On April 13, the National Pest Management Association (NPMA) sent a letter to EPA outlining concerns about how new federal labels will restrict how pest management professionals apply pyrethroids.
Specifically, NPMA asked for (1) clarification of environmental hazard statements. NPMA asked that EPA clarify whether or not certain label directions were advisory or mandatory; (2) clarification of the label statement: "Do not water to the point of runoff." NPMA asked EPA to confirm that if the applicator does not water to the point of runoff but the customer or another person does water the treated area subsequent to the application, the applicator has not violated the label directions; (3) an amendment to labels allowing products to be used "to treat building surfaces for brown marmorated stink bugs, kudzu bugs, boxelder bugs, spiders, cluster flies, multicolored Asian ladybeetles, clover mites and carpenter bees, provided that the application does not exceed the point of runoff, and the surface being treated is above a permissible treatment site like a lawn, soil, turf or other vegetation, and not above an impervious surface or other use site that may not be treated.”
On May 21, EPA responded to these NPMA concerns in a letter addressed to NPMA Senior Vice President Bob Rosenberg.
Regarding the environmental hazard statements, EPA confirmed that those statements are “best management practices” and "not written to be mandatory, enforceable statements."
In response to NPMA’s questioning the statement about “watering to the point of runoff,” EPA responded that, “If the customer or homeowner, subsequent to the PCO application and watering-in, waters the treated area creating runoff, the applicator would not have violated the label directions.”
In response to NPMA’s request that the Agency allow non-agricultural outdoor use pyrethroid product labels to be amended for certain uses, EPA denied that request, noting that it “believes that the flexibility inherent in the 2009 pyrethroid non-agricultural outdoor labeling initiative covers the scenarios NPMA has raised.”
NPMA has indicated that it is still discussing this issue with the Agency.
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