EPA Seeking Comments on Minimum Risk Pesticide Program

Yesterday, the Environmental Protection Agency (EPA) announced that it’s requesting public comments for possible policy changes related to minimum risk pesticide exemptions. If you regularly use pesticides classified as “minimum risk” and are therefore not regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), read on to learn more about the potential changes and how to submit a comment!

The EPA’s ANPR

In an effort to improve and streamline the Minimum Risk Pesticide Program (and other exemptions codified under regulation 40 CFR 152.25), the EPA has released an advance notice of proposed rulemaking (ANPR) with this mouthful of a title: “Pesticides; Modification to the Minimum Risk Pesticide Listing Program and Other Exemptions under FIFRA Section 25(b).”

This ANPR invites the public to provide input on specific questions related to many aspects of the minimum risk program, from the petition process to exemption selection. I’ve taken this daunting policy document and did my best to simplify it so you can “jump around” and look at whatever questions relate to you and your work. 

The public has until July 7, 2021 to submit comments. Once you’ve read through some questions, click here to share your suggestions!

The Petition Process

Here’s an overview of the current minimum risk petition process:

Under the Administrative Procedure Act (APA), the public can petition the EPA to consider whether a new substance should be added to the list of active or inert ingredients eligible for the minimum risk pesticide exemption. 

If the EPA decides to grant a petition, it publishes a proposed rule (also known as a Notice of Proposed Rulemaking or NPRM) that the public can comment on. 

The EPA then considers the comments received on the proposed rule, sometimes making revisions based on those comments, and issues a final rule.

Petition Process Questions

Now, with this ANPR, the EPA invites the public to comment on this petition process and how it relates to the Minimum Risk Pesticide Program by answering these questions:

  1. Do you have any suggestions for improving the processes for initiating a review of a substance or for implementing a decision that a substance may be used or may no longer be used in a minimum risk pesticide process? Please explain how changes could increase efficiencies.
  2. Given the identified minimum risk characteristics of these products and anticipated low impacts on communities, are current approaches effective for seeking input from the public and stakeholders, including State, Tribal, and territorial officials, scientists, labor unions, environmental advocates, and environmental justice organizations? Are there particular approaches that are more or less effective?

Evaluation of Minimum Risk Pesticide Ingredients

When determining whether or not to grant a minimum risk petition, the EPA applies the risk assessment factors described in the March 1996 Minimum Risk Exemption final rule, as well as additional factors currently relevant to pesticide risk assessment. 

The risk factors from March 1996 include:

  • Whether the pesticidal substance is widely available to the general public for other uses
  • If it is a common food or constituent of a common food
  • If it has a nontoxic mode of action
  • If it is recognized by the Food and Drug Administration (FDA) as safe
  • If there is no information showing significant adverse effects
  • If its use pattern will result in significant exposure
  • If it is likely to be persistent in the environment.

Along with the risk factors listed above, the EPA also routinely considers the following additional factors: 

  • Is likely to have carcinogenic or endocrine disruptor properties?
  • Is likely to cause human health developmental, reproductive, mutagenic, or neurotoxicity issues?
  • Is a known allergen or a known allergenic source or a potential allergen?
  • Is associated with developmental toxicity/adverse effects to mammals, birds, aquatic organisms, insects, plants?
  • Does it produce or could produce toxic degradates?
  • Does it have the potential to be contaminated with toxic or allergenic impurities?

Evaluation Questions

Environmental justice and pollution prevention directives will continue to be a part of the regulatory planning process for the Minimum Risk Pesticide Listing Program, but the EPA wants public comments on these questions:

  1. Considering the previous discussion, should the factors discussed above be considered in determining whether a substance should be exempted from FIFRA regulation via the minimum risk exemption?
  2. How would these other factors be weighed in a minimum risk determination?
  3. Are there other policies that the EPA should consider in determining whether a substance should be exempt from FIFRA regulation via the Minimum Risk Pesticide Listing Program? For example, should the EPA consider additional environmental justice and pollution prevention policies?
  4. When considering products that are a “minimum risk” to public health and the environment, should the product also be considered to be of low impact to all communities, including low-income and minority populations? Please explain why or why not.

Exempted Classes of Pesticides

In some cases, the EPA has exempted minimum risks products with pesticidal properties and uses separately from the list of minimum risk pesticide ingredients. One example includes unrefined natural products that lack a specific formulation but serve a specific application, such as pheromone traps.

In the context of this ANPR, the EPA is looking for comments on an unrefined natural product which currently lacks a specific formulation: peat. 

Peat is an accumulation of partially decomposed organic material found in peatlands or bogs. It can be used as fuel, in gardening, and in certain types of septic filtration systems. While the use of peat in septic systems may be intended for a pesticidal (antimicrobial) purpose, it has been suggested that registration of such uses may not be necessary to carry out the purposes of FIFRA.

