Automated Mosquito Misting Systems Region 6 States SFIREG Issue Paper TX, LA, NM, AR, OK Bonnie Rabe, Bureau Chief New Mexico Department of Agriculture

Region 6 Issue Paper Misting systems utilized historically in agriculture around barns, pens, or other structures on the farm or interior commercial use Now marketed for urban homeowner use Concerns: Installation by companies not previously in pest management Installation by companies not previously in pest management Marketing of systems - ‘Total Protection for Your Family and Loved Ones’, ‘Safe’ Marketing of systems - ‘Total Protection for Your Family and Loved Ones’, ‘Safe’ Homeowner maintenance of systems Homeowner maintenance of systems Lack of specific label directions or precautions Lack of specific label directions or precautions Other uses of ‘Automated’ technology Other uses of ‘Automated’ technology

System Installations Region 6 states seeing heavy marketing for systems - ‘franchise opportunities’ Construction, landscape design maintenance, property management companies – little or no pesticide experience Construction, landscape design maintenance, property management companies – little or no pesticide experience Consumer protection -- the level of oversight of these operators is insufficient to ensure the homeowners are not going to be ripped off or that the systems are being installed and run to protect the environment. Lack of efficacy data concerning the types of nozzles, nozzle spacings etc. that are needed to obtain stated benefits Installation primary focus – maintenance optional service, left to homeowner

Marketing Public Health Protection claims ‘Safe’ Claims contrary to label - how and where can use Varying recommendations Lack of efficacy data that demonstrate that these systems provide a real benefit or the degree to which they truly control mosquitos

‘Fully Automated Systems’

‘We can place the nozzles near your children's favorite places to play.’

‘The system can be directed towards the pool, protecting you and your family’

Exposure Risks ‘Automation’ aspect – unsupervised applications Label states – ‘Do not apply when children or pets are present’ Remote control units allow possible ‘control’ by children ‘playing’ with the system Pesticides sold or provided to the homeowners to ‘maintain’ the system without info on proper mixing, use, disposal, and the potential for harm – may add anything Large quantities of pesticide ‘stored’ in residential site Labels do not specifically address use in systems, including precautions – different risk criteria when misused Liability? Insurance coverage?

Off Site Drift set to automatically spray often when no effect on the pest Spray drift in windy and/or rainy conditions Installed systems spraying around homes under the eaves, around pools, dining patios and play structures without regard for possible consequences on neighboring property Use on property bordering wildlife areas may draw animals as a watering source Birds may utilize the installed lines to perch and utilize nozzles as a water source In NM and other western states, potential for use to be applied to outdoor evaporative cooling, through addition of a pesticide NonTarget Exposure

IP Recommendations Since little authority is available to fully regulate automated misting systems as application equipment, and to provide the most direct solution, EPA should specifically disallow this use in urban environments Labels should specifically address the use and precautionary language of pesticides for automated misting systems in residential (including both single and multifamily dwellings) areas, including schools and daycares Regulatory officials will then have the authority to regulate this use as a label violation This action is also necessary to maintain EPA’s goal of promotion of Integrated Pest Management (IPM) and protection of the environment and public health from pesticide misuse EPA has an opportunity for proactive prevention of harm to human health and the environment through issuance of a PR notice to manufacturers, developed to require label language prohibiting residential uses of pesticides in automated misting systems

Further Uses of ‘Automation’ Lawn chemigation systems In-wall application systems Primary issue of homeowner ‘intervention’ in maintenance of systems and use of pesticides Backwards? – contrary to reduced use, IPM?

Ongoing State Action to Address Disallowing use Policy Statements to address Regulation changes Considered ‘distribution’ to require licensing Considered ‘distribution’ to require licensing ‘The suspension, cancellation, …may be made if the Board ‘The suspension, cancellation, …may be made if the Board finds A person has used methods or pesticides not suitable or safe for the purpose for which they have been employed… Educating consumers Press release Press release Information on website Information on websiteOthers?

Timed applications occur regardless of weather, use of the area etc. Efficacy -- I have seen no data that demonstrate that these systems provide a benefit or the degree to which they control mosquitos. Nor have I seen data concerning the types of nozzles, nozzle spacings etc. that are needed to maximize the benefits. This is just open to all kinds of fraud. Consumer protection -- the level of oversight of these operators is insufficient to ensure the homeowners are not going to be ripped off or that the systems are being installed and run to protect the environment.

Thank You!