ATTACHMENT E: EPA Response to PESP ICR Comments_Posted 3-20-12_EPA-HQ-OPP-2010-0793

UNITED STAT ES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF CHEMICAL SAFETY
AND POLLUTION PREVENTION

March 9, 2012
MEMORANDUM
SUBJECT:

FROM:

THRU:

TO:

Response to Public Comments on the Pesticide Environmental Stewardship Program
Annual Measures Reporting Information Collection Request
Frank Ellis, Acting Branch Chief
~1/.//. /
Environmental Stewardship Branch 0~ Vtd/~
Biopesticides and Pollution Prevention Division (7511P)

·

/AI. {YL~ f'rt.C--&-.sf--

f.vKeith A. Matthews, Director
1\) Biopesticides and Pollution Prevention Division (7511P)
Jay Ellenberger, Acting Director
Field and External Affairs Division (7506P)

EPA is seeking an Information Collection Request (ICR) in order to be able to obtain information on
membership application and Stewardship Strategy development, as well as annual reporting activities,
for use by the Pesticide Environmental Stewardship Program (PESP). EPA announced the opening of a
60 day public comment period on this proposed ICR in the Federal Register on October 27, 2010. This
comment period ended December 27, 2010. Eight PESP member organizations submitted comments.
Approximately one-half of the comments received were in support of the proposed information
collection activities while the other half expressed some concern over the collection of specific
measurement data. The comments led to the revision of some measures in the proposed ICR. EPA's
responses to comments follow.
PEACHTREE PEST CONTROL, INC, Terry Bowen

Company does not currently collect all data EPA is seeking.
Comment: We have just recently completed the Application and Strategy Form for membership in the
PESP program. I feel the information requested is critical to the underlying principles of the PESP
program. There must be a way for members to report data that would reflect their efforts in promoting
the ideals and principles of IPM. However, some of the measurements may not be available for
submission or calculation, as the measurement data may not be kept by a PESP member. The omission
of information should not reflect poorly on the PESP member or their promotion to a higher level of
membership within the PESP program, unless such omission is an indication that the member is not
fulfilling the spirit or basic requirements of the PESP program.

EPA Response: Peachtree Pest Control, Inc. is a company that provides pest management services.
EPA has worked closely with several third-party certification programs, namely the National Pest
Man agement Association's GreenPro, IPM Institute of North America' s Green Shield, and EcoWise
Certified, while developing the measures being sought from pest management professionals. It is EPA's
understanding that companies certified by any one of the aforementioned programs shou ld be able to
report on each of the PESP measures for pest management professionals. For other companies, EPA
understands that some may not initially be in a position to co llect and submit information for each
measure. The Agency expects that t hose compan ies may elect to adapt their internal reco rd keeping
systems as necessary and feasible over time to be ab le to provide the data. EPA encourages PESP
member companies that are committed to practicing IPM to work with EPA to improve upon the ways
of verifying IPM over time.
Suggestion for data that might be more appropriate for EPA to collect.
Comment: There may be other sets of data, other than the set of data requested on the Strategy
Form, that would be less burdensome to report or calculate, while still indicating that IPM is still being
promoted. I am not sure what this data wou ld be, but I base this comment on the time it took for me
to gather the information requested . I would be willing to participate in discussions along the lines of
changing the types of data requested.
EPA Response: EPA assembled measures that speak to the information the Agency would like to have
in order to be able to accurately eva luate the IPM adoption and risk reduction being achieved by PESP
members. In developing this set of measures, EPA began the consu ltation process during a PESP
National Conference in November 2009. During the conference, EPA presented its draft list of
performance measures to the PESP members in attendance and engaged them in an extensive, dayand-a-half dialogue. In addition, EPA conducted a pi lot exercise in January and February of 2010, in
order to assess the burden placed on members by submitting annual performance reports. During th is
pilot, EPA asked ten PESP members to submit annual reports, addressing the new set of performance
measures. Based on the results of the pilot exercise, EPA believes the burden associated with collection
and reporting of the requested data to be reasonable.
In cases where companies do not currently coll ect information on a certain measure, EPA encourages
PESP members to work with the Agency to find the most appropriate way to demonstrate their
progress with regard IPM and other risk reduction practices.
FISCHER ENVIRONMENTAL SERVICES, Robert Kunst
Pest management companies already collect the data EPA is requesting.
Comment: My company is a member of PESP and as such has acquired data for reporting info to the
EPA. The requested forms require very little information that the Pest Control industry does not
already keep track of. So NO extra work is necessary for over 95% of the requested info. In other words
the vast majority of data is already collected. This is done because it is either needed for the
management ofthe business or a Federal or St ate regu latory agency already requires us to do it. The
only items that are new are the need to know how many buildings and how many people. That is info
that our industry does not normally collect. That can be done very easily as our technicians are at the
locale between 4 and 20 times per year now. We would need a slightly modified computer program or
we could use the census averages for that area in calcu lating the number of residents. Either way no
2