Exemption Questions

The EPA would like comments on the following questions on the current classes of pesticide exemptions found in 40 CFR 152.25 or on other aspects of the Minimum Risk Pesticides Listing Program.

  1. The EPA broadly requests comment on the utility, clarity, functioning, and implementation of the provisions in 40 CFR 152.25.
  2. Are there other pesticidal substances or systems, like peat as mentioned above, that EPA should consider adding as a new class at 40 CFR 152.25 for exemption from registration under FIFRA? How do these other pesticidal substances or systems meet the existing factors?
  3. What other factors should EPA consider in determining whether a category or class of products should be exempted from FIFRA regulation? Please explain how these other factors should be weighed in a determination.
  4. When considering whether a category or class of products are a “minimum risk” to public health and the environment, should the category or class of products also be considered as being of low impact to all communities, including low-income and minority populations? Are there other factors that the Agency should consider?

Next Steps

After the public comment period ends on Jul 7, 2021, the EPA will review all the responses and determine whether or not to propose any additions or modifications to the Minimum Risk Pesticide Listing Program.

If the EPA decides to move forward with changes to the program, the next step would be to identify, develop, and evaluate specific options for amending the current regulations then issue a proposed rule for another round of public review and comment gathering.

Now that you’ve read the questions, remember to submit your comments before July 7, 2021!

EPA Addresses Risks Posed by Four Common Herbicides

Last week, to address ecological risks, the Environmental Protection Agency (EPA) released interim decisions (ID) for three Pyridines and Pyrimidines herbicides: clopyralid, dithiopyr, and triclopyr. Picloram, another similar herbicide, currently has a proposed interim decision (PID).

If you don’t feel like reading the entire report, read on to view a summarized (and simplified) description of what these decisions mean for applicators.

New Decisions Bring Updated Label Language & Restrictions

Pyridines and Pyrimidines are a class of herbicides used to control broadleaf weeds, woody brush, and aquatic plants in both agricultural and non-agricultural settings. Agricultural use sites include grains, fruits, vegetables and other crops. Non-agricultural use sites include turf, industrial areas, and roadsides.

The EPA is still working to address compost contamination concerns connected to these herbicides. In the meantime, they are requiring the following measures while the IDs and PIDs are under registration review: 

Clopyralid and Picloram:

  • Prohibit the transport of treated plant matter and manure from animals that recently grazed in treated areas for off site composting for a period of time until residues have adequately declined.
  • A clean-out period of at least 3 days for animals fed with treated plant materials.
  • Removal of use on residential turf language from all labels (clopyralid only).
  • For pasture and turf sites: applicators must notify landowners/operators of compost restrictions. Applicators must keep records of the notification for two years.
  • Updated compost pictogram on pesticide labels showing users when not to compost materials.
  • Registrants to participate in a stewardship program and provide educational outreach for those affected by herbicide residues in compost.

Triclopyr and Fluroxypyr:

  • Prohibit the use of treated plant materials or manure from animals that have grazed or consumed forage from treated areas for composting until 30 days after application. 
  • A clean-out period of at least 3 days for animals fed with treated plant materials.The IDs for the three herbicides mentioned above finalize enforceable mitigation measures to address spray drift risks as well as potential residues in compost. 

The compost mitigation measures also include updated label language that focuses on:

Clopyralid and Triclopyr

  • Reducing compost contamination by prohibiting off-site composting of treated plant matter and manure from grazing animals until residues have adequately declined

Clopyralid Only

  • Requiring pasture and turf applicators to notify the property owners/operators of the compost prohibition, and for the applicator to keep a record of this notification for two years
  • Requiring registrants to participate in a stewardship program and provide educational outreach for those affected by herbicide residues in compost
  • Removal of residential use on turf language from all labels

Picloram Public Comments

The PID for picloram, which proposes mitigation similar to the mitigation measures in the clopyralid ID, is currently open for public comment. Interim registration review decisions impose risk mitigation measures necessary to protect the environment pending additional assessments including an endangered species assessment. After reviewing and considering the public comments received on the proposed interim decision for picloram, the EPA will proceed with the registration review process and issue the picloram ID.

Potential Environmental & Human Health Risks 

The EPA only lists negative ecological effects as a result of Pyridines and Pyrimidines herbicides on their website. They say the ecological risks are primarily non-target terrestrial plants through spray drift and runoff. Certain herbicides in the pyridine/pyrimidine class can persist in treated plant materials, and when treated materials are recycled into compost, can cause harm to plants in gardens and ornamental plots where the compost is applied. Pathways into compost include residues in treated turf clippings, hay from treated pastures, and manure from animals that have grazed in treated areas.

