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Case 1:05-cv-01020-MMS

Document 39-26

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III.

INTEGRATED PEST MANAGEMENT IN TERMITE CONTROL

A.

Overview

An integrated pest management approach for termite protection
begins with the design of structures, and continues through site
preparation and construction to maintenance, moisture control,
environmental modification, inspection, and judicious chemical

treatment-

The most promising Innovation in termite control appears to

be the bait-block method of insecticide delivery, which can be used with
conventional toxicants, insect growth regulators, antibiotics and other
control agents*

Use of resistant wood in construction or the treatment

of wood with repellents or antifeedants is another alternative to be

incorporated into future programs.

Integrated termite control has several characteristics ^Alich affect
the choice of strategies to be employed in an IPM
program*

First, there

is considerable opportunity to employ physical design, redesign, and

modification as major elements in preventing termite infestation.

This

applies to the structure being protected as well as the surrounding
environment*

Second, because termite damage is slow to occur and

accumulate, time is available to the decision maker to consider options
carefully before taking action. Third, the high value of the structure

being protected relative to almost any control option may allow greater
flexibility in choosing among options.

A constraint on the

implementation of an IPM approach for termites lies in the generally low

7?

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Note that in both XVIII and XIX, the horizontal lines under
requirement categories Indicate that this Information was not available,

It does not necessarily Imply that such regulations do

not exist*

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Provisions for supervision of non-certified individuals applying
pesticides in all states conform almost entirely to EPA guidelines, in
that the availability of the certified applicator must be directly related to the hazard of the situation.

Special requirements for certification of structural pesticide

applicators, where they exist, are enforced by state structural pest
control commissions.

They tend to be uore stringent than those imposed

on PCO's by state agricultural departments.

However, only about 18

states have specific certification regulations for structural-pesticide

applicators.
XIX.

These regulations are presented in summary form in Table

The certification requirements for structural pesticide applicators
are to a large extent similar to those covered in Table XVIII.

The main

difference is that where states have specific requirements for

structural-pesticide application, they have established separate
structural pesticide commissions to regulate the certification procedure for this industry.

One of the major differences between the state regulations relating
to the

general applicator and the structural applicator is that for the

latter, allowable pesticides, specifically termiticides, are frequently
specified in the regulations.
pesticides may be used.

In all cases, only state registered

The other major difference is that specific These may include

contractual arrangements may be required by state law.

terms calling for identification of infecting organism, inspection before

and after treatment, a warranty agreement and in some
minimum treatment requirements.

cases, specified

Treatment requirements refer to the

physical aspects of treatment or the what, where and how treatment should
Cake place.

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The headings for Table XVIII were selected because these topics

appeared most often in individual state laws and afforded the best means
of comparing state certification requirements. The certification

classifications are designated as either "private" or "commercial" in
almost every state.
The permissable activities category is primarily a

description of the type of activities allowed under the previously
mentioned certification classification.

Almost every state charges some type of certification fee.

These

fees vary a good deal from state to state.

The variation seems to, in

part, depend on whether fees are required for licenses, registration,

equipment inspection or examinations.

As far as can be determined, every

state requires commercial certified applicators to maintain or prove some

type of financial responsibility.

This may include either liability

insurance, surety bonding or both.

Many states maintain reciprocal agreements with neighboring states
which allow certified applicators from other states, with similar

requirements, to apply pesticides within the borders of the states party
to the agreement.

These agreements generally specify some sort of

registration requirement, but other certification requirements are

foregone.
Pesticide use reporting records vary widely from one state to

another.

Some states require the submission of all pesticide-use records

to the state agricultural commissioner, while others merely require the
maintenance of application records

by the certified applicator for

a

specified period of time. Categories of certification vary somewhat from state to state,

however, most follow the category listing

in the EPA guidelines.

The

ERA rules and regulations list 10 major categories allowing states to
determine applicable sub-categories.

7o

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E.