big deal. The number of hours needed to do this work is not 35 hours or more as indicated on the
introduction it is more like 4 hours per month and that is a stretch. Once again pest control companies
are already collecting almost all of the data requested NOW. Therefore, just submitting the data t o
another agency is really no trouble at all. Believe me, if this was a large or hard task you would hear me
squalling, but it just is not.
EPA Response: EPA appreciates the comments submitted by Mr. Kunst.

SARASOTA COUNTY MOSQUITO M ANAGEMENT SERVICES, Eric Schreiber
Using best guesses to respond to measures
Comment: We filled out the EPA's Pesticide Environmental Stewardship Program Strategy Form in
Summer/Fall 2010 and found it to be cumbersome at times to use. The proposed measures in this form
surprised us initially but we came up some "real numbers" we could track. We believe that if the
measures proposed remain in a "ballpark" or best educat ed guess variety, we could measure progress.
At times problems arise with timely reporting by contract ors and ou r own operators on amounts
applied.
EPA Response: Where exact numbers are not possible, EPA finds it completely acceptable for PESP
members to use informed estimates.
EPA should distinguish among pest control strategies.
Comment: The lumping of pests control strategies in generalized terms may misrepresent actual usage
trends (especially depending on abiotic and biotic factors out of our immediate control e.g.; treat ment
for bedbugs in libraries, terminate control in historic or new constructions, new medians in new road
constructions). If the measures are reasonable and can be measured in a meaningful way we see this
as a worthwhile and exciting program. We suggest that perhaps we should focus on 10 or so pest
problems and measure chemical control amounts assiduously on these pests. A regional approach may
be best to capture the uniqueness of pest and pest problems (mole crickets, fire ants) in a useful
subdivision along with more cosmopolitan pest problem s (cockroaches, and rat s).
EPA Response: EPA appreciates this comment, and realizes that each PESP member deals with unique
pest management situations and conditions. This has made the act of determining a set of measures
for PESP members challenging at best. In the past, PESP members have not been required to submit
annual reporting information on specific measures, therefore, there was no emphasis on compiling
pest management strategies across members. However, it is a necessity for the program to be able to
aggregate information from among members moving forward . In an effort to reduce the challenge of
doing this, PESP members have been divided into the categories - live, Work, Play, and Farm.
It should be noted that PESP members will not be required to report on each and every measure, only
as many as t hey are able. The exception to this is pest management professional companies, w hich are
expected to report on each of a separate set of measures that has been developed especially for them.

