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

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