www.safe2use.com/ca-ipm/00-08-03b.htm
Respectfully, Stephen L. Tvedten
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