RELEVANT STATE REGULATIONS

In order to promote safe, responsible pesticide use, the United
States Environmental Protection Agency has issued rules and regulations
governing state certification of pesticide applicators*

These

specifications for certification of pesticide applicators are provided
for in Section 4 of the Federal Insecticide, Fungicide. Rodenticide Act

(FIFRA), and are intended
certification programs.

to set minimum standards for state

It should be noted that these rules and

regulations reflect the best judgement of the Agency regarding the

elements necessary for a well rounded, state administered certification

program.

If states submit a plan lacking an element or elements which

the Agency feels should have been included, that state must satisfy the

Agency that the missing element, or elements, are not necessary for an
effective applicator certification program in that particular state.

State certification plans must be approved by the Administrator o.f EPA.
The EPA rules and regulations for certification of pesticide applicators

appear in Appendix C.
Typically, the individual state agricultural departments are responsible for certification of pesticide applicators.
The requirements

for certification are embodied in state laws, which were enacted to

comply with EPA rules and regulations.

A summary of Individual state

requirements for certification of pesticide applicators is presented In
Table XVIII.

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Table XVII.

Average Renewal Fees for Service Guarantees, 1980.
Renewal Pricing

Total Treating
Price

Service

G-uarantee Avg. Annual Fee

($)
200 250 300 350

($)
36 39

42

-44
46 49 51

400
450 500

Source:

Orkin, Terminix, and Western, 1981.

^

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PLATE XVI.

Specimen Guarantee Requirements.

SUBTERRANEAN TERMITE GUARANTY QUALIFICATIONS
A structure having any of the following conditions cannot qualify for ANY Terminix guarantee. THESE CONDITIONS MUST BE CORRECTED BEFORE ANY GUARANTEE iS ISSUED.
1. Inadequate clearance 2. Excessive moisture

D
Q Q Q

3. Cellutose^iebn&orstored'materials 4. Structural deficiencies

5. Excessive existing termite damage 6. VA>od in contact with soil 7. Inaccessible areas

Q Q Q

T

!F ANY OF THE FOLLOWING CONDITIONS EXIST A STRUCTURE CANNOT QUAUFY FOR A DAMAGE PROTECTION GUARANTEE.

1. Substructure wood heavily damaged 2. Finished basement below grade 3. Finished basement without access

Q Q Q

4. Excessive moisture or fungus 5. Slabs with radiant heat

D D

S^Other________--^----D

This job qualifies for the following:

PROTECTION 0
Source:
Terminix International, Inc.

SERVICE Q

NONE D

(Hromada, pers. comm.,-1981)

W

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PIATE XV.

GUIprLrNZS- FOR rSTTMATOTG TIME IN

TERMITE CONTROL
100 ft/hr
75 ft/hr
30 ft/hr 30 ft/hr 20 ft/hr

Soil Treatment

Outside

Soil Treatment Outside Rubble Walls

Concrete or Asphalt
Short Rodding

Long Rodding
NOTE::
We can longrod more than 20 ft/hr, but a factor is built in to compensate for jobs' where obstructions force'us to do vertical drilling*

Crawl Space Crawl Space

Concrete
Soil

30 ft/hr

75 ft/hr
15 ft/hr

Tile, Linoleum, etc. on Concrete

NOTE:
Radiant Heat

Except Radiant Heat
Vertical Drilling
10 ft/hr
15 ft/hr

Carpet Glued to Concrete
Wood Over Concrete-

15 ft/hr

Checkerboarding Wood Floor
Perimeter should always be treated 18"
/

O.C.*

15 ft/hr

Checkerboarding is in addition to perimeter lOOsqft/hr
Block Walls Rubble Walls
30 ft/hr

15 ft/hr

Source:

Western Termite and Pest Control (Nelson, pers. comm., :L981),

^7

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Case 1:05-cv-01020-MMS Document PLATE XIV. Specimen Pricing Schedule,
Conventional/Crawl Construction
No

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Slab and Basement Construction
Suo-SliB Soi Tnilinini

Lint ll Ftl

Onll and Short RQO

VtrtlMlDrill

Fgundniofl ind Outiiflt Soil TroinrM

NM
SUB
ind

JUfeted

On*
Void

nr
30
40

Void

Two Men Void!

