It would seem to be obvious that no
one wants pests in their home, but the polls and surveys clearly show that 80-90% of the
public will not call a member of the traditional pest control industry to do its pest
control work because they are already worried the pest control industry's poisons are too
strong or too dangerous! Clearly the bulk of the public is more concerned about pesticide
safety than they are about controlling their "pests" with poisons! All of our
customers hired us specifically because we do not use any volatile pesticide poisons!
How does our "government" continue to respond to the public's
main concern? Several states including Florida and Ohio are now demanding that PCO's
can only apply the maximum labeled rate of fumigant/termiticide to legally
"control" termites. The state "regulators" are saying that they are
trying to "protect the public" by demanding that only the maximum label rate of
poison be used in every situation! Ohio has clearly said its "law" does not even
recognize section 2(ee) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
which allows PCO's to use less than the maximum label rate.
The entire environmental community, the entire pest control industry,
all of the insurance industry, all parent teacher associations, all health associations
and advocates, all mortgage companies, all contractors, all developers and all of our
lawyers must now demand that if any federal law or any state mandate demands that PCO's
can only legally apply the maximum labeled rate of any poison in every and all situations,
that the federal government and/or state government must, therefore, become the only
responsible party; the government "regulators" must, therefore, become the PCO's
insurance company, and "regulators" must also pay for all subsequent
contamination and litigation costs; that the government "regulators" must also
pay for all subsequent repairs or damages that the PCO's incur, by following /obeying the
government's rules, rather than following their own professional knowledge, guidelines,
expertise and experience.
In addition to merely "winking and saying" the
"government and/or regulators" are for IPM, safer controls, technologies and
alternatives to pesticides — the government, and especially all of the state
"regulators", must also clearly recognize and clearly state that those PCO's who
really provide/practice true IPM for our clients, who will not let us apply any (much less
the maximum labeled rate of) poison in their homes, hospitals, schools, offices and places
of worship, that we (pest control operators) have a legal right to provide these
alternative (IPM) pest control services that truly do protect our clients, our applicators
and the environment. .
We remember "way back when" — when the "state"
first decided it wanted to "protect the public and demanded that all PCO's use the
maximum labeled rate of chlordane. We alone refused to obey that "state mandate"
back then. Today, we all know the "state mandate" was wrong and that the
carcinogenic chemical chlordane was found to permanently contaminate and poison the air,
people, pets and the environment, no matter at what amount or rate or pressure or method
by which it was applied to "control" termites inside. We still do not care what
volatile, termiticide poison rate the "state" will now try to mandate, because
it never has nor will it ever guarantee to protect us or our clients from all of the
resulting volatile, synthetic pesticide poison contamination its "mandates"
continue to cause — so we will continue to only use baits, table salt, biological
controls like fungi, nematodes and/or mites, dehumidifiers, fans, hairdryers, sand,
mechanical alteration and/or other nonvolatile alternatives, e.g., sodium borate
treatments, to safely and effectively control termites. If any "state regulator"
wants to prosecute "someone" for not using "enough" volatile,
synthetic termiticide poisons or fumigants — they can start by arresting me.
I was the only PCO ever indicted for not using "enough chlordane
way back when", and I am still here,
still disobeying that asinine "mandate".
All of the recent polls and surveys clearly show (at least) most of the
public and the environmental community want safer (IPM) alternatives used to totally
eliminate or at least reduce all pesticide use/misuse and all of the resulting health
problems, environmental damage and contamination problems these poisons cause. Let's see
how well the state "regulators" did the last time they demanded that PCO's apply
the maximum labeled rate of a termite poison. Today at least 75% of U. S. Homes are now
(permanently) contaminated with chlordane at significant levels. New research shows
that people living in homes built before April of 1988 are still most likely breathing the
pesticide chlordane each minute they are in their homes and their homes will remain
contaminated for decades! Chlordane is such a highly toxic and persistent chemical
that homes treated 20-30 years ago are still showing unsafe levels of chlordane in the
indoor air. The problem occurs because the hundreds of gallons of chlordane the
"state" wanted pumped underneath the home are slowly evaporating, rising through
cracks in the foundation or around plumbing pipes and entering the home. Obviously, very
few "regulators" understood back "then" that if 98% of the termite
infestations occur in the porch or stoop, it really is not logical to mandate that PCO's
must "legally" put 98% of the poison "elsewhere" -- to permanently
contaminate "everything".
For the record, for the approximately 25 years that I did apply soil
termiticide poison pretreatments, the Federal Housing Authority (FHA) allowed us to simply
(spot) pretreat the porches and stoops only and so we only spot treated only these areas.
