From: ACTSNYC**At_Symbol_Here**CS.COM
Subject: Re: [DCHAS-L] Pesticide regulation
Date: June 16, 2012 8:49:55 AM EDT
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <34ce9.1d660ea8.3d0ddaf2**At_Symbol_Here**>

That EPA rule below applies to the building owner or agent so they can document that a legal pesticide was used by a certified applicator for the proper purpose which is all they need for regulatory purposes and due dilligence. But the building agent or owner merely drops by on occasions.  The workers spends 40-60 hours a week there, eats lunch there, etc.  And as I understand it, most of you are not charged with protecting the health of the building owner or leasing agent.  You probably dp have responsiblity for the health and safety of people who are paid to work in that building.

As a union worker rep, I've used 29 CFR 1910.1020 to get pesticide MSDSs as well as any condition reports, testing, or other documents from the employer who gets them from the pesticide company.  For health and safety, we need to know what pests are present in the workplace, why and where they are, what was used to control them, and where and when pesticides were applied.

At present I'm dealing with a massive rodent infestation in a public building.  If you were a worker there, wouldn't you want to know eveything about where these disease-carrying dangerous pest were, how and why they are accessing the facility, and what chemicals and strategies they are using to do them in?  We've gotten the same info for West Nile-carrying mosquito control, bed bugs, and even roaches and flies.  If I could tell you where the roaches and flies were in one particular worksite, you would all see the need to know how they got there and what pesticides were used!

It's not only the pesticide MSDS that you need, it is the pesticide company's reports and communications with the building or agent that you need in some instances.  Monona

In a message dated 6/14/2012 5:04:29 PM Eastern Daylight Time, secretary**At_Symbol_Here**DCHAS.ORG writes:

From: "Corrigan, Mary" <mary_corrigan**At_Symbol_Here**>
Date: June 13, 2012 5:28:51 PM EDT

The notification requirements for pesticide application vary from state to state. (Pesticide Applicator certifications are run by states.)  In NY, the DEC requires Certified Pesticide Applicators to provide copies of the pesticide label, rather than the MSDS:  "Except as provided in paragraph c of this subdivision, every certified applicator shall, prior to the application of a pesticide within or on the premises of a multiple dwelling, building, or structure other than a dwelling supply the owner or his agent, with a copy of the information, including all warnings, contained on the label of the pesticide to be applied."

The saying about pesticide labels has been:  "The label is the law".  It identifies approved target pests, application rates, etc..

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