Holla*

Hollow Sloct

Bloc*

me
Brick Vtnft

Can end
tal"

Bin

Till

Floor

Hirdwood

CflBtW

Hoitow

Hollow Bloex
Brick Vtnor

SUB-

Concnit

Shoe Mold

FiMfiCinMI

Stoni

Bloa

32
53

35

69 78

62 77
98

55 64

21

56

47
74

50 60 70 80
90

95
107 125
143 156

118 134 158 177 195

81 106 128

98
114

66 84 100

146
161 202 224 244 266

141

123 157
183 207 229 251

31 63 94 124 157

21
41

30
56 81 97 118
136

57
81 98 113 133 150

186
215

161 190

213
231 252 264

242 276
304 322 349

172
188 207 215 229

100
110

174
186 207

120 130
140

216
238 246 263

210 229 251 268 282
301 317

262
278 295

157 177 200 220 242
254 264

45 77 107 134 16S 19S 228 254

13 17 19 23 26 28 29 32

13 28

39
48 57 70
81

14 26 39 47 56 74 84

21
44

IS 32
48

63
85 108

61 75
81 89 98 103

127
146 164 190

283
311 348
361

34
37
41 44

91 100

110
119 129'

97 110 117
128 141 149

210
231 253

112
118

287
301 341 348 364 382

278 293
306

307
319

370 394
414

237
251 257

279
290 305

150 160

170
180
190

279
289 306
311 333

333

317 334
347 360 371 365 397
413

334
349

349
363 380

403
418

361
372 386 397

200 210 220 230 240 250

437
457 460 499 518 542

342 363
374

399 418
433 449 466

413
425

260270
280
290

392 -411

424 433

433
450

437 455 477 497 518 542 561 581 600 621

376 397 413 430

46

134
143 147 157 171 178 189 198 208

52 53 57
58 62

164
177

276 293
316 325

125 133
143
147

266
278 287 299 307 319

322
337 349 364

455
477 488 515 532 551 567 562 597 606" :." 626 641 656 669

188 196

336
348 355 367

156 161

63
67 66

207 216
226

167
176 178 190 195

376
389 400 409

325
336 348

70 74 77

300

424 439 4S2 462

ASTSOS
524
537

-'561
582

""440454 466 473 484

-"-

463--477
493 501

'.-641
667 686 705

355
361 370 378 385

422 --428440 450 464 471

:

78 81

"-"

'596
617

83
85 87 91

218 226 231 240 24ff 254 262
268

237 242
251 256 2B4

376 386
397 407 422

205 210
220

27T 278
287 293 301

430 437
446 462
468

"226-"-234

240
249 254

551

629

510

726

276

Charges
?orcf./Void

Renewal Pricing
Powder Post Beetles

Customer Investment
Termite

Total
Treating Price

Termita

Powder Post Beetles
With

H/B
Kft

s

4&5n

w/Termite work Minimum
w/o

25e so. ft.

PRO SER
33
34 34 35 36 30

Without

Termite
20 20 20 20 20 20 21 21 21 21 22 22 22 22 23 23 23

Termite Treating Price
Pnrnh/Vniri

$

^
S19.30 ft.

Termite work

Minimum

32esq. ft.
4lesq.ft.

Stone/concrete
#tt

Heavy Infestation
Minimum

S

S200 210 220 230 240 250
260 270

31 31
32

32
33 33 34 35 35 37 37 38 38 39 39 40
41 41

36
37

33 34 34 35 36 36

S

Cutting Plumbing

AOCRSS
Total Termite

S
Treating S
S
S
S
$

OouoleBlocK or BncK
#ft

s
S

37
37
38

S^Sft.

