Comments on: Blaming EPA is not the answer either http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/ A bed bug policy advocacy group Wed, 28 Jul 2010 04:37:51 +0000 hourly 1 http://wordpress.org/?v=3.0.1 By: Section 18 exemptions under consideration? — New York vs Bed Bugs http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/comment-page-1/#comment-8049 Section 18 exemptions under consideration? — New York vs Bed Bugs Sun, 19 Jul 2009 22:19:20 +0000 http://newyorkvsbedbugs.org/?p=2785#comment-8049 [...] couple of months ago we looked at just such doubts from PCT columnist Richard [...] [...] couple of months ago we looked at just such doubts from PCT columnist Richard [...]

]]> By: sam bryks http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/comment-page-1/#comment-7589 sam bryks Mon, 06 Jul 2009 16:06:34 +0000 http://newyorkvsbedbugs.org/?p=2785#comment-7589 Renee, after your comment about Safer, I went to their website to have a look. I simply haven't visited it for a while, and things do move forward.. Yes, Safer emphasizes IPM but in their factsheet on bed bugs here is what they note about treatment "Remember, there is no magic formula that will guarantee bed bug elimination. These tips are in addition to the limited use of pesticides, and are in no way intended to replace a select treatment program by knowledgeable professionals. Do not use chemicals around sleeping areas and furniture unless they are properly labeled to treat bed bugs in the home. Always seek professional advice before applying pesticides around people with health conditions" So Safer does not say.. do not use pesticides, but they emphasize "limited use" and "a select treatment program by knowledgeable professionals" The no pesticide zone refers to lawns and exterior environemnt and this is becoming more common. Toronto started iwth a new policy banning cosmetic use of pesticides for landscape.. with exception of golf courses and other specific situations, and the Province applied the policy throughout all of Ontario. This is due to a history of heavy appications of herbicides and insecticides on a repetitive basis. The Safer no pesticide Zone refers to posters they supply to advise people that pesticides were not used in the area so children can play there without fears of allergic reactions or other effects. Safet also provides a definition of IPM and a list of firms they recommend who follow IPM standards. This is Safer's defintion of IPM... not bad "Integrated Pest Management (IPM) is a proven method of pest control that emphasizes simple, inexpensive prevention practices that cause the least harm to people and the environment. IPM focuses on eliminating the cause of pests by minimizing access to food, water, and hiding places." I think that they are leaders in Illinois in this area. I have watched their work developing over the years.. Good for them... a lot of common sense explained in simple terms. here is their link http://www.spcpweb.org/# I am always dismayed by attacks on IPM because it is so basic and has such common sense in whatever format presented, that I don't know how anyone could consider this counter-productive. When done by professionals in managing major accounts for pest issues whether food industry or housing, there is an overview that is needed to enable some practical decision rules of application - so that in the hospitality industry, for example, protecting reputation and spread of infestation is critical, and the decision rules and methodologies are stringent. Most housing organizations could not afford the costs of how hospitality industry would treat a hotel room, so there is a need to examine best and most cost-effective practices. That is the very IPM that Rich says doesn't exist. I know it does because I have been a practictioner for about 27 or 28 years. The other 2 or 3 years from when i started in this business, I was a neophyte learning the business and cannot claim knowledge of IPM at that time. Let's take the best of IPM practices and apply to bed bugs, and as I have said a few times before, this site with the extensive information here supports IPM ... that is the science of pest management. It is much more than what we would call Pest Control. There is a reason why National Pest Control Association changed its name to National Pest Management Association, and I can assure you that IPM was at the heart of this change.. best wishes to all.... and success in pest management by best practices. I call it IPM.. You can call it whatever you like. Sam Renee,
after your comment about Safer, I went to their website to have a look. I simply haven’t visited it for a while, and things do move forward..
Yes, Safer emphasizes IPM but in their factsheet on bed bugs here is what they note about treatment
“Remember, there is no magic formula that will guarantee bed bug elimination. These tips are in addition to the limited use of pesticides, and are in no way intended to replace a select treatment program by knowledgeable professionals. Do not use chemicals around sleeping areas and furniture unless they are properly labeled to treat bed bugs in the home. Always seek professional advice before applying pesticides around people with health conditions”
So Safer does not say.. do not use pesticides, but they emphasize “limited use” and “a select treatment program by knowledgeable professionals”

