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 Pesticides
This section of VetCA covers properties, risks, compliance issues and disposal requirements for pesticide used for controlling insects, rodents and other pests at a clinical facility. It does not
cover use of pesticides on animals.
Properties
A pesticide is any substance or mixture of substances intended
for preventing, destroying, or mitigating any pest. Pesticides are typically
used in many areas at veterinary care facilities. Some of the most common include examination rooms, waste disposal areas, public areas such as waiting rooms,
halls and offices, in addition to their
use outside for lawns, plantings, and other landscaping applications.
Over the last several decades, pesticide use has increased
dramatically. As of 1991, Americans were using approximately one billion
pounds of pesticides a year, twice what was used in 1964. Today, approximately
25,000 pesticide products, containing more than 600 different active ingredients,
are on the market in the United States.
Chemical pesticides have been used in the United States
since the 1950's. When effectively applied, pesticides can kill and control
pests including insects, fungi, bacteria and rodents. In human hospitals, chemical
pest control has helped to contain the spread of infection and has reduced
infestations with vermin.
On the negative side, pesticides have harmful side effects.
Many pesticides are known or suspected to be toxic to humans. They can cause
neurologic damage, delayed development, cancer, reproductive dysfunction,
and possibly impairment of the immune and endocrine systems. Concern about
these effects was first expressed in the early 1960's and now has become
widespread as knowledge has grown of the toxicity of pesticides.
Risks
In the process of eliminating
pests, healthcare facilities using pesticides risk exposing patients, workers,
and visitors to toxic chemicals through the inhalation, ingestion, and absorption
of pesticide residues. In addition, pesticides and herbicides can contaminate
local water resources.
According to the New York State
Attorney General's Office, there are about 25,000 pesticide products containing
600 different active ingredients, most of which target organ systems common
to both pests and humans. In addition to these ingredients, pesticides contain
a host of "inert" ingredients that are not disclosed on the label
and do not require the same health warnings applied to active ingredients,
although many are just as harmful to human health.
The effects of acute pesticide
exposure can include nausea, vomiting, headaches, rashes, dizziness, aching
joints, flu-like symptoms, and asthma. Long-term effects can include cancer,
birth defects, genetic damage, neurological problems, and chemical sensitivity
development. Infants and children, the elderly, pregnant women, and those
with compromised immune systems, allergies, and sensitivity to pesticides
are more susceptible to adverse effects.
Compliance Requirements
Applicable Regulations. The Federal Insecticide, Fungicide
and Rodenticide Act (FIFRA) provides EPA with the authority to oversee
the registration, distribution, sale and use of pesticides. (See
the FIFRA page for more information.) The
Act applies to all types of pesticides, including insecticides, herbicides,
fungicides, rodenticides and antimicrobials. FIFRA was first passed in
1947 and amended numerous times, most recently by the Food Quality Protection Act (FQPA) of
1996.
Requirements for Pesticide Users. As
a part of the pesticide registration, EPA classifies the product as unclassified,
general use, or restricted use (40
CFR Section 152.160(a)). The Administrator may prescribe additional
restrictions relating to the product's composition, labeling, or packaging. For
pesticides that may cause unreasonable adverse effects on the environment,
including injury to the applicator, EPA may require that the pesticide
be applied either by, or under the direct supervision of, a certified applicator.
FIFRA requires users of
products to follow the labeling
directions on each product explicitly. The following statement appears
on all EPA-registered product labels under the Directions for Use heading: "It
is a violation of federal law to use this product in a manner inconsistent
with its labeling." In other words, over and above the requirements
of common sense, healthcare facility staffs are required by law to
follow the safety precautions and use directions on the labeling of each
registered product. Note in particular
- Specified dilution
- Contact time
- Method of application
Not following these or any other condition of use covered
by the label would be considered misuse of the product.
FIFRA common areas for inspections. While a state environmental agency or EPA inspector is authorized to examine a wide range of documents and operations, he or she will probably be particularly interested in the following features:
- Personnel protection equipment
- Pesticide application equipment
- Pesticide storage areas, including
storage containers
- Cleaning disinfectants and
labels
Typical records an EPA Inspector may ask to review
for FIFRA compliance include:
- Records of pesticides purchased
(purchase orders, inventory)
- Pesticide application records
- Description of the pest control
program
- Certification status of pesticide
applicators
- Pesticide disposal manifests
- Contract files
- Recent ventilation rating for
pesticide fume hood and pesticide mixing/storage areas
Alternatives
The pest management programs at many healthcare facilities
involve applying synthetic organic pesticides on a routine schedule, rather
than in response to specific problems. Such practices almost always result
in excessive and unnecessary pesticide use.
This system is especially unjustifiable when it is used
as a substitute for good housekeeping. Pests appear when there is material
around to attract them. Good housekeeping practices can go a long way toward
making pesticides unnecessary. In any event, pesticide applications, if they
are to be made at all, should be targeted at a specific pest which has reached
a pre-determined threshold problem level.