We issued a 5-year FHA porch and stoop pretreatment warranty. To my knowledge, of the
thousands and thousands of (spot) porch and stoop pretreatments -- we never were called
back -- regarding a subsequent termite infestation. Someone ought to tell the
"regulators" that the most poison ever applied by a PCO is during a termite
"control" -- therefore, it is logical to expect any termite "control"
that must always use the maximum labeled amount of any volatile, synthetic termiticide
poison, will, obviously, also create the most severe contamination problems!
Several illnesses are now linked to chronic chlordane contamination
(home) exposures. There are now several university studies showing what once was the
so-called acceptable levels of chlordane in indoor air can (now) cause respiratory and
neurological problems. Examples of several studies are:
"Families in apartment complex treated with chlordane show
increases in sinusitis, bronchitis, migraines, cough & anemia."
JOURNAL: Bulletin of Environmental Contamination Toxicology, 39:903
(1987)
In a study reported by Dr. J. Milton Clark, Ph.D., at the School of
Pubic Health, University of Illinois, half of the homes judged to have had a proper
termiticide application had detectable air levels of chlordane, an average of 2.7
micrograms per cubic meter, months to years following the last application… The
United States Environmental Protection Agency has often considered lifetime
cancer risks exceeding one in a million as unacceptable. An air level of less than
0.1 micrograms (of chlordane) per cubic meter, which appears unachievable, may
need to be required (of chlordane) to have cancer risks within an acceptable range.
On August 11, 1987, on the basis of new evaluations regarding the safety of the
cyclodiene termiticides, EPA announced the cancellation of virtually all termiticide
uses of chlordane, heptachlor, aldrin and dieldrin." Remember, these
"treatments" were all judged "at the time" to be proper
termiticide applications!
"Immune System Damage & Autoimmune Problems."
JOURNAL: Archives of Environmental Health, 43(5):349-352 (1988)
"Immune System Macrophages Paralyzed By Chlordane."
JOURNAL: Agents & Actions Journal, 37:140-146 (1992)
"Fatigue, Depression, Anger, Memory, Concentration Problems All
Caused by Chlordane Exposure."
JOURNAL: Bulletin of Environmental Contamination Toxicology, 39:903
(1987) Dr. Kaye Kilburn stated, "Chlordane is a chlorinated cyclodiene insecticide
introduced in 1948 and is considered to act as a toxicant with many of the signs and
symptoms of poisoning like those produced by DDT… It is tragic that exposure is still
occurring to a material that the National Research Council in 1982 characterized as a
hazard at any dose: it could not (even then)
determine a level of exposure to any of the cyclodiene termiticides below which there
would be no biological effect."
"Asthma, Allergies, Bronchitis and Cough Linked to Chlordane
Homes."
JOURNAL: Bulletin of Environmental Contamination Toxicology, 39:903
(1987)
"Neuroblastoma & Leukemia After Chlordane Exposure."
JOURNAL: Teratogenesis, Carcinogenesis, and Mutagenesis, 7:527-540
(1987)
"Liver Damage Results from Chlordane Exposure."
SOURCE: Science News, November 24, 1984.
Because of the widespread contamination of chlordane in American homes
(the chemical emits vapors for decades after treatment) and its link with
causing abnormalities in blood and childhood blood and brain cancer, Dr. David
Ozonoff, of the Boston School of Public Health, stated there is an "urgent
need for legislation creating a national program for monitoring homes known to
have been treated to detect persistent contamination with these highly dangerous
pesticides."
"How Chlordane Causes Infertility in Female Test Animal."
JOURNAL: Toxicology and Applied Pharmacology, 19:234-246 (1971).
"Overweight - a Symptom of Chlordane Exposure."
JOURNAL: Toxicology & Applied Pharmacology, 126:326-337 (1994)
"Teachers and Students Develop Illness - High school found to
contain
high levels of chlordane."
SOURCE: E-Magazine
I have personally found some homes with such high levels of termite
poison contamination that the wells were poisoned and the people had to be permanently
vacated; yet termites were still there eating away. In spite of the fact that no
amount of termite poison will ever control all of the termites, in spite of all the health
studies, in spite of all the bad press and controversy regarding pesticides, in spite of
all the contamination, in spite of all the termite resistance to synthetic termiticides,
in spite of the fact there is no residual action with fumigants, in spite of what the
public wants, in spite of what the environmentalists want, in spite of all the regulation
and effort to stop pesticide contamination -- the "state" still wants to
"protect" (to pollute) the public again, by making PCO's apply the maximium
labeled rate of even more termite poisons!
Today, doctors and scientists state that millions of adults and children
are becoming sick by living in homes built before April, 1988. This is because the
toxic pesticide chlordane contaminates the ambient air in over 30 million U. S. homes!