^ Treating Toiat
^
Auto-Vents
w/Termite work

Ft

37
38

280 290
300 310

38
39 39
40

38 39 39
40 40
41

Vapn-Chek
PowdRr Po<;t BsetiR
Fxr.p.^ivp

Cutting Plumbing Access

320
330
S49 ea.

Sheeirock Wooo ^.n

S^-SO S48.50
S56.40 S72.60
Vapo-Check

40
41

New Openings

To

Ceram'c Tile

Replace w/o Termite work

539'ea: 563ea. S53 ea^

340 350 360
370 380 390 400 410 420
430 440

Op^riR

41

41

42
43

42
43

New Ooenmgs

23
23 23 24 24 25
26

RnnrRuppnrt?
Autn-Vfint
Tay nr Stats Fftfi

To Replace
events.
w/Termite worit

43 44
44

43
44 44

42
43
44 44

S S S
%

Minimum
w/o

ftm s^ H
17..,-

Trtfal

<
Floor Supports

45 45
46 47 47 48

45
45

Termite work

Minimum

25esQ.ft.

w/Termite work
Minimum
w/o

45 46

S66 ea. S76 ea.

450
460

46
47

RfW
Toial Treating

Termite work

Minimum

470
480

^Fioo'-^i^port-;
Tntflf S
ana/or

490
500

48 49 49 50

47 48 48 49

26 27 27 28 29 29 30
RO/-

46 47 47
48

Tnlaf Inveiitment

Renewals
Tprmitp

48
49

PPR
Total
Rpni?waf

S S

49
50
in<^

s

Hunr t;nn iimo'-iino/-

Anacnea Slab >s a oorcn. carDon. garage,

sidewalk.

Som'ce:

Tp1-

i'^i"

Tn-tp-rr-ti'on^l

T-

c.

(Hromada, pers.

con

1981).

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Plate XIV.

Wages, equipment, vehicles, chemicals, other direct costs. In

addition to overhead and profit margins are factored into the dollar

charge per lineal foot presented in the schedule.
lineal feet into a time factor (Plate

Some companies convert
to th& pricing

XV) before referring

schedule, the others have already accounted for this
schedule.

conversion in their

Almost all termite control contracts include a one-year service and (future) damage repair quarantee along with the treatment.

Guarantees depend on the initial damage, the configuration of the;
structure, and the treatment procedures that the

firm^

has employed.

In

order to qualify for guarantees, a structure must meet certain criteria

e.g. no excessive moisture, inaccessible areas, structural

deficiencies, etc. (Plate XVI).

At the end of one year, the customers can

continue the service guarantee or the service and damage repair guarantee

for a set fee.

The damage repair guarantee cannot be continued if the The set fee is related to initial charge for

service guarantee is not.
treatment.

For example, if the initial total treating price is $250.00,

the average annual renewal fee for the retreatment (service) guarantee is

$39.00.

Table XVII below, shows total treatment prices and corresponding

average renewal fees for service quarantees.
available for damage repair quarantees-

Similar data is not

4S'

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D.

Pricing of Termite Control Services and Customer Expenditure

The consumer normally pays a single fee for post-construction
treatment of a structure.

The inspection, proposal for work, treatment

of the structure and a one year guarantee are all covered by thi fee.

If a professional opinion and written report are required for a real
estate transaction, a separate charge is assessed.

Where a treatment

is subsequently purchased for the real estate as a result of such a

report, the cost of the report is usually substracted from the cost of
treatment.

The fee charged for treatment is based primarily on the amount of
time (labor) required to do the

treatment,.3/

The amount of time

required to perform a termite treatment is a function of both the mode of
application (e.g. trenching requires less labor/time than rodding) and

the area (lineal feet) to be treated.
is determined

The mode of application, in turn,

by the type of structure (e.g. slab, crawl space, etc.).

To simplify computation of the treatment charge, most termite control
companies use a pricing schedule like the one presented in

i/

This is consistent with the fact that labor constitutes the largest cost to the firm (see Section C).