The no pesticide zone refers to lawns and exterior environemnt and this is becoming more common. Toronto started iwth a new policy banning cosmetic use of pesticides for landscape.. with exception of golf courses and other specific situations, and the Province applied the policy throughout all of Ontario. This is due to a history of heavy appications of herbicides and insecticides on a repetitive basis. The Safer no pesticide Zone refers to posters they supply to advise people that pesticides were not used in the area so children can play there without fears of allergic reactions or other effects.
Safet also provides a definition of IPM and a list of firms they recommend who follow IPM standards.
This is Safer’s defintion of IPM… not bad
“Integrated Pest Management (IPM) is a proven method of pest control that emphasizes simple, inexpensive prevention practices that cause the least harm to people and the environment. IPM focuses on eliminating the cause of pests by minimizing access to food, water, and hiding places.”
I think that they are leaders in Illinois in this area. I have watched their work developing over the years.. Good for them… a lot of common sense explained in simple terms.
here is their link http://www.spcpweb.org/#
I am always dismayed by attacks on IPM because it is so basic and has such common sense in whatever format presented, that I don’t know how anyone could consider this counter-productive. When done by professionals in managing major accounts for pest issues whether food industry or housing, there is an overview that is needed to enable some practical decision rules of application – so that in the hospitality industry, for example, protecting reputation and spread of infestation is critical, and the decision rules and methodologies are stringent. Most housing organizations could not afford the costs of how hospitality industry would treat a hotel room, so there is a need to examine best and most cost-effective practices. That is the very IPM that Rich says doesn’t exist. I know it does because I have been a practictioner for about 27 or 28 years. The other 2 or 3 years from when i started in this business, I was a neophyte learning the business and cannot claim knowledge of IPM at that time.
Let’s take the best of IPM practices and apply to bed bugs, and as I have said a few times before, this site with the extensive information here supports IPM … that is the science of pest management. It is much more than what we would call Pest Control. There is a reason why National Pest Control Association changed its name to National Pest Management Association, and I can assure you that IPM was at the heart of this change..
best wishes to all…. and success in pest management by best practices. I call it IPM.. You can call it whatever you like.
Sam

