Robert's Rants
Robert's Rants
A personal blog on the Canadian pesticide industry and other pet peeves and interests

PMRA Proposes Demand CS Indoor Uses Eliminated: ACT NOW

I’m inserting a section of the Product Re-evaluation Document specifically covering Demand CS .   The PMRA is proposing elimination of all indoor residential uses of the product.

“The following postapplication scenarios were assessed: application for bedbugs, band and spot application, and crack and crevice application. Both cancer and non-cancer risks of concern were identified for all lifestages from dermal exposure for all scenarios except crack and crevice application. Both cancer and non-cancer risks of concern were identified for children from incidental oral exposure for all scenarios including crack and crevice application. Revised label directions are proposed to specify that crack and crevice applications are only permitted in non-residential areas.”

Their “cancer and non-cancer risks of concern” are not scientifically based, and in generally unfounded.  They are stating a “concern” about children having an oral exposure to the product, even when applied in a crack and crevice application, under box springs or behind a refrigerator.

The Industry needs your help now…YOU ARE THE INDUSTRY!

There is a 90 day comment period on the proposed changes and YOU NEED TO COMMENT.

 Read through the whole executive summary (linked below) and comment.  Always refer to PRVD2017-03

Here’s where to comment:

Okay okay….back to Pest Management: The #1 Rule!

And why the regulators don’t get this….(last half of my title).

I like the word regulators.  Makes it sound like you’re back in the days of prohibition…revenuers and regulators.  Fits.


The number one, numero uno, # 1 rule of Pest Management?????


IPM starts with exclusion.  A pest, or invasive species, isn’t a pest until it has actually invaded someone’s space or property, water or food source, and reduces the quality of life overall.

Isn’t that too simple?

BUT (did you sense that coming?) we seem to be forgetting that fact when we look at labeling that continues to be approved by PMRA.

First case in point was the ruling on rodenticides and restricting the only registered and allowable out door registration to bromadiolone.   One active ingredient out of the 5 -6 registered.

And what happens when you feed one active ingredient continually to a population, where 5% may survive from a lethal dose?   And a population that can drop new pups like Putin drops f-bombs on the Ukraine?

Like the French in WWII.


I’ve been reading through the re-evaluation again, and still don’t believe they had enough data to restrict the use of ALL the other actives outdoors.

Case in point #2.  A new Bayer product.  And I’m not picking on Bayer, because they have been getting the short stick on all their labels lately.

Think of the lowly house fly, just the one that isn’t inside your customers restaurant.   But he’s hoping to get inside your customers restaurant.  He’s not across town getting his nails done (that’s weird) or hanging at the track with boyz (yeah I’m ghetto cool).

He’s hanging right outside that restaurant waiting for that door to open.

14 seconds to make the egress from garbage to filet mignon.

The fly is probably sitting on the door frame…outside…

So logic…what a word…logic would dictate you would want to use the new Fly Spot…where?   C’mon people.  Think.


Here’s a new bait/pesticide combo that probably works great, with an indoor registration only.  Unless you count dumpsters, which may help.

A simple application of an attractant with a rapid contact used outside, like around the door frame where The Fly (Jeff Goldblum version) is sitting waiting, would seem to be the logical choice.

But there’s that word again.

One question though:  Does it make sense to use more pesticides indoors than out?

Give me exclusion any day.

Trudeau asks “Who Moved My Cheese?”

These trade concessions, tariffs, duties and “trade deficits” debates just continue to amaze, daze and confuse me.

First off I have to admit I’m simple minded.   Easily confused my wife says.

BUT…now Canada is upset with the EU on the price of cheese coming into the country.  It will destroy the Quebec cheese industry.  No more Oka!  (I hate that friggin’ commercial anyway)

And NAFTA looms overhead like a big stick ready to come crashing down…a big stick of soft wood lumber!

So does anyone else see the “weirdness” of all this?

One country is best at producing cheese, cheaper and just as good.

One country is best at growing timber, since half the country is forest.

And the USA can’t do much of anything, besides consuming goods.   Oh, and digging up coal.  But they are determined to protect their foresters.

Philadelphia Creme Cheese though!

It would seem to me that if the governments kept their noses and MP’s and Senators out of it, and the money out of their own pockets, this would sort itself out?  Granted some people would have to shift their way a earning a buck.

If I can’t grow lumber at a cheaper price than my neighbor (competitor) maybe I should find a means to do it better…or stick to the markets where I excel?

Or follow the government’s brilliant ideas, like giving away cheese to reduce supply and drive prices back up.

Global economy with a village mentality.

And no, I’m not the village idiot!