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E-mail from Cathryn O'Connell, EPA Chemical Review Manager

Dear Dr. Fallon,

Thank you for your message about misting systems. As you stated in your email, the Agency has been working to establish new requirements for misting systems through the reregistration process, which reviews older pesticides. In the process of conducting this review, a few, but not all,of the chemicals that appear to be more popularly used in these systems have gone through review. Those chemicals include the pyrethrins, piperonyl butoxide (a pesticide synergist), and permethrin.

During the reregistration process, EPA met with numerous users to determine how the pyrethrins, piperonyl butoxide, and permethrin products are typically used in outdoor residential misting systems. These use parameters served as a basis for both the risk assessments and the recommended label changes for these chemicals. Companies that want their products that to continue to be registered with the EPA and used in outdoor residential misting systems must have specific label language added addressing: maximum application rates and frequency, nozzle placement, calibration of equipment, and the security of the storage tank.

In addition, the product labeling must restrict the presence of people, pets, and food during applications, and require product installers and service technicians to comply with the license, certification, or registration requirements of the state(s), tribe(s), or local authority(ies) where these systems are installed.

These requirements are chemical specific, so it is very important to read the pesticide product label that will be used in the misting systems in your community to determine what the specific requirements and rates are for the product you are using. With that in mind, many of these changes that EPA is requiring will not appear on older product labels, since these decisions have been made relatively recently (Summer 2006).

In the meantime, the best place to look for the new label requirements mentioned above is the reregistration eligibility decision (RED) documents for each chemical. I've copied the generic label changes that the EPA is requiring for the pyrethrins, piperonyl butoxide, and permethrin below.

Outdoor Misting System Label Statements:

When using this product installers and service technicians must comply with the license, certification, or registration requirements of the state(s), tribe(s), or local authority(ies)where they are installed.

If the system works on an automatic timer, set the timing for application when people, pets, and food are unlikely to be present.

If the system works when a person operates a remote activation device, then application of this pesticide when people, pets, and food are present is prohibited.

Do not use in an evaporative cooling system.

Direct nozzles to spray towards the target area and away from swimming pools, water bodies, or eating and cooking areas.

If used in a system with a reservoir tank for the end use dilution, the system reservoir tank must be locked. Securely attach the end use pesticide label and a dilution statement to the system reservoir tank in a weather protected area or plastic sleeve. The dilution statement must be phrased as follows: this container holds __ parts [product name] to __ parts water. If used in a direct injection system, the pesticide container must be locked. Securely attach the end use label to the pesticide container in a weather protected area or plastic sleeve. This product must only be used in systems that have been calibrated to apply no more than the maximum application rate of [this rate is different for each different pesticide active ingredient].

If you are interested in looking at these RED documents more closely, they can all be found at the reregistration website http://cfpub.epa.gov/oppref/rereg/status.cfm?show=rereg.

Just one more thing to keep in mind, the homeowner is responsible for the system, and for making sure the misting application is being conducted correctly. If there is drift onto neighboring properties, it is the homeowner's responsibility. Setting up the nozzles correctly and being aware of where the spray is being directed is important.

The Agency also is developing a web fact sheet for consumers that will include best management practices for safe use of mosquito misting systems. Unfortunately it is not up and running, yet, but look for it on our website, as it will hopefully be available in the next few months or so.