Although the EPA says “there are no human health risks of concern for this class of herbicides,” the Oregon Health Authority (OHA) has different data.

According to OHA, continued exposure to drinking water that has a level of picloram above the legal limit of 500 parts per billion can cause diarrhea, weight loss, liver damage, and damage to the central nervous system.

If you have data or experience that agrees with OHA, be sure to submit your public comment on picloram here. And if you currently use any of the other three herbicides mentioned earlier, be sure to review and follow the new EPA guidelines.


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PFAS Appearing In Variety of Pesticides, EPA Responds

Over the past few months, the Public Employees for Environmental Responsibility (PEER) advocacy group has discovered that multiple publicly available herbicides and insecticides contain Polyfluoroalkyl Substances (PFAS), a group of manmade chemicals linked to various health issues.

What does all of this mean for applicators that have used these contaminated products and who might have been exposed to PFAS? Read on to get a breakdown of all of the discoveries, test findings, and possible consequences.

PFAS Background

PFAS are a group of man-made chemicals that can be found in food packaging, commercial household products, some drinking water, and more. Of the many variants, PFOA and PFOS are the most commonly produced and are known as “forever chemicals” - meaning they don’t break down or leave a person's body over time. 

The EPA recognizes that PFAS exposure can lead to “adverse health outcomes” such as low infant birth weights, effects on the immune system, cancer (PFOA), and thyroid hormone disruption (PFOS).

Contaminated Products

Per a new report from E&E News, PEER announced that their own testing revealed PFAS in the following pest control product:

  • Mavrik Perimeter - a mosquito and tick control agent Zoecon. 

Author’s Note: There are at least three other unnamed pesticides that showed PFAS levels during initial testing. PEER is still waiting for more result confirmations before putting their names out. These findings have not yet been evaluated or confirmed by the EPA. 

Anvil 10+10

The new findings listed above are part of PEER’s follow-up investigation after they discovered PFAS in a commonly used mosquito control insecticide, Anvil 10+10.

New testing from an environmental watchdog group shows PFAS are present in multiple pesticides. Claudine Hellmuth/E&E News (illustration); Freepik (mosquito); EPA (logo and text) ; Clarke Mosquito Control Products Inc. (Anvil bottle)

PEER’s initial test results revealed that it contained roughly 250 parts per trillion (ppt) of PFOA, and 260 – 500 ppt of HFPO-DA (hexafluoropropylene oxide dimer acid, a “GenX” replacement for PFOA). Massachusetts, parts of Florida, New York, and many other states have all used Anvil 10+10 in aerial spraying programs.  

When PEER alerted Massachusetts Department of Environmental Protection (MADEP) of its findings, MADEP independently tested nine samples of Anvil 10+10 from five different containers, and found eight different PFAS, including PFOA and PFOS.

“In Massachusetts, communities are struggling to remove PFAS from their drinking water supplies, while at the same time, we may be showering them with PFAS from the skies and roads,” stated PEER Science Policy Director Kyla Bennett, a scientist and attorney formerly with EPA, who arranged for the testing.

The EPA Steps In

In response to these findings, the EPA released the results of their own Anvil 10+10 investigation just last week. They discovered eight different PFAS compounds in the fluorinated (a chemical coating) high-density polyethylene (HDPE) containers, with levels ranging from 20-50 parts per billion.

Despite these findings, the EPA has this to say concerning possible exposure:

“The PFAS detections...from the tested containers do not represent PFAS concentrations in the environment or human exposure to PFAS. While the EPA is early in its investigation, the agency will use all available regulatory and non-regulatory tools to determine the scope of this emerging issue and its potential impact on human health and the environment.”

PEER says this response, and the EPA’s general testing method, is not enough. Bennett says the EPA should be more proactive in warning the public about the possibility and implications of PFAS contamination in pesticides.

"We now have five different manufacturers that are selling PFAS-contaminated pesticides," Bennett said, noting PEER's latest findings. "This is a problem of epic proportions."

She’s also concerned that the EPA’s testing methods are too focused on PFAS coming from HDPE containers. PEER’s new tests (results listed above) revealed different PFAS compounds than were found in the Anvil 10+10 containers, raising questions about whether the chemicals could be getting into pesticides through other means.

Possible Contamination Causes

One theory Bennett proposed for explaining the contamination would be pesticide manufacturers listing PFAS chemicals as an “inert” ingredient, because there’s no requirement to disclose inert ingredients to consumers.

But there are pesticide manufacturers that dispute the claim. Megan Provost, president of Responsible Industry for a Sound Environment (RISE), which represents nonagricultural pesticide producers, said, “PFAS chemistry is not an active or inert ingredient in any pesticide formulation” made by members in her coalition. She instead blamed container manufacturers, saying “fluorinated packaging is used for some 20% to 30% of pesticide formulations to increase product and packaging integrity.”