W

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variable costs; however, it accounts for only 6 or 7 percent of total

revenue.

Thus,

a

pest control firms' profits are far more (more than

twice) sensitive to increases in labor costs than they are to Increases
in chemical costs*

This fact should be kept in mind when considering
a structure*

regulatory changes which affect the time required to treat

It should be noted, that the cost structure of the three firms are
quite similar, in spite of the fact that they differ in several ways.

For instance Western operates only in the Mid-Atlantic Region (Md,

N.J., Wash., D.C, Va., Del., Pa.), whereas
nationwide.
Termite

Orkin and, Terminix operate

pre-treatments represent a small percentage of total

termite-control related revenue for all three firms.

However,

this

precentage is far larger for Terminix, than for either Orkin or Western.
Since the pre-treatment market is distinct from the remedial treatment

market, involving an entirely different type of consumer and a different
mix of services, one would expect these differences to be reflected in

the cost structure of the three firms*

^2

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>le XIII* Variable or "Direct" Costs of Termite Control Industry as a Percentage of Total Termite Control Revenue.

Expressed

Item
Labor (wages)
Chemical

Z of Total Revenue
15-20

a/

6-7
2-5 7-13
1-3

Equipment (pumping units, hoses)
Vehicles (includes maintenance)

Damage

Claims

Other (miscellaneous expenses uniforms, insurance, taxes)

10-20

a/

Based on chemical prices prior to the 60 percent increase in the price of chlordane in the fall of 1980.
Orkin Pest Control, Terminix International and Pest Control.

Source;

Inc., and Western

Termite

4-i-

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C.

The Cost Structure of The Termite Control Industry

The costs Incurred by a. firm are conventionally discussed in
terms of variable or direct

costs, and fixed or overhead costs.

The

former category consists of those expenses which vary with the volume of business the firm does, whereas the latter category consists of

expense items which are invariant with business volume.

Chemical

costs fall within the variable or direct cost category, and it is on

this category of costs that we shall focus.

A breakdown of variable costs for the termite control industry is
presented in Table XIII*
This breakdown of costs is based on data

provided by Orkin Pest Control, Terminix International,
Western Termite

Inc.,

ami

Controll/.

These three firms represent a

sul^tantial share (25
control market.

30 percent) of the professional termite

The largest component of variable costs is labor costs (i.e..,

applicator wages), this constitutes 15
related

20 percent of total termite

revenue.^./

The next largest component is vehicle related
termite

expenses (including maintenance), comprising 7-13 percent of
revenue.

The cost of chemicals is the third largest component of

Parenthetically, all labor related expenses variable and fixed, amount to 50-60 percent of these firms' termite revenue. A/ Based on chemical prices prior to the 60 percent increase in the price of chlordane in the fall of 1980.

3/

U-[

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There are currently two chlorpyrifos formulations registered with

EPA for subsurface termite control. Dow Termiticide Concentrate, a 44.4

percent emulsifiable concentrate, but this is no longer being so3,dDursban TC, a 42,0 percent emulsifiable concentrate is the product

.recently introduced into the market.

Two gallons of concentrate are

mixed with 100 gallons of water to yield a 1.0 percent use strength emulsion.

o

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snails).

Several penta labels indicate that the products can be used for

soil application to control termites.

However,

pest control operators

report no use of penta for this type of application.

Penta use, as

a

termiticide, is limited to specific termite control problems, e.g. where
termites have been associated with decay, or for direct application to infested wood structures that can not conveniently be replaced (refer to

Appendix B for label summaries).

vii.

Chlorpyrifos

Chlorpyrifos is a product of Dow Chemical Company.
marketed under two trade names:
Dursban(R) and Lorsban(R).

It is

As Dursban(R),

Chlorpyrifos is used for control of fire ants, turf and ornamental plant

insects, mosquitoes, cockroaches and other household insects, stored
products insects, as well as termites and lice, homflies and other pests
on cattle.

