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

You Wanna New SDS???? Quit your whining and read the LAW!

Okay….so maybe this is a sore spot.

The rules, laws, regulations blah blah blah set up around WHMIS 2015, SDS versus MSDS, Global Harmonization and expiry dates are not confusing at all,  if you have the 17 days, 4hours and 37 minutes to read them.

BUT…

This is actually something that makes sense.  I want to know which products myself and staff are dealing with that are deemed hazardous.  Meaning it’s going to f%$# up somebody or something or the environment if you mess around with it.  Like get serious here.

Which is why WHMIS falls under the Hazardous Products Act.

The problems with WHMIS, and have always been problems, are twofold; one being the expiry date issue and secondly generating an SDS for non-hazardous products.

(I won’t get into the fact that Pesticides are exempt)

With the new WHMIS 2015 coming into full effect December 2018, the right decision was made to eliminate the expiry date UNLESS there is a major change that will affect the health, transportation and storage of the product.

Not every 3 years…just because some CFIA inspector has been doing it this way since 1988 when the first rules came out.

Only when there is a MAJOR change.

Otherwise:  THEY DON’T EXPIRE!!!

Not clear enough?   THEY DON’T EXPIRE!!!!

As to my second point, I believe generating an SDS for goods that are non-hazardous should be a crime against the state and capital punishment enforced.  Remove one finger for each infraction.

I won’t name names AP&G, but why I have 30 SDS’s for a glue board is beyond me…

There are others though.

But in my puny mind if there’s an SDS it means you’re dealing with a hazardous product, which also means all the boxes should also be properly labelled, with First Aid steps, transportation rules, handling and storage, plus evacuation and firefighting measures spelled out.

You can’t pretend your product is Hazardous, when it’s not, and fill in all the data with N/A, N/A, N/A.

If it isn’t hazardous drop the friggin’ SDS for crying out loud.

Now’s your chance!!!!

We should have a contest though…101 ways to kill your lover with a box of 72 MB unscented glue boards.

 

Want NAFTA to truly work? Two little changes

Here ya’ go…my magical methodology on fixing the woes of the North American Free Trade Agreement:

1. Open the borders between the three countries

2. Standardized currency

Think like….EURO????

This little suggestion leads to about 6 separate rants, so at one per week that takes me to Spring!

But:

Step 1 OPEN LES BORDERS (for my french friends) and yes this would include the Quebec border.  Unfortunately French would become the 12th most spoken language, right after Vietnamese, and no longer part of the “bi-lingual” mix.

No WALL.   If one was ever needed, then let Mexico put up a tiny one on their southern border.  What country is that anyway, Nicaragua or some other “shit hole”.

Even with a minimum wage Labor costs drop 25%.   Cool.

Trump would freak not being able to keep the hordes from moving north…or else he’d be happy with cheap domestics (like he doesn’t have already)

2.  One common currency:  If you ever ever really really want free trade, then create a common currency. That’s a frigging no brainer.  A “Euro” could work.

Call it whatever…NABitCoin, MEXCANUS, TRUMPASSO,

Government and Industry spend hours and millions to come to an agreement, and 3 years later you can buy Levi’s for a third of the price by crossing the Rainbow bridge into Canada from New York.

Or figure out who’s really winning in this situation and get on with it.  Forget NAFTA.

A hint though, of the three countries it ain’t Canada or Mexico.

 

So did you check? But let’s talk numbers

Okay…I almost forgot but something has been bugging my arse…that’s a really cool word we should use more often.

Have you been following the NAFTA debate?   Softwood lumber and automobiles.

Yes it’s serious, very serious, powerfully serious.

My vote????  If it mattered?   Kill NAFTA and let free trade rule.  NAFTA has nothing to do with free trade.

But boil it all down to a pot of stew and it’s still simply who wants to make the most money out of the deal…from a politicians standpoint only.  Tit for tat doesn’t exist anymore.

It’s like the wife’s wedding vow “what’s yours is mine and what’s mine is mine”  (not my wife of course but I heard that from other guys…)

But Trump says the scale is unbalanced, that there is a grossly disproportionate amount of the trade dollars ending up in Mexico and Canada hands.

Here’s the argument on soft wood lumber in a nut-shell:

The US timber farmer (rancher?) has to have his own land in most cases.  This requires him to make more inputs into producing his lumber.

Where the Government of Canada simply cuts some wood for a new 3000 mile pipeline, stacks it by the road and HALLELUJAH!