What Now? States, Manufacturers Respond 

Regardless of who’s to blame, pesticides have a growing PFAS problem. In response, Anvil 10+10 manufacturer Clarke Mosquito Control Products Inc. confirmed in January that they voluntarily ceased all sales and shipments of the pesticide.

Massachusetts, Maine, and New York have all introduced or proposed bills that either limit or completely ban the use of any pesticide that contains (or might contain) PFAS due to florinated HDPE containers.

The EPA said they are “actively working with the Food and Drug Administration, the U.S. Department of Agriculture, and industry and trade organizations to raise awareness of this emerging issue and discuss expectations of product stewardship.”

If you suspect you have used a pesticide that may contain PFAS, you can file a report with the EPA here.


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EPA Extends Chlorpyrifos Public Comment Period; Future Use In Doubt

This month, the EPA extended the public comment period on its draft risk assessments (DRAs) and proposed interim decisions (PID) for chlorpyrifos to March 7, 2021. The purpose of the comment period is to “give the public and stakeholders more time to review and comment” on the December 2020 PID

This extended comment period is part of the effort the EPA needs to take following President Biden’s “Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis” Executive Order

The order aims to “review” actions taken by the previous administration across many government agencies. Action number 42 under the EPA section includes the “Chlorpyrifos; Final Order Denying Objections to March 2017 Petition Denial Order,” ruling. In “non-government speak,” this means the Biden administration is reviewing the sudden switch made by the Trump administration in early 2017 to block the outright ban of chlorpyrifos use - which started in 2015.

In a statement, the EPA said they will “follow the science and law in accordance with the Biden-Harris administration's executive orders and the Federal Insecticide, Fungicide, and Rodenticide Act in reviewing the chlorpyrifos DRAs and PID to ensure they are protective of public health and the environment.”

Back on the Ban Path?

Many news publications (both in and out of the agricultural science industry), see this “review” process as a sign that the Biden administration is considering a return to the 2015 chlorpyrifos ban proposal.

Successful Farming reports the way chlorpyrifos could ultimately be banned is still uncertain, but “some former EPA directors predict it will most likely be revoked via a voluntary cancellation.” This process can take as little as 30 days and only requires general agreement within the industry.

Chemical & Engineering News (c&en) says a voluntary cancellation would be “easier than five years ago” because unlike in 2015, Corteva Agriscience (formerly Dow AgroSciences), the largest maker of chlorpyrifos, is unlikely to fight a ban because they already agreed to phase out production last year.

The other option is a formal procedure to ban the pesticide that could take two to three years. In the past 40 years, there have been no formal cancellations of any pesticide, says Bill Jordan, a former deputy director at the Office of Pesticide Programs at the EPA and now an industry consultant and a volunteer at the Environmental Protection Network. “EPA has always thought voluntary cancellation was a faster, cheaper, better process than a formal cancellation,” he says. 

Regardless of the method used (if any at all), it’s clear to many that the EPA under the Biden administration will be very different compared to the Trump years. Biden himself has said he wants to take a close look at all current policies “that are harmful to public health, damaging to the environment, unsupported by the best available science, or otherwise not in the national interest.” 

Kari Hamerschlag, an advisor on the DNC Council on the Climate Crisis, said “Our goal in the Biden years is to root out the corporate dominance and interference in policy and try and get it back to policy that is actually healthy for people and the planet.”

Possible Consequences of a Ban

According to c&en, outright banning chlorpyrifos could create problems in the pesticide supply chain because on January 12, a federal court ruling directed the EPA to remove the pesticide sulfoxaflor, one of the few alternatives to chlorpyrifos for some applications, from the US market while the agency evaluates the risks of that chemical to endangered species. Environmentalists sued the EPA for allowing sulfoxaflor back on the US market in 2019, after the agency banned it in 2015 because of adverse effects on bees. 

The Current Course

The EPA is currently reevaluating 22 organophosphate pesticides, including chlorpyrifos, as part of a standard process to reassess pesticides after 15 years on the market. The agency expects to complete that review by Oct. 1, 2022. Unless the courts step in, or a voluntary cancellation occurs, chlorpyrifos use could continue until the end of the review.

To learn more about why there’s such an interest in banning chlorpyrifos, click here. If you would like to contribute to the conversation surrounding chlorpyrifos by submitting a public comment to the EPA, click here.


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2021 WPS Training Update: New AEZ Requirements

Next week marks the beginning of the fourth annual National Pesticide Safety Education Month! That’s why our next few blogs will highlight the Environmental Protection Agency’s (EPA) Worker Protection Standard (WPS). 