]]> By: Sam Bryks http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/comment-page-1/#comment-7567 Sam Bryks Sun, 05 Jul 2009 19:17:13 +0000 http://newyorkvsbedbugs.org/?p=2785#comment-7567 Renee,, my comment about "spray the hell out of a place" was not directed at you Renee.. nor do i advocate vacuuming every day. And i certainly do not intend condescension Renee. I have made deserved positive statements about your site more than once and about your talents here, so i don't know why you would presume me to be condescending. Pesticide free zones may be necessary in some cases but that is not my point. I mentioned Safer because i know they work hard at reducing use of pesticides while advocating good control practices. As for 5 units with infestation in a 300 unit site, my meaning is not that this is not serious, but it is a matter of degree of response. I have been in situations in which there was demand by tenants or by health departments for total building treatments on "perception" and a distorted belief that spraying an entire building for roaches was a good reactive step. and do it once a year.. that used to be the practice of many housing providers. I have refused to do that on more than one occasion and required an assessment before taking such disruptive and often unnecessary action resulting in gallons and gallons of insecticde being sprayed for NON EXISTENT pests in most units. Let me direct readers to the Health Homes Initiative site http://www.healthyhomestraining.org/ as one of the very best resources about IPM, as well as NPMA that endorses IPM as a valued practice and the fact that IPM has a best quality certification program that uses IPM as a major strategy, and National Environmental Health Association web site with a podcast by Professor Marc Lame who has written in detail on school IPM, and whose lecture is insightful and tells the facts with clarity.... the naysayers are arguing from political positions not from facts, nor common sense, and the dialogue here by Rich demonstrates this beyond doubt. it feels like arguing about intelligent design vs evolution and anyone with a basic sound knowledge of science whether a lay person or a scientist knows that this is essentially a nonsensical argument and that has been validated by the courts in the U.S. not long ago in one of the states in which a school board tried to give intelligent design validity as an alternative idea to evolution. The court basically said that the argument was actually a thinly veiled attempt to give Creationism validity as a scientific theory which it is not. Of course, evolutionary theory does not exclude a divine force whereas creationism ascribes religious doctrine to try to discredit evolution as a fact of knowledge through an overwhelming body of evidence. Those who want to attack the concept of IPM .. seem to want to make it anti-pesticide and attach all the political nonsense to that, when we should be focused on best practices and safety and minimize use of pesticides to achieve control and protect the public health. This is not politics. it is about risk/benefit and cost-effectiveness, about sustainability of control through education and legislated practices and rules designed to protect the public.. remember, democracy is an evolution of human behaviour in maximizing rights of the populace and to improve the quality of life . and IPM is really part of that... |I suggest that readers check out the healthy homes website for a very wonderful and detailed overview of these things.. I rest my case.. i will continue to promote ipm in my work.. but i am tired of arguing about it.......... the facts are simply overwhelming in support of IPM as THE best practice............... call it what you will Sam Renee,, my comment about “spray the hell out of a place” was not directed at you Renee.. nor do i advocate vacuuming every day. And i certainly do not intend condescension Renee. I have made deserved positive statements about your site more than once and about your talents here, so i don’t know why you would presume me to be condescending.
Pesticide free zones may be necessary in some cases but that is not my point. I mentioned Safer because i know they work hard at reducing use of pesticides while advocating good control practices.
As for 5 units with infestation in a 300 unit site, my meaning is not that this is not serious, but it is a matter of degree of response. I have been in situations in which there was demand by tenants or by health departments for total building treatments on “perception” and a distorted belief that spraying an entire building for roaches was a good reactive step. and do it once a year.. that used to be the practice of many housing providers. I have refused to do that on more than one occasion and required an assessment before taking such disruptive and often unnecessary action resulting in gallons and gallons of insecticde being sprayed for NON EXISTENT pests in most units.
Let me direct readers to the Health Homes Initiative site
http://www.healthyhomestraining.org/ as one of the very best resources about IPM, as well as NPMA that endorses IPM as a valued practice and the fact that IPM has a best quality certification program that uses IPM as a major strategy, and National Environmental Health Association web site with a podcast by Professor Marc Lame who has written in detail on school IPM, and whose lecture is insightful and tells the facts with clarity…. the naysayers are arguing from political positions not from facts, nor common sense, and the dialogue here by Rich demonstrates this beyond doubt.
it feels like arguing about intelligent design vs evolution and anyone with a basic sound knowledge of science whether a lay person or a scientist knows that this is essentially a nonsensical argument and that has been validated by the courts in the U.S. not long ago in one of the states in which a school board tried to give intelligent design validity as an alternative idea to evolution. The court basically said that the argument was actually a thinly veiled attempt to give Creationism validity as a scientific theory which it is not. Of course, evolutionary theory does not exclude a divine force whereas creationism ascribes religious doctrine to try to discredit evolution as a fact of knowledge through an overwhelming body of evidence.
Those who want to attack the concept of IPM .. seem to want to make it anti-pesticide and attach all the political nonsense to that, when we should be focused on best practices and safety and minimize use of pesticides to achieve control and protect the public health. This is not politics. it is about risk/benefit and cost-effectiveness, about sustainability of control through education and legislated practices and rules designed to protect the public..
remember, democracy is an evolution of human behaviour in maximizing rights of the populace and to improve the quality of life .
and IPM is really part of that…
|I suggest that readers check out the healthy homes website for a very wonderful and detailed overview of these things..
I rest my case.. i will continue to promote ipm in my work.. but i am tired of arguing about it………. the facts are simply overwhelming in support of IPM as THE best practice…………… call it what you will
Sam

