California Pest Control Operator

I am currently reading through your "safe" pesticide e-mails, and will look through them thoroughly. I do have a couple comments though.

I am very curious as to your (and others) debate about registered vs non-registered pesticides. Many of the products listed by Mr. Tvedten (sodium octoborate and others) as well as insecticidal soaps and other (arguably) low toxicity pesticide products are in fact toxic and are pesticides. I have read dozens of articles and books advocating "non-toxic" pest control, which in fact recommend the unsafe use of a pesticide!

The definitions of IPM I have read on your website thus far are also false. IPM is Integrated Pest Management. To control a pest one needs to know the pests biology, harborage, food source, water source, original source of the pest etc. Using an IPM strategy, one they addresses each of these (and other) areas as part of an overall strategy. One part of the strategy may include the use of some sort of pesticide be it insecticidal soaps or insect growth regulators. IPM is NOT the non-use of pesticides. Especially if you use pesticides and claim you do not (which is what it appears that you advocate.)

I strongly believe in IPM and have been a member of BIRC on and off for almost 15 years. One of the problems with implementing IPM on a professional evel is that IPM involves the consumer. Especially when dealing with a commercial or industrial situation, much of IPM involves monitoring, sanitation, and 'baby-sitting' the property owners in proper building maintenance, sanitation etc. I love implementing true IPM programs and in my professional career have taken on "sensitive" accounts which no other pest control company would touch.

The problem is that cities, schools, businesses, and homeowners think they want IPM, but are unwilling to implement or get involved in IPM. When a proposal is given to them, 99% of the time (in my 17 year experience) they turn it down and ask for a "silver bullet" solution. This results in the application of more pesticides, and less effective control. Unfortunately this is the choice of the consumer! I have spent hundreds of hours putting together IPM programs which were scraped by the consumer because it was 1) too consumer involved 2) too complex 3) not quick enough 4) "too expensive". I put together a detailed program for a school district once, (at significant cost) only to have the school district go with the "low bid".

It takes a lot of time and money to develop an IPM strategy and proposal for a consumer. I have seen DOZENS of situations where myself and others have spent lots of time putting together real IPM bids and proposals at a GREAT cost to ourselves, only to find the consumer choosing to hire another PCO who has made a "silver bullet" proposal which pretty much ignores IPM and cost pennies to the dollar compared to the bids prepared by myself and others who tried to earnestly provide what the consumer asked for.

By copy of this reply, I am forwarding your email to Steve Tvedten. Please also visit his site at: http://www.getipm.com I believe that review the materials on the Intelligent Pest Management program would be helpful. Also, feel free to email Steve directly.

My political and professional "positions" on pest management, IPM, and pesticides have made me friends and enemies in both "anti pesticide" camps and amongst my fellow "professionals". I am extremely experienced with DPR and their stand on registered pesticides. The best "product" for use on a sitting honey bee swarm (africanized honey bee control) is soap and water. I was on the subcommittee (of the Statewide Africanized Honey Bee Task Force) which looked at this issue and tried to get DPR to give an exemption. DPR made it clear that professionals could not use soap and water. DPR is perfectly happy if a homeowner uses soap and water as a pesticide on their own home, but if a professionals (in-house, for hire, or governmental) want to use soap and water or any other product it must be registered. Our solution was to get a 24c special use permit for IMPEDE which is a registered soap and water pesticide. The biggest hurdle with the 24c was getting the manufacturer to agree to the 24c registration as they obviously advertise their product as being "benign" and "safe" for honey bees and did not want their product name associated with killing bees. We worked out their concerns and we may now use IMPEDE with the 24c registration. If someone wants to use soap and water, borates, oils, or DE, there are plenty of registered products available. Most of these "non pesticide" or "natural pesticides" or "non toxic" pesticides as you know them may be used, but the consumer is still protected because all of California's pesticide safety and consumer notification laws still apply.

One of the problems as I see it, are the extreemist on both sides of the issue. For example, San Francisco almost banned the sale, and use or possession (I kid you not) of glue boards because they are "inhumane".

The judicious use of pesticides (yes even synthetic) pesticides in conjunction with a proper pest managment program helps to protect peoples health and property. I have yet to see any valid claims to the contrary.