Today, we’re looking at the revised 2020 WPS Application Exclusion Zone (AEZ) requirements that the EPA approved in October 2020. But first, if you’re not yet a certified applicator (but want to be) or you’re not sure if your employer or your business needs WPS training, here’s a basic summary:

WPS aims to reduce pesticide poisonings and injuries among agricultural workers and pesticide handlers by requiring employers to provide training that covers the following topics:

  • Pesticide product safety
    • Reading labels
    • Following directions
  • Pesticide application
    • Best health practices during application
    • Restricted Entry Intervals training
    • Posting signage to protect workers from entering areas that have been recently sprayed
  • Use of protective equipment
  • Pesticide handling
  • Decontamination practices

2020 AEZ Requirement Updates

On December 29, 2020, the EPA enacted updates to the AEZ provisions under the WPS that “improve enforceability for state regulators and reduce regulatory burdens for farmers.

The final rule prohibits applicators from using a pesticide in a manner that would result in sprays contacting unprotected individuals either directly or through drift. Here are some of the biggest changes to the AEZ provisions: 

  • Agricultural employers and handlers can make or resume applications when individuals are in an area subject to an easement, provided that the handler can ensure that the application will not contact those individuals.
  • EZ requirements are limited to within the boundaries of the agricultural establishment, removing off-farm responsibilities that were proving difficult for state regulators to enforce. No changes were made to the “Do Not Contact” provision.
  • Criteria for deciding whether pesticide applications are subject to the 25- or 100-foot AEZ are simplified.

Click here for a complete FAQ document from the EPA that describes all the changes in great detail.

Who needs to comply with the WPS?

  • Any employer or employee of an agricultural or commercial business that handles pesticides, including farms, forests, nurseries, and greenhouses.
  • Any employer of agricultural workers who work in places sprayed with pesticides within the last 30 days or have high-contact agricultural tasks like weeding, moving irrigation equipment, pruning, and harvesting.

To be compliant with the EPA, you or your employees can complete WPS training using an EPA-approved WPS course.

When you choose our training program, there’s no need to worry about scheduling, organizing the logistics, or tracking records and paperwork. Our system handles it all automatically. Here are some more benefits our program offers:

  • We provide all EPA required documentation.
  • Certificates are downloadable immediately after completing the course.
  • 24/7 access to the program online for an entire year.
  • All video courses are provided in Spanish & English!
  • Save time & money by avoiding the classroom and using our program instead.

If you know of any businesses that need WPS training - click here for more information on our online program!


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New Michigan Emergency Rule Extends License Renewal Deadline

On December 30, Michigan pesticide applicators got perhaps their last gift of the holiday season in the form of a new emergency rule from the Michigan Department of Agriculture and Rural Development’s (MDARD). The new rule extends the validity of any licenses that expired on December 31, 2019 or December 31, 2020 to June 30, 2021.

In addition to extending the expiration date, the rule gives applicators six additional months to renew their licenses via continuing education courses.

“Extending applicator credentials and giving them more time to complete their continuing education courses allows inspectors to focus on our regulatory activities protecting human health and the environment from misapplications of pesticides,” said Brian Verhougstraete, MDARD’s Pesticide Section Manager. “It also provides certified applicators and businesses some regulatory clarity and ensures they can continue their work protecting our food supply from damaging pests.”

If you don’t have time to read the entire emergency rule, here are the relevant highlights.

  • A certified or registered applicator license with an expiration date of December 31, 2019, is considered valid until June 30, 2021.

  • A qualified certified or registered applicator who renews a license with an expiration date of December 31, 2019, shall be issued a license that is valid until December 31, 2022

  • A certified or registered applicator license with an expiration date of December 31, 2020, is considered valid until June 30, 2021.

  • A qualified certified or registered applicator who renews a license with an expiration date of December 31, 2020, shall be issued a license that is valid until December 31, 2023.

The Natural Resources and Environmental Protection Act, P.A. 451 of 1994, Part 83, requires individuals to be either a certified pesticide applicator or a registered applicator to apply a pesticide for a commercial purpose. The Act also requires certification for anyone wishing to purchase a restricted use pesticide. Michigan’s certified pesticide applicators must pass written examinations to ensure they have the knowledge and skills necessary to properly apply pesticides in a manner that protects themselves, the public, and the environment. 

Whether you want to get licensed or renew your license, our online courses can help! Click here to view all the courses we have available for Michigan.


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Oregon Phasing Out Chlorpyrifos Use by 2023

Last week, the Oregon Department of Agriculture (ODA) filed Administrative Rules with the Oregon Secretary of State that immediately limits the use of chlorpyrifos-based products and phases out nearly all use by December 31, 2023. 