3

WESTERN EXTERMINATOR COMPANY, Keith Willingham
Comparing data across companies
Comment: EPA wants a way to measure progress and to accurately compare companies, but some of
the data they are asking for is open to different interpretations, leaving them comparing apples to
oranges.
EPA Response: EPA is aware of the fact that it can be challenging to compare integrated pest
man agement (IPM) practices across pest management companies. Nonetheless, EPA deems it
necessary to work toward this goal as a way to measure progress in the adoption of I PM. The measures
in this ICR represent a best effort by EPA to develop a set of measures that will inform the Agency of
whether and to what extent a PESP member is practicing IPM. EPA worked closely with three major
professional certification organizations in the development of measures that are specific to pest
management professionals: National Pest Management Association (GreenPro), IPM Institute of North
America (Green Shield), and EcoWise Certified.
EPA understands that some companies may not initially be in a position to collect and submit
information related to each measure, but it is the Agency's expectation that those companies that wish
to remain in good standing as PESP members will adapt their internal record keeping systems as
necessary and feasible over time. EPA encourages PESP member companies that are committed to
practicing IPM to work with EPA to improve upon the ways of verifying IPM over time.
Total Acres Under Management and Total Square Feed Under Management
Comment: Total Acres Under Management and Toto/Square Feet Under Management are not
commonly collected, and with over 100,000 customers, are not practical for us to get. Other
companies will have the same issue of not having this information, leading to guesses on these
numbers. One company will guess at the average size for residential homes as being 2,000 square feet,
w hile another company may use 2,200 square feet, and a third company 1,800 square feet.
Commercial accounts will ev.en be more difficult, due the market average 20,000 or 45,000 square feet.
Total acres will have even more variance. We have over 10,000 apartment/HOA complexes on service.
How will we come up with total acres and will the other companies use a similar approach?
We recommend that EPA allow companies to collect the number of accounts by business type and
then use a conversion factor, or that EPA supplies the conversion factor. Don't ask for a large number
of business types. Keep it simple, about 10 types.
EPA Response: In asking pest management companies to report on the total area, both indoor and
outdoor, being treated under an IPM program, EPA's intention was to be able to determine trends in
IPM adoption over time . We have been informed that the majority of pest management companies do
not collect these data because it is not critical to their business models. The Agency would, therefore,
like the reporting of these area data to be optional. Those companies that have the data could provide
it as an important measure of the area IPM impacts but those companies without the data would not
be required to collect or report on it. EPA encourages PESP member companies that are committed to
practicing IPM to work with EPA to improve upon t he ways of verifying IPM over time.

4

Total Number of People in Accounts Under Management
Comment: Total Number People in Accounts Under Management will vary with the company's "guess"
as to how many people will be found at an account. If company A services 100 schools and assumes
500 people per school, company A impacts 50,000 people. Company B with its 100 schools includes
student parents and siblings, so assumes 2,000 people per school. Their number of people impacted is
200,000. Whatever number of people I assume per account type is a guess and cannot be compared to
any other company.
We recommend that EPA collect the number of accounts by business type and use or supply a
conversion factor to come up with the number of people.

EPA Response: In asking pest management companies to report on the total number of people in their
accounts that are being managed under IPM, EPA's intention is to be able to determine trends in IPM
adoption over time. Because of the positive health impacts associated with occupying buildings
managed under IPM versus a traditional routine spraying schedule, it is important for EPA to have a
sense of the number of people occupying buildings managed under IPM. EPA understands that some
companies may not be in a position to collect and submit information related to each measure, such as
the number of people in accounts under management. It is the Agency's expectation that those
companies and organizations that have these data will elect to report on it. The Agency will make
reporting on this optional. EPA encourages PESP member companies that are committed to pract icing
IPM to work with EPA to improve upon the ways of verifying IPM over time. EPA agrees with the
commentor and will collect the total number of accounts for each pest management member
company.
Defining IPM
Comment: Until EPA endorses a particular definition of I PM, it's going to be impossible to compare
responses from different companies. EPA wants to know number of accounts "under IPM" , but w hat is
the standard we are using for IPM? For example, we visit thousands of homes each month. The
technician calls each customer asking about any pest concerns (in a sense checking a monitor), when
he/she arrives at the account and the customer is home they ask once more about any concerns. Next
using a Webster the tech removes webs and spiders from under first story eaves and while walking the
property looks for pests and for conditions that could support pests. Any conducive conditions found
are reported on paperwork left with the customer and verbally if t he customer is home or in a post
service phone call left on the customer's answering machine. The technician may treat for a pest
found, make a preventive treatment, or make no treatment. Information about what the customer can
do (fix vent, cut tree back) was given to the customer; does this mean the account was serviced under
IPM? We also have over 3,000 schools, food plants, and food warehouses where, except for rodent
bait, it's rare a preventive treatment is made. Are these accounts " under IPM"?
We recommend that instead of the generic IPM, EPA should ask for accounts, by business type,
serviced under Green Pro, Green Shield, or EcoWise programs. Each of these programs has a built in
audit program and the service specifications are very clear.

