Pest Perspectives - November/December 2015 - (Page 23)

capitol concerns Another View: The Pest Control Industry Isn't Bad A personal commentary by Sean Brantley, FPMA Government Relations Committee Co-Chairman O n October 7, the Office of Inspector General for the US EPA issued a Memorandum to announce its plans of conducting preliminary research on structural fumigation factors. The two primary objectives of OIG's research are to determine a) the extent and nature of adverse impacts caused by structural fumigants, and b) to determine if regulatory, program execution (e.g., training, funding, inspection, enforcement, etc.) or other factors associated with adverse impacts. The OIG's is an independent arm that performs audits, evaluations and investigations within EPA to enforce its own policies and promote efficiency as well as detect fraud and waste. The federal standards are exceeded by Florida and for all practical purposes provide exceptional regulatory oversight by our DACS. It is important to note that some of the current structural fumigation safety requirements were created right here in Florida. Our state still holds a high regard for enforcement of Chapter 482 and its attendant Rule 5e-14, as well as the label and product manual while still maintaining extremely high compliance ratios (even during risk based enforcement schemes). Compared to other states where fumigation related incidents have occurred, Florida leads the way in regulatory oversight and compliance. There are roughly 60,000 fumigations reported each year. That reporting is a state requirement and is not part of federal standard. During these 60,000 fumigations, there are possible inspections for paperwork during reporting, recordkeeping, licensure and certification, the actual initiation of the fumigation at the put-up, the exposure period when under tarp or seal, the takedown and active aeration, the passive aeration and the final clearance. Along the way a certified applicator such as a Fumigation Certified Operator or a Special Identification Cardholder in Fumigation must be present and account for proper compliance with label, rule and law. Traceability to compliance is easy with the mandatory RUP recordkeeping, mandatory DACS notification of the impending fumigation and licensed applicator's presence at critical phases of the fumigation itself. In addition, in order to purchase and use any fumigants labeled for structural use, the users must attend a product Stewardship program. This is a mandatory training that highlights the proper use and safe handling of the fumigant. And I have not even begun to tell you about the litany of other state and federal agencies that have a hand in fumigation regulations including DOT, OSHA, FMCSA, FL DOT, HMPSA and DHS. The most regulated sector of pest control by leaps and bounds is fumigation. There is rule attached to everything you do and payment plans to make sure you remember. | The question is, "Is there room for improvement?" I believe that we have the framework. I believe that the industry has the right guidance. I believe that we probably are handling ourselves properly most of the time. If we are to seek changes, there should be a well balanced approach to determining need, practicality, consumer protection and cost, enforceability and "reality." Recently, there was a case in the U.S. Virgin Islands. The story goes a fumigator took a single unit out of a multi-unit building that was occupied by vacationing families and fumigated it with methyl bromide. Keep in mind that methyl bromide has not had a structural use label for very long time. Also keep in mind that only an idiot would allow people to stay in the same building as a fumigation, let alone upstairs. This fumigator acted contrary to all things we know and do right. To top it off, investigators were still finding dangerous levels of methyl bromide in the airspace of the apartment six weeks later and ran across records indicating that as many as 37 other people had been exposed by the same guy during this and previous fumigations. This case has 742089_Bell.indd 1 Pest Perspectives 23 4/24/15 8:29 PM

Table of Contents for the Digital Edition of Pest Perspectives - November/December 2015

Message from FPMA Headquarters staff
Indecent Exposure: Stories of Pesticide Exposure
presidential perspective
The Advantage of Minimum Risk Pesticides
Best Practices for Exterior Bait Stations
capitol concerns
marketing matters
operational excellence
FPMA corner
advertiser index

Pest Perspectives - November/December 2015