ODA said they wrote the rules with the help of a “diverse workgroup” of leaders and experts from many backgrounds including agriculture, environmental justice groups, toxicologists, and farmworker health-and-safety organizations. ODA’s goal for these new rules is to reduce the risk potential exposure for “workers and bystanders.”

Chlorpyrifos, a popular “broad-spectrum” insecticide mainly used in Oregon on Christmas trees, leafy greens crops, and alfalfa, has been the subject of many critical studies over the years. To understand why Oregon is taking this action, we’ll first dive into the controversial history of chlorpyrifos.

Chlorpyrifos History & Toxicity Studies

Chlorpyrifos has been registered by the EPA as an insecticide since 1965, and is widely used on nearly 50 different crops including corn, soybeans, and almonds. It’s highly toxic to birds, fish, and bees. Chlorpyrifos is an organophosphate, which makes it a “nerve agent” - meaning it kills pests by creating an overstimulation in the nervous system. This effect also makes it highly toxic to birds, fish, and bees. In 2000, prolonged exposure to chlorpyrifos was deemed toxic enough to humans to get most residential uses banned outright.

Between 2000 and 2012, the EPA added additional restrictions on certain crops like tomatoes, and “curbed the insecticide’s use by reducing the rate at which it can be applied and banned its use in certain areas near residential and public spaces.”

Calls to ban all use of chlorpyrifos came from multiple studies linking chlorpyrifos to developmental issues in children. Here are summaries from just a few of the studies:

  • “Low to moderate levels of exposure to the insecticide chlorpyrifos during pregnancy may lead to long-term, potentially irreversible changes in the brain structure of the child, according to a brain imaging study by researchers from the Columbia Center for Children's Environmental Health at the Mailman School of Public Health, Duke University Medical Center, Emory University, and the New York State Psychiatric Institute. The changes in brain structure are consistent with cognitive deficits found in children exposed to this chemical.” - source
  • “Exposure to the pesticide chlorpyrifos is associated with early childhood developmental delays, according to a study by researchers at Columbia University’s Mailman School of Public Health.” - source

  • A UC Davis study found that mothers who live within a mile of fields where chlorpyrifos and other organophosphate pesticides were applied had a 60 percent higher chance of having children with autism spectrum disorder. - source

Studies like these along with pressure from many external forces led the EPA to propose the complete ban of chlorpyrifos in 2015, stating they were “unable to conclude that the risk from aggregate exposure from the use of chlorpyrifos meets the safety standard.” By as late as November 2016, the EPA was still on track to ban all chlorpyrifos use.

But in March 2017, the EPA (under a new administration and with new leadership), overturned these efforts and stated it won’t outright ban chlorpyrifos “without first attempting to come to a clearer scientific resolution” on the matter, a task it’s set to complete by 2022. A few studies (one from China and another from Canada) that influenced the EPA’s 2017 decision did not find any association between organophosphates developmental issues in children. However, the authors of both studies admit limits to their findings, and the doctor who conducted the Chinese study warned “results should be interpreted with caution, and more studies of children living in China are warranted. 

With a federal-level ban off the table for the time being, states are taking action. In recent years, California, New York, Hawaii, and Maryland have either banned or greatly limited chlorpyrifos use. Now, with the context established, we return to Oregon. 

Oregon’s New Rules

According to ODA, the following measures are effective immediately upon rule adoption:

  • Use of chlorpyrifos for mosquito vector control, golf course turfgrass, and certain types of enclosed structures is prohibited
  • A 4-day restricted entry interval after use for all crops, including nursery and Christmas Trees.
  • Aerial application is prohibited on all crops, except for a very narrow window of time on Christmas trees.
  • All applicators must pass a pesticide certification exam and obtain a license.
  • Respiratory protection requirements are increased.
  • Recordkeeping is required, and must be maintained for at least three years.
  • To protect bystanders and water quality, expanded buffers are required around sensitive sites and waterways.

Effective January 1, 2021

  • All products containing chlorpyrifos will be restricted-use, except for cattle ear tags. 

Effective March 1, 2021

  • All mixer or loaders of chlorpyrifos must either be a certified and licensed pesticide applicator, or have successfully completed a special training conducted or approved by ODA.

After December 31, 2023

  • It is prohibited to use or sell chlorpyrifos except for:
    • Commercial pre-plant seed treatments
    • Granular formulations
    • Cattle ear-tags

The final rule prohibits aerial application on all crops, except Christmas trees, for a ten-week window between April 1 and June 15. This permitted window will be prohibited after December 31, 2023, providing a transition period for the nation’s largest Christmas tree industry.

"We feel like we came up with a rule that gives some flexibility to the agricultural community, and is protective of workers, bystanders and water quality," said Rose Kachadoorian, ODA pesticides program manager. "We will work with the industries as best we can to help find alternatives."