The product Lorsban(R) is used primarily in agriculture as a

soil insecticide, seed

treatment, and for dormant

rnj

folier

applications.

Dow obtained a state local need registration (24-C) in late 1979
for Chlorpyrifos to be used as a subsurface termite control.

This

registration was limited to California and no product was sold until
mid-1980.

By the end of 1980, only a few thousand pounds of Chlorpyrifos
The

(a-i.) were sold for this particular use (Speer, pers. comm. 1981).

Dow product was granted a conditional registration as a termiticide by
SPA in August of 1980, but it has only recently appeared in the market-

Consequently, no quantity data is available on its use as

a termiticide

with the exception of the few thousand pounds sold in California during
the last half of 1980.

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^&

slightly, but not as much as was anticipated.

Usage was estimated

to be

about 1.0 million pounds in 1975-76 and is believed to have remained
constant for the last 5 years-

Very little lindane has been used for termite control, its major
uses being seed treatment and the control of various wood inhabiting

beetles.
that

Based on a 1977 survey conducted by Hooker, it was estimated
lindane were distributed for termite control

11,000-12,000 pounds of

in 1976

This usage level appears to have remained constant over the

last 5 years.

Very few pest control operators indentify lindane as a

preferred termite control agent.

Its use appears to be limited to

a few

independent pest control firms located in southern California.

Most of

the lindane used for termite control is believed to be applied as a

surface spray rather than by injection or trenching.

vi

Pentachlorophenol

Pentachlorophenol producers in the United States have a capacity
of about 80 million pounds per year.

Current pentaehlorophenol

production is in the range of 40 to 50 million pounds per annum

(EPA 1981).

In general about 80 percent of all pentachlorophenal
Most of the remainder Is used in

produced is used for wood preservation.

registered fungicide products applied to a wide variety of industrial
products including leather, burlap, masonry, cordage, paint, pulp and

paper mills and cooling towers.
The registered wood preservative products containing penta have a
wide range of uses because of their efficacy against a broad range of

pests (bacteria, yeast, slime molds, algae, fungi, plants, insects,,

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Aldrin is and always has been sold for termite control only as a

4 pound per gallon emulsifiable concentrate.

This is mixed 1 gal3.on to

95 gallons of water to form a 0.5 percent use strength emulsion.

iv.

Dieldrin

Dieldrin is also a product of Shell Chemical still registered with

Company.

Although

EPA, production of

dieldrin in the U.S. was

discontinued following the cancellation

of'most of

its uses in 1974.

Currently, dieldrin is not available in the U.S. and there is no known
consumption of it.

Lil^e aldrin, dieldrin was used in agriculture
insects, especially those infesting corn.

to control soil

Only small quantities of
Dieldrin usage VELS
eoitt

dieldrin were used as a subsurface termiticide.

always much lower than aldrin, primarily because of its higher

but

comparable effectiveness (aldrin breaks-down into dieldrin in the soil).

v.

Lindane

Lindane was previously produced by Hooker Chemical Corporation

but all registrations and marketing activity were transferred to ISoecon

Corporation more than a year ago*

Hooker terminated the production of

lindane after the initiation of RPAR proceedings and began purchasing

lindane from foreign producers.

After the transfer of lindane activities

in 1980, Zoecon Corporation continued to import lindane from these same

foreign manufacturers.
since 1976

There has been no domestic production of lindane

(Mercado, pers. comm. 1981).

Usage since 1976 has decreased

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The most common formulated control are H-60

products used for subterranean termite

(2-1/2 Ibs/gal) and Termlde (2.1 Ibs heptachlor/gal. 4.2
The heptachlor concentrate is typically diluted and
The major formulator of these

Ibs. chlordane/gal).

applied as a 0.5 percent emulsion.

products is Stephenson Chemical Co,

iii.