]]> By: Renee Corea http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/comment-page-1/#comment-7554 Renee Corea Sun, 05 Jul 2009 05:50:00 +0000 http://newyorkvsbedbugs.org/?p=2785#comment-7554 But of course, I advocate "spraying the hell out of a place" instead of vacuuming every day here, don't I? Why would you choose such an obvious example of exactly what we're not talking about? And indeed your examples further fail you when you offer Safer Pest Control Project for my perusal, where I see that I can order a $15 sign to proclaim to the world that my lawn, school, park, or business is a "pesticide free zone." So I can see perfectly how you are tired of me making it "seem" that IPM is anti-pesticide where there is no evidence anywhere of such an idea. I have no interest in either demonizing or lionizing IPM, or indeed pesticides. I only care about bed bugs. Don't condescend to me, Sam, I beg you, nothing depresses me more. And I submit that if you have a 300 unit building where 5 units have bed bugs, you have a time bomb. But of course, I advocate “spraying the hell out of a place” instead of vacuuming every day here, don’t I? Why would you choose such an obvious example of exactly what we’re not talking about? And indeed your examples further fail you when you offer Safer Pest Control Project for my perusal, where I see that I can order a $15 sign to proclaim to the world that my lawn, school, park, or business is a “pesticide free zone.”

So I can see perfectly how you are tired of me making it “seem” that IPM is anti-pesticide where there is no evidence anywhere of such an idea.

I have no interest in either demonizing or lionizing IPM, or indeed pesticides. I only care about bed bugs. Don’t condescend to me, Sam, I beg you, nothing depresses me more.

And I submit that if you have a 300 unit building where 5 units have bed bugs, you have a time bomb.

]]> By: sam bryks http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/comment-page-1/#comment-7553 sam bryks Sun, 05 Jul 2009 03:23:45 +0000 http://newyorkvsbedbugs.org/?p=2785#comment-7553 thanks Renee.. yes, i did mistake Rich's website for the other, and i will certainly look at his with interest.. the threshold limits for bed bugs in single units should be zero... simple as that... but when dealing with entire buildings, one looks at extent of sprad of infestation to make decisions about broader tactics in a site... so if we had 5 infestations of bed bugs in a building with 300 units, we would not survey the entire site with dogs or staff inspecting unit by unit but look at the five specifically, but if we had 35 units spread throughout the entire buidling, we would look at investigating each case and adjacent units and perhaps even full block inspections... that is an example of thresholds of action.. it is not about saying that a few are acceptable in a unit or even in a building, but rather what actions are merited by the extent of infestation.... i always liked the idea of an annual survey by mail in addition to the careful tracking of treatment data. the governing principles of IPM in my view are 1. risk/benefit as a primary health and safety evaluation that should apply to any activity 2. cost-effectiveness 3. reduced use of pesticides as an outcome of intelligent analysis of best practices in the specific case 4. education of clients and service providers in treatment protocols 5. quality assurance processes in place by service provider and clients why would we not want to reduce use of pesticides? If i can get something done without pesticides,, all the better!!! remember the study of effects of Dursban in children's intelligence.... !!!!!! just one study.... history has many stories of sacrificing people for profit and short term gains.... we don't need to be part of that in any way... that is part of the ideal of IPM... i am amazed by those who would argue this rather than embracing the common sense of it. but I will continue to present this as the best current approach to pest management in the urban setting, or indeed in any setting. It encompasses best science and methodology and ethical values in pest management and has been long overdue as a standard practice in our industry. i have seen the failure of pest management when this is not done properly countless times. and more often than not, the driver is cost.. so that pest control services in public housing are often the lowest and cheapest services imaginable... go the the health homes initiative web site of the Safer Pest Control project in Chicago.. or EPA or the NEHA and you will see solid documentation of IPM.. The benefit has been demonstrated time and time again, and yet we still have these elemental arguments trying to make it seem as if IPM is anti-pesticide. It is pro best practices and pro reducing use of pesticides when best practices enable this.. Sometimes it necessitates a lot of application, but given the choice between vacuuming up a heavy infestation of bed bugs as a first step or spraying the hell out of a place, to me the choice is obvious. Sam thanks Renee.. yes, i did mistake Rich’s website for the other, and i will certainly look at his with interest..
the threshold limits for bed bugs in single units should be zero… simple as that…
but when dealing with entire buildings, one looks at extent of sprad of infestation to make decisions about broader tactics in a site… so if we had 5 infestations of bed bugs in a building with 300 units, we would not survey the entire site with dogs or staff inspecting unit by unit but look at the five specifically, but if we had 35 units spread throughout the entire buidling, we would look at investigating each case and adjacent units and perhaps even full block inspections… that is an example of thresholds of action..
it is not about saying that a few are acceptable in a unit or even in a building, but rather what actions are merited by the extent of infestation…. i always liked the idea of an annual survey by mail in addition to the careful tracking of treatment data.