What do you think of this latest chlorpyrifos ruling? Do you think more states should follow Oregon? Let us know on social media!


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2020 Recap: Positive Pest Control Company News

We know - this has been a weird year. With so many annual routines disrupted and the seemingly endless negative news cycle, we want to highlight various stories from the past year that show the many ways pest management professionals like you have made a positive difference in local communities.

Meeting Surging Demand

Thanks to a survey of over 3,000 households from Smith’s Pest Management in California, we have an idea of how the pandemic created a surge in “unwelcome house guests” across the country. One big reason for the increase in household pests, according to the survey, comes from increased household waste. 

In Michigan alone, the survey found a 24% increase of pests since the start of the stay-at-home orders. Click here if you want to look at an interactive map and see the numbers for your state!

Despite these rising numbers, you and your pest management colleagues from across the nation did and continue to do the essential work of keeping full homes (and empty offices/restaurants) safe from pests. And speaking of restaurants...

Supporting Local Communities

Keeping Out Unwelcome Diners

With many states enacting renewed pandemic safety orders, such as closing indoor dining at restaurants, one pest control company in Fort Wayne, IN is stepping up and making a difference.

Ben’s Bugs Be Gone is offering free pest control throughout the winter for local privately owned restaurants. The owner, Ben Williams, is a COVID-19 survivor who said his recovery experience changed his perspective. Now that he’s working again, he wanted to give back to the community. 

Williams says he knows local restaurants and businesses are struggling, and with these facilities closed, they will most likely have to deal with whatever pests made their way in, while the business was on its way out.

Partnering With Local Charities

We know there are plenty of pest control businesses that have helped their local communities; probably too many to count! But here are three examples that may inspire you or your business.

Near the end of November, P.E.S.T. Relief International (which here stands for Professionals Empowering, Sustaining and Transforming) showed its support for military veterans by creating the “A Bag of REST” project that launched during the Certified Pest Control Operators (CPCO) of Georgia conference. 

During the CPCP, participating pest management professionals carefully filled backpacks with toiletry kits, masks, snacks, and personal notes of encouragement. Project sponsors included Target Specialty Products and Bug Off Pest Control Center.

After the event, Andrea Hancock, founder of P.E.S.T. Relief International and vice president of Mattress Safe, drove the backpacks down to the Elks Lodge in St. Petersburg, FL, where she distributed them to local veterans residing at the Bay Pines Veterans Administration Healthcare System.

“I had the pleasure of meeting four veterans who were homeless and offered them a Bag of REST as a tangible way to show our deep appreciation for the sacrifice they made for our country,” Hancock said.

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In early fall, Logan, Utah-based Fox Pest Control and the Make-A-Wish Foundation of Utah threw Mason, a local teenager, a “reveal event” in which he learned he was selected by the foundation to grant his wish.

Fox Pest Control made the reveal event possible by contacting several local businesses to help donate food, supplies, and funds. Make-A-Wish Foundation Community Manager Melanie Rossiter described working with the Fox Pest Control team as “an absolute joy.” 

“Fox embodies what it means to be a partner that truly puts the wish kid first. Every detail of the evening was clearly based all around Mason’s interests and favorite things. We are so grateful to grant wishes with such a generous, thoughtful, community-oriented business,” Rossiter said.

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If you’re thinking that you can’t do anything “big” like these last few examples, take a look at what Miller Pest & Termite from Missouri did back in November. When it comes to supporting your community, even the “little things” make a big difference.

To commemorate Breast Cancer Awareness Month, the team at Miller Pest & Termite automatically donated $10 for every new service it signed on to the Pink Tractor Foundation, a Non-Profit Organization that raises money to help local families fighting cancer.

Additionally, the company also matched customer donations up to $1,000 in total donations. Miller said it is proud to have raised a total of $1,120 for the Pink Tractor Foundation. This charity is one Miller felt strongly about supporting since some of its own families have been affected by Breast Cancer.

Adapting To Meet New Needs

Back in July, Arizona-based Truly Nolen Pest Control made the news for adapting their business to exterminate not household pests, but COVID-19. After Truly Nolen Pest Control realized they were already using an effective COVID-19 “killer” sanitizing spray for cleaning up after rat infestations, they decided to start a new side “business.”

Truly Nolen worked out procedures for a program called Truly Sanitized, developed training and then started offering their new service. Mark Ringlstetter with Truly Nolen said he sees the value in large scale sanitation for his pest control business.

“I would imagine [the pandemic has] changed everyone's perception of how to protect yourself against things like the common cold or even the flu. So I think you're going to see some public behavioral changes with the way they go about things.”