Aldrin

Aldrin is currently imported by Terminix International

Inc., from

Shell International Chemical Company both for its

own.use

and resale to

other structural pest control operators.
in the

It is no longer being produced

U.S'.,

having been discontinued by Shell Chemical Company in 1974
Terminix Imported aldrin in 1977

and by and

Amvac Chemical Corp. in 1978.

1978, but aldrin lost

its price competiveness with the result chat it

was not imported into this country in 1979 and 1980.

Now aldrin :ls once

again being imported, primarily in response to significant chlordfine

price increases, and Terminix anticipates substantial sales through the
rest of 1981.

They expect aldrin will capture as much as 25 perccsnt of

the termiticide market.by the end of 1981

(Hromada, pers.

comm.

1981).

Prior to the cancellation of most uses in
used in agriculture.

1974,

aldrin was widely

The major agricultural use of aldrin was for the
This accounted for 97 percent of total

control of insects on corn.

agricultural usage in 1971.

During this time period aldrin also competed

closely with chlordane in the subsurface termiticide market.

At present,

there is virtually no use of aldrin in agriculture, but its use as a
termite control seems to be

increasing in response to chlordane price

increases.
that market.

These increases allow imported aldrin to be competitive in

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Table XII.

Distribution of Heptachlor by EPA

Region^/,

1980.

Quantity
Region,
Distributed

Percent

(Ibs.)
I II
III
800 .03

51,000
59,000

2.48
2.87

IV
V

1,131,000
33,000

54.96
1.60

VI

306,000 126,000 185,000

14,87
6.12 900 8.07

vn
VIII
IX

166.000

x
lotal

2,057,800

100

Source:

Data provided by the Velsicol Corporation, 1981 (Frommer, pars. comm

1981).
-a/ Refer to regional map In Appendix.

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ii.

Heptachlor

Heptachlor Is also produced by the Velslcol Corporation.

It has

always been used in much smaller quantities and for fewer sites than
chlordane.

But unlike chlordane, a higher percentage (an estimated 752)

of heptachlor was used in agriculture, mainly for corn soil treatments.
Agricultural usage of heptachlor was estimated to be between 1.5 and 2.0
million pounds in

1974, whereas just less than 0-5 million pounds were

used for termite control.

Following the suspension of chlordane and heptachlor products in

1975, agricultural usage of heptachlor

declined significantly from the

stable level of usage experienced in previous

years (about 1.0 to 1.5

million pounds annually).

According to the settlement phase-out plan,

most registered products containing heptachlor will be effectively

cancelled, or their application for registration denied by July 1, 1983.
Velsicol Corporation reported that the phase-out plan is being followed

and that the only remaining uses are for seed treatment, pineapples

(Hawaii) and subterranean termite control (Frommer, pers. comm. 1981).
Compared to 1974, when approximately 25 percent of heptachlor was
used for termite control, nearly 90 percent (1 to 2 million pounds) was
used for termite control in 1980. Table XII shows the distribution of

heptachlor by EPA region.

Again, this is initital distributon.

Region

IV receives more than half of the heptachlor distributed and Region VI
receives approximatley 15 percent.

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Table XI.

Distribution of Chlordane by EFA

Region^/,

1980.

Region

Quantity Distributed

Percent

(ibs.)

I II III
IV
V

114,000 948,000
566,000

1.19 9-91
5.92

3,776,000
880,000 1,285,000

39.50 9.21 13.11 10.43
.39

VI
VII

997,000

VIII
IX

38.000
906,000

9.48
.86
100

x
Total

82.000
9.592,000

Source:

Data provided by the Velsicol Corporation, 1981 (Fronnner, pers. comm

1981).
J^/ Refer to regional map in Appendix.

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By 1980, less than 10 million pounds of ehlordane were b<*ing used
in the U.S.

Nearly all of the 10 million pounds were used for termite

control, with only very small quantitites being used for dipping roots or
tops of non-food plants.

It was the most widely used insecticide for
Table XI shows the distribution of

subterranean termite control. ehlordane by EPA regions.