EPA Response: The Food Quality Prot ection Act defines Integrated Pest Management as, 11 3
sustainable approach to managing pests by combining biological, cultural, physical, and chemical tools
in a way that minimizes economic, health, and environmental risks. " IPM relies on a combination of
5

common-sense practices and science-based st rategies for managing pests in an effective and
environmentally sensitive manner. IPM is not a one size fits all approach to pest management.
Therefore, EPA does not propose that there is any one set of practices that PESP members should
employ when practicing IPM. However, any and every IPM plan should be based on the following
principles: 1) set action thresholds, 2) monitor and identify pests, 3) prevent pest conducive
conditions, and 4) control- taking intervention actions that may include t he use of pesticides.
It is EPA's expectatic:m that PESP members employ all four of these tactics at any given site in order to
be able to claim that the area is being managed under IPM. Using rodent or cockroach baits at a food
processing facility does not by itself constitute IPM. Visiting a site only to monitor and prevent, without
making a treatment, does. EPA worked closely with the National Pest M anagement Association (Green
Pro), IPM Institute of North America (Green Shield), and EcoWise Certified in developing the set of
measures specific to pest management professionals. Therefore, if a pest management professional
practices IPM to the extent that they can pass the auditing requirements of any of those three
certification programs, then that pest management professional can certainly report on all of the PESP
measures.
Total Preventive Treatments
Comment: This comment is in regard to the measure Total Preventive Treatments. Suppose our
technician finds a trail of ants and treats it with a pesticide, and at the same time he/she is putting
down a residual for other ants that will/may come into the area. In a broad view this is a preventive
treatment. Is this the same definition the other companies are using? Does preventive treatments
include a treatment made when no pest is present and is made only to stop a future pest? Is putting
rodent bait in a bait station a preventive treatment? If bait is placed in 20 stations at one account, was
one or 20 preventive treatments made? Every company must have the same protocol or you cannot
compare the numbers.
Another issue is how would you collect this information? Unless you have a system for the service
person to say this is a preventive treatment, you would have no way to collect this information. This
would need to be set up in advance and all the service personnel would need to be trained and all the
companies would need to be using same protocol, and most (all?) companies would need to change
forms or other reporting methods. This can get very expensive and would take time to implement. We
recommend that EPA drop this measure.
EPA Response: EPA appreciates this comment. In the context of I PM, EPA considers "prevention" to
mean removing conditions that are conducive to pests. Prevention includes taking steps to ensure that
pest populations cannot increase to unacceptable levels. In an agricultural setting, prevention might
mean rotating between different crops, planting pest-free rootstock, or regularly aerating soils. In a
non-agricultural setting, prevention might mean reducing clutter, avoiding standing water, or sealing
gaps in the exterior of a building. (See EPA's IPM Fact Sheet at
http://www.epa.gov/pestwise/htmlpublications/ipm fact sheet.html.) EPA does not consider applying
a pesticide today to combat pests that might appear tomorrow an IPM practice.

6

The commenter raises a good point, however, which is that the phrasing of this particular measure is
misleading. In response, EPA has removed the Total Preventative Treatments measure. The subsequent
measure was modified to request Total Non-Chemical Treatments ONLY to capture information on the
prevention of pest conducive conditions .
Total Number of Spot Treatments
Comment: This comment is in regard to the measure Total Number of Spot Treatments. There is no
way to collect this data unless you set up a system for the service person to indicate the treatment was
a spot treatment. This means changing forms and programs. What if he/she makes two spot
treatments, do you also need to collect number of spots? This will be expensive and time consuming.
Therefore, we recommend that EPA drop this measure.
EPA Response: In response to this comment, EPA will modify the information being requested and