I took a look at Steve's website, but have not had a chance to go through the site in much detail. One of the international leaders in "Least Toxic Pest Control" and IPM is Bio-ntergral Resource Center (BIRC) - PO 7414 Berkeley CA 94707. 510 524-2567 f 510/524-1758 They publish both a montly and quarterly journals on IPM and alternative pest control strategies, and published a great book "Common Sense Pest Control" ISBN 0-942391-63-2 While I can't say I agree with everything they say in their 700+ page book, it is without a doubt the best IPM manual published to date (I will check out Steve's CD-ROM) and overall it is one of the best pest management reference guides in print today.

We have controlled all pest (including head lice) in over 350 schools without using any volatile pesticide poison; about 5 times (and only as a last resort) we have used a spot application of boric acid or sodium octaborate both are non-volatile pesticides. The rest of the time we used Pestisafes such as cleaners, biologicals, traps, vacuums, lights, talcum powder, fans, sanitation, exclusion etc. to control/eliminate all of the pests. We have developed and/or field tested approximately 1500 Intelligent Pest Management tools. Since switching from "registered" poisons (I do not believe they are truly "registered" for many reasons) we have used these tools to virtually eliminate all of the pests at all of our accounts so much so that only one man handles all 350 schools in 2 states.
Steve

2/19/99
My first CD-ROM is about 1000 pages long and at a minimum is comparable to "Common Sense Pest Control" and allowed us to remove pest inside over 350 schools without the "judicious" use of any synthetic poison.

The 2nd version will be over 1600 pages and takes one from "IPM kindergarten to IPM graduate school". We have also field tested a "silver bullet" - if you don't believe it try the enzymes on every insect, mold, fungus problem you have - you too will describe them as the perfect pesticide but I prefer to call them "pestisafes".

Absolutely pest control can be done without the use of pesticides. As I frequently tell people, I would have no problem if all structural pesticides were banned today. My only point, is that what you describe is not "IPM" per se, as you use no pesticides. I agree completely that a proper IPM program does not rely upon pesticides as they are relied upon by most traditional "good old boy" pcos, but without any question, pesticides of some form are definitely tools which fit into an IPM program. No if someone wishes not to use pesticides, - terrific, they have just removed one of MANY tools and strategies utilized in an IPM program. Nothing wrong with continuing to call that strategy IPM, (though I might want to use other language to distinguish it from regular IPM).

We probably also disagree about the alleged harmful affects of pesticides in general, but that difference in opinion is moot and not germane.

I will be contacting Jen-Par Enterprises to order your CD-ROM book. It looks great!

I am also *very* interested in your "Kleen Kill Enzyme Cleaner". In your other e-mail you indicated that it was a "silver bullet" that I should "try the enzymes on every insect, mold, fungus problem you have". With that kind of testimonial, I have to try this! - But I do have some questions. What is it's mode of action? Is this product ($30 quart/$90 gallon) a concentrate, or a finished material? Is there a label or instructions I could see first? And lastly is this registered as a pesticide? If not (I will still try it anyway) what is the argument you are using to be able to use this product? I am well aware of the debate over regulating GRAS or 'non-toxic' products. ( <good natured ribbing follows> As you must know FIFRA defines pesticides as generally any product which 'kills, mitigates, or otherwise control pests' and all pesticides (and all compounds for that matter) are toxic at some level... and it is illegal to claim (as you did) that a pesticide is non toxic". <end of good natured ribbing>.) I was part of a group who petitioned Cal-EPA to allow governmental agencies and professionals to use soap and water to control some specific pests. The end result: Cal-EPA stated in writing that they would cite professional PCOs, or governmental agencies if we used soap and water, and said we could/should not recommend the public use soap and water. They gave several reasons, the two big ones being that some soaps can irritate the eyes, (the term liquid dish soap was apparently not specific enough for them) and the other was that there was a registered product (IMPEDE) which we could use. (IMPEDE is the professional product which is sold over the counter as "Safer Soap" - which is dish soap and water. I had a fellow PCOs tell me he occasionally buys IMPEDE so he can get "fresh containers" to put his own soap and water into. Not something I can advocate, but I had to smile when I was told this.

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