the governing principles of IPM in my view are

1. risk/benefit as a primary health and safety evaluation that should apply to any activity
2. cost-effectiveness
3. reduced use of pesticides as an outcome of intelligent analysis of best practices in the specific case
4. education of clients and service providers in treatment protocols
5. quality assurance processes in place by service provider and clients

why would we not want to reduce use of pesticides?
If i can get something done without pesticides,, all the better!!!
remember the study of effects of Dursban in children’s intelligence…. !!!!!! just one study….
history has many stories of sacrificing people for profit and short term gains…. we don’t need to be part of that in any way…
that is part of the ideal of IPM…
i am amazed by those who would argue this rather than embracing the common sense of it. but I will continue to present this as the best current approach to pest management in the urban setting, or indeed in any setting. It encompasses best science and methodology and ethical values in pest management and has been long overdue as a standard practice in our industry.
i have seen the failure of pest management when this is not done properly countless times. and more often than not, the driver is cost.. so that pest control services in public housing are often the lowest and cheapest services imaginable… go the the health homes initiative web site of the Safer Pest Control project in Chicago.. or EPA or the NEHA and you will see solid documentation of IPM.. The benefit has been demonstrated time and time again, and yet we still have these elemental arguments trying to make it seem as if IPM is anti-pesticide. It is pro best practices and pro reducing use of pesticides when best practices enable this..
Sometimes it necessitates a lot of application, but given the choice between vacuuming up a heavy infestation of bed bugs as a first step or spraying the hell out of a place, to me the choice is obvious.

Sam

]]> By: Renee Corea http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/comment-page-1/#comment-7542 Renee Corea Sat, 04 Jul 2009 20:18:16 +0000 http://newyorkvsbedbugs.org/?p=2785#comment-7542 Hello, gentlemen. I thank you for having this conversation in public here, even if it is so strained. I'm just catching up to all the comments now. Sam, I doubt that I showed you Rich's website as I have only known about it myself since about the time of the aftermath of the EPA bed bug meeting. The website I did show you is George Rotramel's, and I think it would be great to look at it again. <a href="http://www.georgerotramel.com/about" rel="nofollow">This is the relevant page</a> where he writes about IPM at length. If I can request the indulgence, I should like to hear your thoughts on his interesting discussion. I am intrigued by the idea of threshold limits and their inapplicability to the pest in question, bed bugs. Sorry to bring the discussion to such a parochial concern as this! ;) I confess that what I don't quite understand and don't quite find helpful about IPM is its governing principle of pesticide use reduction. With bed bugs, I want the discussion to be about how to kill the bed bug, not about the policy goal of pesticide use reduction, especially because in current practice so many people are living with repeated and useless pesticide applications and self-applications <em>and</em> bed bugs. The bed bug must come first. Rich, I'm fixing the link to your site attached to your name in these comments so that anyone can click your name and read your site. EDIT: Sorry, I forgot the link, now added, and I also added what we mentioned earlier in this conversation, that the practical effect of the current situation with regard to pesticide abuse and overuse by desperate people is no good. Hello, gentlemen. I thank you for having this conversation in public here, even if it is so strained.