change the question from the Total Number of Spot Treatments to a yes/no question that asks whether
the member is utilizing spot treatments for pests as opposed to large area applications.
Total Pounds AI Applied in Interior and Exterior Spaces
Comment: This comment is in regard to the measure Total Pounds AI Applied in Interior Space and
Total Pounds AI Applied on Exterior Grounds. How many companies are going to know how to convert
gallons of liquids to pounds? Will every company report the totals of all the actives on the labels?
Many products containing Pyrethrins, also contain Piperonyl Butoxide and N-Octyl bicycloheptene
dicarboximide. Will all companies report all the actives or just the " main" active, Pyrethrin? Amounts
reported by the technicians will often have small errors, for example 2 ounces, when it should have
been 2.1 ounces. Amounts reported for a few services are not an issue, but times 100,000 plus services
over a year, the error grows.
A more accurate approach is to take all the purchases made over the year and convert this to pounds
active. Supply companies with an excel spreadsheet they can use to input pounds/gallons of products
purchased or have the numbers sent to EPA for inputting. A disadvantage of this approach is that you
lose the ability to distinguish between amount applied inside verses outside, but a work around would
be for the company to supp ly a percentage of products applied, taken from service slips, of in versus
out.
EPA Response: EPA appreciates this comment. It is probable that not all companies will know how to
convert pesticide product measures into pounds of active ingredient (AI) and that calculation errors
will occur. In response, EPA has simplified the pesticide reporting measure so members need only
report details on actual pesticide applied (or purchased ) by EPA registration number. EPA will be
responsible for all conversions and calculations related to this measure.

Total People Reached by Educational Materials
Comment: This comment is in regard to the measure Total People Reached by IPM/PESP Educational
Materials. This number will vary with the company' s "guess" as to how many people will be found at
an account. I send a flier to each resident we have on service; do I multiply by 1 per home, or 2.3 per
home, and will the other companies use the same number? Back to the same example used in the
discussion of total people in accounts, if company A puts out IPM/ PESP educational materials at 100
schools and assumes 500 people per school, company A impacts 50,000 people. Company B with its
7

100 schools includes student parents and siblings, so assumes 2,000 people per school. There the
number of people reached is 200,000. Whatever number of people I assume per account type is a
guess and cannot be compared to any other company.
For information on a company website, is the number of people based on counts of views or on
number of downloads?
We recommend that EPA collect data on educational materials sent/taken to accounts based on
business type. If two educational fliers were given to 2000 homes, this would be reported as 4000
educational opportunities. Also have the educational materials reported as a ratio of the accounts, by
business type. 4000 educational fliers were given to 2000 homes, but 3000 homes are on service, the
ratio would be 1.33. Also have the data reported for website materials be based on number of
downloads of materials.

EPA Response: EPA agrees with the commenter on the fact that this measure is broad, and
appreciates the recommendations given. Therefore, EPA will remove the measure, Total People
Reached by IPM/PESP Educational Materials, but retain a measure to capture the Total Number of
People Reached by /PM Training/Educational Events.
Suggestions for additional measures
Comment: Here are some suggestions for other data points EPA could collect :
Reducing Pounds of Pyrethroids Used - Based on each year's purchases of products, determine the
reduction of total pounds of Pyrethriods as a percentage of all actives. EPA would supply an Excel
spreadsheet for companies to input pounds or gallons of materials purchased or send the data to the
EPA for inputting.
The Revenue from GreenPro, EcoWise, or Green Shield Certified Accounts - Each of these programs has
a built in audit program and the service specifications are very c;:lear. This data should be collected as a
ratio of total pest revenue.
The Number of GreenPro, EcoWise, or Green Shield Certified Accounts- Each of these programs has a
built in audit program and the service specifications are very clear. This data should be collected as a
ratio of total accounts or better yet by total accounts within business types.
The Number of Monitors Purchased - The word monitors would need to be clearly defined, for example
would rodent bait stations be counted as a monitor? Ask for numbers, by type of monitor, and to
standardize the data for comparison across companies, have the data reported as a ratio of total
number of services made.
Percentage of Employees GreenPro Certified- Ask for the percentage of total employee that have taken
and passed the NPMA GreenPro exam.

EPA Response: While EPA appreciates the suggestions for additional data points made by this
commenter, these data points are not the most appropriate for the federal government to collect. EPA
is interested in information on how IPM is being practiced by all pest management professionals, not
8

only those who are certified under Green Pro, Green Shield, or EcoWise. With regard the suggested
measure on use of pyrethroids, PESP is not attempting to measure reductions in the use of any
particular pesticidal active ingredient at this time.

9