And what US auto companies are caught up in fighting Canadian auto makers???    Might as well throw the Mexicans in on that one.  Not much market for soft cactus…whoops…hand me a shot and a lime.

NAFTA is so full of trade agreements, “balance” so to speak, that it’s become meaningless.

What country had the bright idea in the first place?

 

 

Neonics and pest control…is there an effect?

Okay what brought that on was reading all the posts following a story I read on CBC.ca concerning the PMRA and a just published commentary doc.  Not many times you see the PMRA in the news, surprisingly.

The document highlights further restrictions on neonics and allows for a 90 day comment.

To be honest I have yet to read the PMRA doc, but will.  The impact is more ag and crop related from what I gather.  Our neonics for structural should be non-impact on the bee decline.

And all the posts following the CBC story were from the anti-pesticide movement, claiming the restrictions should be an actual ban.  Some made valid points.  Not all tree-huggers have sap for brains.

But some do.

So as is my nature I’m mulling through the plight of the honey bee.  Cell phone towers, auto congestion, airplanes, smoke and pollution.

I’d be confused as hell if I was a bee.  Most days I can’t even find my way down the stairs.

But maybe not just the honey bee if being effected by all this bad air

I don’t want to imply a correlation between the decline of the bee and the overall business for outdoor pest control services….but…..

Namely wasp, hornet and bee calls.

They’re down. I guarantee it.

So if the same thing is having an effect on the bee is affecting our outdoor business, then where should we stand?

I know the major suppliers will say there’s no effect, but makes you wonder.  I think it’s a combination of hundreds of effects, some more harmful than others.

In an industry where your job is controlling pests, and there are no pests….

True Detective #132

So the police respond to an odor complaint, Apartment 3G in the THC apartment complex off Bloor.

Upon arrival, they immediately know the problem, a corpse must be behind the cause, and behind the door to Apartment 3G.

Luckily enough they were being accompanied by that famous Canadian detective, JB “Gord” Fletcher (no relationship).

And sure enough, after kicking in the door there lies the corpse of a man sitting in his easy chair, the TV on to the latest CSINCISLAWSVU episode.

Dead as a door nail.

Mysterious circumstances, or just a plain old boring natural death?

So brilliant JB sums up the situation:

“400 pound man, mid-fifties.  Ashtray full of Camel butts, but he smoked alone.  Last meal was a party pizza, extra cheese, topped up with a 48 ounce slushy and a bag of cheetahs.  Face has that orange color you see in cheetah addicts. Beer cans everywhere, Coors Lite thank god.  Surgical tube pulled tight on one arm, but no needle.  Bottle of nitro, but not enough for a terrorist attack.  Bad heart?”

“What do think the cause of death to be?”  queries JB to his escorts.

Young rookie (are there ever old rookies?) surmises;

“This one’s too obvious.  Obese, addicted, alcoholic smoker with a bad ticker choked on a cheetah while going through withdrawal”.

“I second that” chimed in the old pro.

“Aha and au contraire” cried JB.   “On the surface it may look like an easy call but, you missed a few fine points.  If you look closely at the pizza box you’ll see the 3rd leg of a cockroach, obviously an Oriental nymph.  My guess 2nd instar.

“Secondly, what appears to be injection sites on his arms are actually bed bug bites.”

“Thirdly, if you look at your white socks you’ll see they are now covered in fleas.”

“And lastly, sitting on his windowsill is a can of BuGBuster Blaster”.

“So it’s pretty obvious…

Gotta be the pesticide!”

 

 

Robert’s Rule on Rodenticides: “What’s the Worse that can Happen”

Here’s the bare facts:

I believe the Industry has been given a false sense of comfort on the Evo Express and tampering.   Is the Evo 100% safe in preventing secondary poisoning?  Nope.

The other problem is we only have bromadiolone to use outdoors.  (except in underground burrows which is considered “indoors”)

Of the 2 – 3 bromadiolone products available, it appears Resolv has a very high attraction rate to rats.   BUT…this seems to be true for all rodents found in the woods, parks or backyards.

Mice, rats, chipmunks and squirrels.  Little critters with very sharp teeth.

If you use a highly attractive bait in any plastic station, you may have secondary poisoning.  Always?  Of course not.

Can you give a 100% guarantee this will never ever happen though?   Nope.

If you put a T-rex in an Evo then no problems right?  Wrong.   If you’ve never seen a squirrel in a T-rex you haven’t been around long enough.

But you then have the problem of daily inspections and re-setting traps.

Do we prepare ourselves for any situation? Nope.

