Sept. 10, 2004
From: David Patriquin, Biology Dept., Dalhousie University
To: PMRA OFFICIAL, PMRA
Re: Further clarification on the use of soap
Dear PMRA OFFICIAL,
Thank you for your communication of Sept. 9 replying to my query about the legality individuals asking lawncare companies to assist them with using household soap to control chinch bug, I can understand and appreciate your comments cf other factors determining the ability of companies to respond to a request to use household soap.
However the statement you made following that, viz,
Some suggested wording to address this issue could therefore be:
"...you may want to request some assistance from friends, neighbours or
family members to use the dish soap flannel trap method...."
left me wondering whether I have fully understood your earlier response (Aug. 27) to my queries about the use of household soap.
The context in which the use of household soap was discussed in the CBC interviews with myself and yourself on Aug 20 was in regard to use of soap as an alternative to diazinon and sevin (which are registered for use on chinch bug, but are not permitted under the Pesticide By-law) and to insecticidal soap (which is permitted under the Pesticide By-law, but is not registered with the PMRA for use on chinch bug). In the first interview, (with myself) I stated that the PMRA does not allow use of insecticidal soap or even household soap to control chinch bug while it does allow use of diazinon and sevin, basing my comment on my earlier communications with the PMRA on this matter. In the subsequent interview with you, the interviewer asked why the PMRA does not permit use of household soap to control chinch bug, and you stated that was not true, that individuals may use household soap to control chinch bug. As you paraphrased it in your communication of Aug. 27:
.. lawncare companies cannot use dish soap as this would become a product/service rendered making a pesticidal claim, thus subject to the PCPA but individuals may use dish soap on their properties as this is not a method that requires registration under the PCPA.
There was no mention in those interviews of physical controls or traps, and my questions were not about use of soap as an irritant in conjunction with trapping and physical removal of the bugs, but rather about use of household soap as an alternative to pesticidal soap.
When I wrote to the PMRA on Aug 20, I was requesting clarification of the position of the PMRA position on use of household soap because the statements in the CBC interviews of Aug 20 were inconsistent with what I had been told on April 30. I did point out at the end of that communication that another point of confusion was
your listing of the 'soap and flannel trap method' as a 'Physical Control' for Chinch Bug, while at the same time, apparently, stating that household soap cannot legally be used to control chinch bug
In your reply (Aug 27), you included mention of 'physical control' when you stated that it is OK for individuals to use soap to control chinch bug, and in this last communication (Sep. 9) you seemed to have made a point of referring more specifically to the 'soap and flannel trap method'. This leads me to wonder whether I have misunderstood the PMRA position, as stated in your communication of Aug. 27. I suspect I have, but I have had no feedback from you about the revisions I made to the Control of Chinch Bugs Without Pesticides website which I informed you about on Aug 30, and which I assume the PMRA has examined. (However, I did not request a formal review of the revisions, as I had following revisions made as a result of communications with the PMRA in late April/early May.)
I am grateful if you could provide answers to each of the following questions.
1. Are methods that do not require registration under the PCPA listed somewhere in PMRA documents available via the web? [cf the paraphrasing above; how do we (the public) know which methods of pest control do not require registration under the PCPA?]
2. How do you define 'physical control'? Is this definition and are definitions of other terms related to classification of pest control agents available in a PMRA document available via the web?
3. Is use of insecticidal soap according to manufacturers' instructions (e.g., as a 2% solution, applied weekly for 2-3 weeks and thereafter as required) considered to be a 'physical control'?
4. Would application of dish soap (which I have been referring to as household soap) at 2% concentration to a patch of lawn affected by chinch bug be considered a 'physical control'?
5. On April 30, in response to a request to clarify whether or not individuals can use household soap to control chinch bug, I asked
Q3 . Is it permissible for an individual resident to use ordinary soap at approx. 2% concentration to control chinch bugs in lawns?
The PMRA responded as follows:
Q4. Is it permissible for a lawncare company to use ordinary soap at approx. 2% concentration to control chinch bugs in lawns?
"For questions #3, 4, Ordinary Soap
Is your statement of Aug. 27
Ordinary soap is not considered to be a pesticide. It is considered basically for monitoring purpose. This product is not registered under the Pest Control Product Act and therefore it is illegal to use it to control the chinch bug."
The bottom line, can environmental organizations encourage individuals to use dish soap as an alternative method of physical control for chinch bugs? Yes
at variance with the April 30 statement? or
6. Is it the PMRA position that it is OK to use soap as a 'physical control' (irritant'), but not as a killing agent/direct substitute for insecticidal soap?
Finally I request that the PMRA review the following pages on the Control of Chinch Bugs Without Pesticides website, and tell me whether you would like any statements changed in order for the PMRA regulations to be accurately represented (in summary form) on these pages.
I am grateful for this further clarification. I hope you understand that this somewhat protracted process is not being made to cause you difficulties or embarrassment, but rather to understand clearly and report correctly on the PMRA regulations as they relate to use of 'alternatives to pesticides' such as soap.
- David Patriquin