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

PMRA: Do Labels Need to be So Confusing??? Pictograms baby!

This year like every other I get several daily phone calls about what product to use on what insect for what location.  I try not to wince too much when I await the response to “Have you read the Label?”  And don’t tell smile too much when you say “Of course!  I always read the label!”

They are complicated, over-written and over-regulated and as such they don’t get read as they should.  MY OPINION (although I find I’m right more often than wrong)

Here’s the solution first,  then followed by some clever support ranting.

Roberts Two (2) Part Label Improvement:

  • Reduce the Labeled Sites to 10 at most and make these consistent on EVERY label.  Outside, but not the deck!   Garbage room, broom closets, mud rooms, overhead drop celings with 2’x 36″ tiles only.  Give me a break!
  • Remove having to list each and every genus, family, order, species and sub sub-species.    A PMP should be smart enough…heavy emphasis on the “should be” ….to know what is causing call backs or not.  And if a tech rep made the recommendation he should be demoted to the US

Simple Simple.

As I read through a long label this morning I was surprised at how confusing it was.  Long lists or paragraphs of sites and longer (or real short) lists of insects.  But then there are numerous references to “other areas” and “where insects hide”.

What about a label reference to “insect pests such as…blah blah blah”?   Isn’t that an open-ended recommendation where other insects, not specifically mentioned, could be treated?  I could interpret that as all Insecta…such as my arse.

Crack & Crevice Only:  hmmm then  it says one paragraph later “if you see ’em spray ’em!!!”   Like I’m stupid and need to be told that one.  But the product is no longer C&C only.

The PMRA is trying to streamline the use of products, but more so on application nomenclature (definitions) than sites and pests.  Hopefully more extensive.   I hope it isn’t more confusing than we already have.  But why not streamline the whole shebang?  Consolidate the insect pests and sites also, then maybe the more important factors of rate, safety, first aid and disposal might get more attention.

ALSO…The PMRA should not be playing consumer advocate and requiring individual testing on each and every pest.

Have you ever noticed that IMM (Indian meal moth for those of you with less than 2 months of experience) isn’t on some of the permethrin product labels????? Small matter, but it doesn’t work?  Or does it?  Not that I would use it, but what scientific reason exists that an IMM is immune to permethrin?

Or is there a scientific reason, say the lack of substantiating data and submission??????

I am not advocating de-regulation or making the product “too” easy to use, but since everything else is going to pictograms for those that can’t read, we should follow suit…

You could have a Dragnet Label that would include 87 glossy pictures of bugs!   Then people could see the difference between a roach and a stink bug!

 

 

 

 

 

 

 

 

 

Bed bugs are labelled…just not where they hide!

Here’s a prime example of an on-going PROBLEM in our federal registration process, and with the supplier industry to some extent.

On the label, and rightly so, are statements explaining WHERE you can use a pesticide, and on WHAT pest, and at the correct RATE.

Easy Peesy as my granddaughter would say.

Au contraire..

A recent inspection brought to light an issue, while accurate, really should be examined and worked out.

Dragnet is labelled for Bed Bugs, in a residence, and as a crack and crevice only.  There are lots of suggested locations on where to spray.

Just furniture is not mentioned, or beds, and a crack & crevice on/under the box springs has been deemed to be an illegal treatment.   And in review of all the labels, it appears Demand mentions not to spray surfaces of furniture where people can come in contact with the spray. but not Dragnet or Prelude

Is it interpretation, or black and white?  In this case if an area or item is not specifically spelled out, it is not allowed.

And in this case, or any bed bug case, you can spray according to the label, and still have a 1000 insects toasty cozy in the frame.

To sum it up,  we are trying to make an exact science out of something with constantly changing variables, locations and insect pests.  It’s like we want to manage the product to such extremes we kinda forget the purpose of it???

THE MATRIX:

We are blessed (ahem) with a very limited selection of chemicals in Canada, but if added up, 83.28% is a pyrethroid.   A synthesized bench lab chemical now churned out by big chemical plants.  At $3.00 a kg.  There may be 4 – 5 generations of products, but a pyrethoid is a pyrethroid is a pyrethroid.  The major difference is rate responsiveness, residual activity, and some variation in toxicology.

And yes I realize there may be different sodium channels for each…but don’t get anal about it.

So when a new pyrethoid is registered…shouldn’t we have the same sort of insect pests and locations on each???

Do we need 5 pyrethroid products with a huge variation of insects and locations…and restrictions…

(it’s here where I need to say everything I say may be wrong and is not representative of me, myself and my kinfolk on the poor farm in Kansas, my wife, my one grandson but not the other and won’t take responsibility for anything)

READ THESE LABELS!

Example; is Deltagard good on all tick species and not one other structural insect?   And the Perm Boyz, Prelude and Dragnet, only work on brown dog ticks.

Quantum will NOT control carpenter ants…I love this one…If I have pharaoh ants AND carpenters I need two baits.

Demand will kill Germans, but not Orientals.  Or is that vice versa?  Which one has the stripes and can fly backwards????

You can use a 0.5% aerosol pyrethrin for flying insects, not for crawling.  That takes another a different 0.6% product.

lambda is okay on box springs, not permethrin.

BUT…can each of your haul around 10 different products???  Just because one rodenticide is labeled for outdoors and one for indoors?

I AM NOT ADVOCATING GOING OFF LABEL!!!  DON”T EVEN THINK ABOUT IT!

But, maybe we can sit with the industry and PMRA and university researchers, and come up with a better plan?   An easier and safer plan?

Let’s disconnect the matrix, and come up with a solid INSECT CONTROL plan, with the use of pesticides as a component…only.

I’m available, for small stipend!