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Pesticides

 

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 healthcare facilities. Some of the most common include food preparation and waste disposal areas, public areas such as waiting rooms, halls and offices, patient rooms and treatment areas, 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 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 affects.

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 staff 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 an 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.

Healthcare 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.

  1. The labels of all products, except household use, must contain the statement, "Do not contaminate water, food, or feed by storage or disposal."
  2. 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 HERC Universal Waste State Resource Locator for links to more information.

More Resources

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.

Restricted and Canceled Uses. EPA registers pesticides and their use on specific pests and under specific circumstances. For example, "Pesticide A," registered for use on apples, may not be used legally on grapes, or an insecticide registered for "outdoor use" may not legally be used inside a building. In some circumstances, use of a registered pesticide may be restricted to pesticide applicators with special training.

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).

©2015 Healthcare Environmental Resource Center
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