March 9, 2012 

MEMORANDUM 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

SUBJECT: Response to Public Comments on the Pesticide Environmental Stewardship Program 

Annual Measures Reporting Information Collection Request 

FROM: 

THRU: 

TO: 

Frank Ellis, Acting Branch Chief ~ 1/ .//. / 

Environmental Stewardship Branch 0~ Vtd/~ Biopesticides and Pollution Prevention Division (7511P) · 

f.vKeith A. Matthews, Director /AI. {YL~ f'rt.C--&-.sf--

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 I PM. 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 

Management 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 should 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 collect and submit information for each 

measure. The Agency expects that t hose companies may elect to adapt their internal record keeping 

systems as necessary and feasible over time to be able 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 would 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 evaluate the IPM adoption and risk reduction being achieved by PESP 

members. In developing this set of measures, EPA began the consultation 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 pilot exercise in January and February of 2010, in 

order to assess the burden placed on members by submitting annual performance reports. During this 

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 collect 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 to 

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 MANAGEMENT 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 educated guess variety, we could measure progress. 

At times problems arise with timely reporting by contractors and our 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 problems (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 they are able. The exception to this is pest management professional companies, which 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 

management (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 I PM. 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, 

while 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 the 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 I PM. 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 practicing 

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 what is 

the standard we are using for I PM? 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 I PM, 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 Protection 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 strategies 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 I PM. 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 I PM. Visiting a site only to monitor and prevent, without 

making a treatment, does. EPA worked closely with the National Pest Management 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 supply 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 Green Pro, 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 Green Pro 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