This is where we lack in our planning – the what if’s.  And being prepared for worse case scenarios.  Even if it never happens.

How many of us know what to say to the homeowner if there’s a dead squirrel in the yard?  Does it happen?  Maybe one in a million, but how do you address?

Does anyone have the information Lipha provides on secondary poisoning always on hand?  A copy in their truck?  What to do and how to react?  Poison control center numbers?

If you prepare for the Worse case scenario, you prepared for anything.

 

 

 

 

 

 

EVO and RESOLVE. Too good to be true?

I’ve beat this dead horse before, until it turned into horse jerky, but a word from the wise (me!)

Tamper Proof – nothing can get inside   (like my brain)

Tamper Resistant – kinda holds ’em back  (like my diet)

Tamper Evident – red flag goes up once it’s been tampered with (like my hand in the cookie jar)

I really believe that someone (the name doesn’t ring a BELL) did such a good job of fear-mongering and confusing the regulations with marketing that PMP’s truly believe that if you use an Evo Express you have nothing to fear on non-targets getting at the bait.

“But Bobby baby…..it’s Tier 1!”

But what the hell does that mean???  Entrust our Ottawa government types to write mis-leading legislation.  Tier 1 in Canada applies to Domestic products, BUT they included the language on all Commercial labels.

Through it all though, the onus lies on one person and one person only.

You.  The individual who puts the bait and stations out.  Neither Bell or Lipha will jump in.

So

Read the top of the station:   Tamper Resistant

Now, add to that a regulation that only allows bromadiolone to be used outdoors, and you have two options:   Contrac Blok or the new and exciting Resolv!  (forget Maki – everyone else has – even the supplier)

BUT….Resolv is so attractive to rodents it might even attract chippies (I’m turning Canadian), squirrels and beavers  (hey government inspectors…this is humor in poor taste remember).

So imagine a highly attractive bait in an indestructible bait station.  Perfect right????

Tamper resistant…

So the simple moral of this story???

You need to think, and think hard, on how and where you use a bait, and what you put it in.

Is there a total squirrel/chippie/beaver tamper free option?     Sure, let the rats have their freedom!

 

 

GREAT NEW DEMAND CS LABEL???

Just read this and either shake your head, laugh, say WTF or maybe get on the phone to your MP and ask why your tax dollars are going to waste.

June 24th:   the PMRA issues the PRVD2017-03, pretty well eliminating lambda-cyhalothrin uses in all crops, and some of our structural uses.  Primarily residential indoors and turf.

August 23rd:  the PMRA issues a new and improved label for Demand CS, with more insects, more sites, and better language on some of the uses.

Does this seem like a logical move to you?  I can see, well kinda, well – no I can’t understand why this wasn’t done in some sort of coordination between Cubicle A and Cubicle B.

The PMRA Giveth, and the PMRA taketh away.

 

Demand_EN_Label_09_17

 

Let’s Get Real – and I won’t name names

In reviewing the data of a pesticide within the cyclical guidelines of the PCP Act, I decided to look at the maximum rates, and maximum allowable applications to determine the potential exposure levels possible.

And to be on the safe side I take the evidence (rat and mouse studies) and apply a 300 fold safety factor.   That’s what I’m putting in my report.

So that’s 10 fold for intra-species differences (one rat might be different than another) and another 10 fold for inter-species differences (humans ain’t like rats) then another 10 fold for the little kiddies (cuz their parents let them lick the floor).

So 300 fold the safety level….

But wait… 10 x 10 x 10….doesn’t that equal 1000 fold safety level?  Oh, I can say 300 fold, then change the math to fit my desired outcome.

So instead of meeting the criteria of less than 1 per million incidences of a potential carcinogenic effect, I’ve changed the hurdle rate to one per billion chances of contracting (that’s not the right word) cancer from this product.

1,000 x 1,000,000.  Do the math.

So in the entire human population of 7 billion, there may be a chance that 7 people develop  cancer due to direct exposure to this product.

Perfect, I ban those products or uses to save those people.  I am good.

What’s that?  What about other benefits?

Lyme disease, West Nile, asthma, Zika, malaria.  Bed bugs and the effect on the psyche of people living with them.  Cockroaches sharing your food, which many people can’t afford. Stored product pests completely ruining grains and flour, food and feed.

And all the other benefits that product brings…

I still ban it to save those 7 people.  I am good.

Zero use means zero risk correct?

Hey buddy, can ya’ spare a smoke?  Gotta ponder this.