Symptoms include childhood cancers, neuroblastoma, leukemia, infections, bronchitis,
asthma, sinusitis, infertility, neurological disorders, aggression and depression.
Unfortunately, most occupants are totally unaware this is the cause of their illness!
Was permanently contaminating 75% of all American homes with the
cancer-causing chemical, chlordane to "protect" them from termite
infestation(s) really worth all of the risk???? Let's look at the real potential for
(termite) damage. The Eighth Edition of the Mallis Handbook of Pest Control, on page 257
noted, "Field experiments conducted by Forshchler and Townsend (1996) in Georgia
offer yet another perspective on the amount of wood likely to be nsumed.....The study
monitored more than 60 Reticulitermes colonies, averaging less than 100,000 termites
during a 3-year period.......Colonies ate the equivalent of one 5-inch section of pine 2 x
4 per year." It seems obvious that in the majority of termite infestations (at least
early on) our state "regulators" have actually destroyed 75% of our homes to
"protect" a 2 x 4! The other problem with the "regulators" new
"mandate" is it fails to even consider that today's volatile, synthetic
termiticide poisons will not even be effective in a relatively few years, even if and/or
when they are applied at the maximum labeled rate. If the state "regulators" are
really concerned that non-control of termites is the most significant problem they are
encountering, they should ask themselves why our alternatives to traditional, volatile,
synthetic termiticide soil poisons work better and last longer and are much safer! Then
perhaps they will mandate the use of "our" alternatives, and not simply
"mandate" that PCO's simply apply/use more and more of the same old volatile,
synthetic termiticide poisons that did not work even when they permanently contaminated
75% of our American homes!
When will the "state" finally recognize that we who are true
professionals in the pest control business are not simply maximum poison applicators and
that poisons do not "protect" - they kill!!
As a truly professional pest control operator for over 30 years, I have
consistently proven my point: we get better, safer pest/termite control/elimination
without using any volatile, synthetic pesticide poisons or fumigants, using our safer IPM
alternatives, than we ever did or could using the maximum labeled rate of any termite
poison! In addition to the better termite control, we also do not cause any pollution,
contamination, sickness, death or damages!
Who is the "state" truly "protecting?" The public?
The ground water? The wildlife? The applicators? The environment?...or is the
"state" really trying to protect the profits of the poison manufacturers?
After DDT, after asbestos, after PCB's, after chlordane, and all the
other unintended chemical catastrophes, our Congress finally wrote into law that our
government's knowledge about those chemicals they allow into commerce must improve; that
the risk of the toxic chemicals in our environment would be identified and controlled.
In the early 1980's, the National Academy of Sciences' National Research
Council completed a four- year study and found that 78% of the chemicals in the
highest volume of commercial use had not even "minimal" toxicity testing; over
13 years later, there has been no significant improvement.
What the government does not know about current chemicals may not be
hurting any of us - or it may be hurting all of us. Some of us, however, are allergic even
to milk, to grains, to yeast, to fragrances, to dust and mold. Obviously, "some"
of us will react to any given chemical, in any amount, in a negative way. Look at the
Physician's Desk Reference - many of us react negatively even to medicine! Has the
Government really decided there is no need to protect the more sensitive/vulnerable people
in our country?
What the government also does not know about termite control can also
hurt people and the environment. Perhaps some of the state "regulators"
would be kind enough to explain to me why the labeled rate/volume of any volatile,
synthetic termiticide poison that can legally be applied to treat an active termite
infestation in a home (post-construction) may only be half or even less than half of the
(maximum) amount of the termite poison now being "mandated," that must always be
applied, in every situation, to "prevent" nonexistent termites in a home
(pre-construction) which may never experience a termite infestation, even without any
treatment of any kind? How on earth can the curative dose to "control" be so
much less than what is "needed" to "prevent" termites?
Chemical safety can't be based on "faith", nor can the
Government ever "control" even termites, much less chemical risk, by
having some "mandate" that "legally" demands that every PCO must apply
the maximum labeled rate of poison in every situation!
If the "state" wants to arrest someone for consistently
getting better, safer termite/pest control without using any (much less than the
maximum labeled rate of) volatile, synthetic pesticide/(soil) termiticide poisons or
fumigants — the "state" can start with me. It should be obvious I
have already "confessed." I won't be using any volatile, synthetic termiticide
poisons to "control" termites. We will continue to use the labeled rate of
sodium borate to pretreat and/or to treat only the susceptible wood, and/or will continue
to control termites using only our other safer alternatives that work better. It also
should be obvious that "someone" else should be arrested and/or
"someone" else should pay for all the chlordane contamination their old
"mandate" has already caused, and "someone" else should now be
prepared to pay for all the new contamination, sickness and death their new
"mandates" will also cause!
Respectfully,
Stephen L. Tvedten