Are there things you or your business has done to help your community during the pandemic? We’d love to hear about it! Let us know on social media or email us for a chance to be featured in a future blog!


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By the Numbers: Inside Washington’s Murder Hornet Nest

After the Washington State Department of Agriculture (WSDA) found and removed an Asian Giant Hornet nest late last month, there was still one major step left; opening and examining the nest.

Removal of the nest itself was complicated due to the fact that it was tucked inside a tree. Once WSDA entomologists had safely removed the hornets living in the nest, they also removed the tree itself before splitting it open to reveal the nest inside.

The nest was just over 8 feet high in the tree and, once opened, was found to be about 14 inches long and 9 inches wide. So far, over 500 Asian Giant Hornet specimens in various stages of development have been collected from the nest, and the counting is still ongoing! 

Here are the preliminary results of what WSDA entomologists found in the nest.

  • 6 combs – There were six layers of comb in the nest. Combs are the structures that hold the hornet larvae as they develop. Part of the interior of the tree had been chewed away to accommodate the combs.
  • 776* cells – The combs are made up of cells and each individual cell can hold a developing Asian giant hornet. *This number is approximate as there was some damage to the combs.
  • 6 unhatched eggs These eggs were all located in the last and smallest of the combs.
  • 190 total larvae - The larvae are whitish “grubs” in uncapped cells. Many had fallen out of the combs into the tree cavity during the nest removal.
  • 108 capped cells with pupae – Pupae are the next stage after larvae. Based on the size of the cells, most of the pupae found are believed to be pupae of new virgin queens.
  • 112 workers – This total includes 85 workers that were vacuumed out of the nest on Oct. 24. All of the workers survived being vacuumed out of the nest.
  • 9 drones – Drones are male hornets and they generally emerge from the nest before the new queens emerge.
  • 76 queens – Most likely all but one queen would be new virgin queens. New queens emerge from the nest, mate, and then leave to find a place to overwinter and start a new colony the next year.

Despite multiple applications of carbon dioxide, removal of the workers, and storage in a cold facility, most of the specimens were still alive when the nest was opened.

Nest reassembled in tree - image from WSDA blog

WSDA’s Future Plans

WSDA plans to continue trapping through at least Thanksgiving and possibly beyond, but will likely only track worker hornets. Even if no other hornets are found, WSDA will continue to trap for at least three more years to demonstrate the area is free from Asian giant hornets.

If you may have seen an Asian giant hornet in Washington State, report it with a photo if you can get one at:

If you believe you have seen an Asian giant hornet but live in another area, please report it to your state or province’s invasive species managers.

Source: WSDA website

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Study Shows Many Pesticide Labels Don’t Follow EPA Guidelines

According to a study by the Oregon State University (OSU) Extension Service, over 30% of pesticide labels fail to follow Environmental Protection Agency (EPA) recommendations and provide incorrect information about their toxicity to honey bees. The research, which was discovered by an unsuspecting young student, may be used by regulators to identify labels that need amending. 

"I kind of stumbled onto this research project by accident," said Matthew Bucy, now a pesticide registration specialist at the Oregon Department of Agriculture.

While working as an OSU undergraduate honors student, he read through hundreds of pesticide labels in order to update a data table. After studying 232 insecticide labels, Bucy discovered a clear pattern. About a third of the labels deviated from EPA recommendations, and many didn't list accurate details about their residual or acute toxicity.

Rose Kachadoorian, a pesticide specialist at the Oregon Department of Agriculture (ODA), and formerly an adviser on Bucy's thesis committee, said the pesticides weren't misbranded or mislabeled intentionally; “they're just old.” “A lot of the language is what we call legacy language," said Kachadoorian.

Bucy's “accidental” discovery turned into a major research project that has continued well past his graduation. Kachadoorian, Bucy, and experts at the ODA formed a working group called The Oregon Bee Project to address the labeling problem. While they continue to hold workshops that try to educate pesticide applicators, they expect changing label language will take time.

Kachadoorian said her ultimate vision is to create a standardized labeling system for pesticides.

“Look at FDA pharmaceutical labels, she said, they all have similar formatting.”

“You know where to look on the label to find things like dosage and possible side effects. But pesticide labels look different across companies, making information harder to find.”

Bucy said his groundbreaking research as a student led to his job in pesticide work at ODA, where he hopes to continue helping the agricultural community.

"I read a few hundred labels. Why not read a few hundred — or thousand — more?" he said.


While you may never have to read hundreds of labels all at once, make sure you understand the ones you do need to read with our Reading the Pesticide Label: Beyond the Basics video course!

You’ll find that course, and many others, included in our Oregon Pesticide Applicator Continuing Education Bundles - register now before the December 31st deadline


You can read the entire unedited article here


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