Veterinary facilities should consider adopting integrated pest management (IPM)
programs. IPM is a systematic and sensible approach to pest control. It takes
advantage of all the available options--non-chemical as well as chemical.
The essence of IPM is an orderly decision-making process that reviews all
pesticide use and then determines how to reduce that use. Wherever possible
non-chemical approaches are employed.
Disposal Requirements
The label of all registered pesticide products, except
those intended solely for household use, must bear explicit instructions
about pesticide disposal. The statements listed below contain the exact wording
that must appear on the label of these products.
- The labels of all products, except household use, must
contain the statement, "Do not contaminate water, food, or feed by
storage or disposal."
- Except those products intended solely for household
use, the labels of all products that contain active ingredients appearing
on the "Acutely Hazardous" Commercial Pesticide Products List
(RCRA E List)
or are assigned to Toxicity Category I on the basis of oral or dermal toxicity,
skin or eye irritation potential, or Toxicity Category I or II on the basis
of acute inhalation toxicity must bear the following pesticide disposal
statement: "Pesticide wastes are acutely hazardous. Improper disposal
of excess pesticide, spray mixture, or rinsate is a violation of Federal
Law. If these wastes cannot be disposed of by use according to label instructions,
contact your State Pesticide or Environmental Control Agency, or the Hazardous
Waste representative at the nearest EPA Regional Office for guidance."
EPA offers the following advice for pesticide disposal:
- The best way to dispose of small amounts of excess pesticides
is to use them - apply them - according to the directions on the label.
If you cannot use them, ask your neighbors whether they have a similar
pest control problem and can use them.
- If all the remaining pesticide cannot be properly used,
check with your local solid waste management authority, environmental agency,
or health department to find out whether your community has a household
hazardous waste collection program or a similar program for getting rid
of unwanted, leftover pesticides. These authorities can also inform you
of any local requirements for pesticide waste disposal. To identify your
local solid waste agency, look in the government section of your phone
book under categories such as solid waste, public works,
or garbage, trash, or refuse collection or you can
call 1-800-CLEANUP.
- State and local laws regarding pesticide disposal
may be stricter than the Federal requirements on the label. Be sure
to check with your state
or local agencies before disposing of your pesticide containers.
- If the container is partly filled, contact your local
solid waste agency.
- If the container is empty, do not reuse it. Place it
in the trash, unless the label specifies a different procedure.
- Do not pour leftover pesticides down the sink,
into the toilet, or down a sewer or street drain. Pesticides may interfere
with the operation of wastewater treatment systems or pollute waterways.
Many municipal systems are not equipped to remove all pesticide residues.
If pesticides reach waterways, they may harm fish, plants, and other living
things.
Universal Waste. Under certain circumstances, pesticides
are covered under Universal Waste rules
(40 CFR
part 273):
- Recalled pesticides that are:
- Stocks of a suspended and canceled pesticide that
are part of a voluntary or mandatory recall under FIFRA Section 19(b),
including, but not limited to those owned by the registrant responsible
for conducting the recall; or
- Stocks of a suspended or canceled pesticide, or a
pesticide that is not in compliance with FIFRA that are part of a voluntary
recall by the registrant.
- Stocks of other unused pesticide products that are collected
and managed as part of a waste pesticide collection program.
The federal universal waste rule establishes two types
of universal waste handlers. The small quantity handler of universal waste
(SQHUW) who accumulates less than 5000 kg of universal waste on site at any
one time and the large quantity handler of universal waste (LQHUW) who accumulates
5,000 kg or more of universal waste.
With regard to disposal, all universal waste handlers can
send their universal waste to either another universal waste handler, a destination
facility which is defined by the regulations to be one who treats, recycles
or disposes of universal waste, or a foreign destination. One, of course,
must comply with all applicable Department of Transportation shipping requirements.
Please note that unlike hazardous waste, you can transport
your universal waste from one handler to another so if you have several hospitals
in an area, you can send your waste to one of the hospitals who would then
send it on to the destination facility. By doing this you may be able to
reduce your shipment costs if there is a discount for bulk deliveries.
Please note that State definitions and regulations relating
to universal wastes may differ. Check the page for your state on the VetCA Universal Waste State Resource Locator for links to more
information.
More Resources
EPA Office of Pesticide Programs, Chemical Search. Enter chemical name or CAS number to find registration and chemical information. Also, provides EPA point of contact. A video tutorial is available.
Controlling Pests without Harmful Pesticides.
Includes a Directory of Least Toxic Service Providers that practices Integrated
Pest Management.
National Pesticides
Information Center - Pest Elimination Guides and Information for a
variety of pests including mosquitoes, flies, cockroaches, lice, fleas,
termites and guidance in selecting a pest control firm.
IPM Standards
for Schools: Tactics and Resources for Reducing Pest and Pesticide Risks
in Schools and Other Sensitive Environments. Presents integrated pest
management (IPM) practice standards for educational facilities to help
schools become certified in providing effective and safe pest control (IPM
Institute of North America, Madison, WI, 2004).
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