The amount distributed does not fully reflect

end use, as this just portrays the first step in the distribution chain*

It consists of shipments to distributors and sub-registrants.
shipments are then distributed (sometimes nationwide) by the sub-registrants and distributors.

These

The largest quantity of ehlordane

distributed goes initially to Region
followed ..by Region

IV.1/

(approximately 40%),
Almost all the states

VX2/

(approximately 13%).

in these regions are located in the high termite infestation hazard area

(see map on page

0

).

The most common formulated products used for subterranean termite

control include C-100 (8 Ibs/gal.). C-50 (4 Ibs/gal.), 8EC (8 Ib/gal.)
and Termide (4.2 Ibs.

chlordane/gal., 2.1 Ibs. heptachlor/gal.).

The

cnlordane concentrates are typically diluted with water to obtain a 1.0
percent per gallon emulsion before
use*

The chlordane-heptachlor mix is

diluted with water to obtain a 0.5 percent

chlordane/0.25 percent

heptachlor emulsion.

The major formulators of these products include

Federal Chemical Co., Dexol Industries. Inc., Chevron Chemical and Black
Leaf Products (EPA Microfiche, 1980).

I/

?J

Kentucky, Tennessee, North Carolina, South Carolina, Georgia, Florida, Alabama, and Mississippi. Arkansas, Louisiana, Oklahoma, Texas and New Mexico.

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B.

Production and Usage of the Seven Registered Termiticides

1.

Chlordane

Chlordane Is produced by the Velsicol Corporation, a subsidiary
of Northwest Industries, Inc.

Prior to the cancellation action in 1974

against most of its use sites, an estimated 21 million pounds of
chlordane were used in the United States.

Approximately 30 percent, less

than 7 million pounds, of this total were used for termite control.

In

agriculture uses, more than half of the chlordane was'used on corn (EPA,

1976).

Registered uses at that time Included control of ants on citrus,

fire ants on lands not used for food or feed production or grazing;,
cutworms on

grapes, grasshoppers on flax, various insects on

strawberries, fire ants and Japanese beetle larvae on nursery stock, and
as a soil insecticide to protect corn primarily from rootworms, wireworms

and cutworms.
Under the provisions of the settlement plans to phase out

specified uses of chlordane and heptachlor, most registered products
containing chlordane were to be effectively cancelled or their

registration applications denied by December 31, 1980.

The only uses of

chlordane unaffected by this settlement were subsurface ground insertion for termite control and the dipping of roots or tops of non-food plants-

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On balance, it seems reasonable to assert that approximately
15 percent of the chlordane marketed Is purchased by homeownersunknown portion of this is no doubt used on other pests. There is

Some

probably significant variation among homeowners in regard to the extent
to which they follow recommended application procedures, with a

corresponding variation in the resulting effectiveness of termite
control and exposure hazard*

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presented in Appendix B.

Label summaries are also presented in this

Appendix for chlorpyrifos, dieldrin, heptachlor, lindane, and

pentachlorophenol.

In the course of actual application, the labels

should be strictly followed.

iii.

Do It Yourself Chemical Treatment

There are numerous termiticide products (mainly chlordane)
which can be purchased for use by the homeowners.
The availability of

these products to homeowners varies on a state by state basis according
to the applicable state regulations.

EPA estimates that approximately 1.5 million pounds of
chlordane are purchased annually by homeowners.
Since chlordane

historically has been a common household insecticide, the extent to
which this volume is Improperly used on pests other than termites is
unknown.

Little, if any, heptachlor or lindane is purchased for termite

control by the homeowners.
pest problems by homeowners.

However, lindane can be purchased for other
About 1.6 million pounds of
to

pentachlorophenol (penta) are used around homes and farms primarily
preserve various wood structures and products exposed to natural
elements.

Little, If any, penta is used as a soil treatment for

subterranean termites.

No aldrin, dieldrin and chlorpyrifos are isold to

homeowners for termite control-

2^