I’m just catching up to all the comments now. Sam, I doubt that I showed you Rich’s website as I have only known about it myself since about the time of the aftermath of the EPA bed bug meeting. The website I did show you is George Rotramel’s, and I think it would be great to look at it again. This is the relevant page where he writes about IPM at length. If I can request the indulgence, I should like to hear your thoughts on his interesting discussion. I am intrigued by the idea of threshold limits and their inapplicability to the pest in question, bed bugs. Sorry to bring the discussion to such a parochial concern as this! ;)

I confess that what I don’t quite understand and don’t quite find helpful about IPM is its governing principle of pesticide use reduction. With bed bugs, I want the discussion to be about how to kill the bed bug, not about the policy goal of pesticide use reduction, especially because in current practice so many people are living with repeated and useless pesticide applications and self-applications and bed bugs. The bed bug must come first.

Rich, I’m fixing the link to your site attached to your name in these comments so that anyone can click your name and read your site.

EDIT: Sorry, I forgot the link, now added, and I also added what we mentioned earlier in this conversation, that the practical effect of the current situation with regard to pesticide abuse and overuse by desperate people is no good.

]]> By: Sam Bryks http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/comment-page-1/#comment-7540 Sam Bryks Sat, 04 Jul 2009 18:50:26 +0000 http://newyorkvsbedbugs.org/?p=2785#comment-7540 Rich, if you don't mind my calling you by first name and i extend that courtesy to you if you so choose, ... i do appreciate the piece on the fallacy of composition. I should have researched this more carefully. I didn't find it listed on the list i found on the net, so i appeciate the education on that. So, i yield on that point. Rich said "you have only recently discovered that what you have been doing right along has in reality been IPM. That alone strengthens my argument " Sam says.. your point here is completely inaccurate on both statements you make. I never said that I only recently discovered lPM. You misread what i wrote totally.. and it hardly strengthens your argument by any means. I don't want to write a four page exposition here again. This is really becoming a lot like arguing with someone who supports creationism as an argument to refute Darwin's insightful understanding of evolution. I don't think that cluttering the pages of newyorkvsbedbugs is going to serve the cause. notwithstanding my accepting that there is indeed a fallacy of composition, i still find your arguments against IPM to be fallacious and empty of value, and steeped in political context and accusations. the common elements in agricultural and structural ipm are obvious... knowledge of the pest and its habitat as a requirement... designing methods of prevention in order to be able to manage the pest cost - effectively .. and the term, "manage" does not suggest that the ideal threshold in strucural should be more zero. I once saw a manual on cockroach control put out by a misiguided and inexperienced health promoter who should have known better, who tried to set an acceptable threshold in homes. I am sure her threshold was zero but she thought she could apply a higher threshold to those less fortunate than herself. Having said that, the reality of thresholds of existing infestation can and are used in structural pest control as part of decision rules for treatment when considering structures with many dwellings. One must understand the distinctions between economic thresholds in agriculture, and thresholds in structural pest control. We don't do a full building treatment for one infestation of roaches or bed bugs, but decisions can be made about the extent of action -- i.e. decision rules.. and this is IPM ... no matter how you want to label it as something not applicable to structural. Rich says 1.IPM is merely pest control and doesn’t truly exist in structural pest control as some different from of structural pest control. Sam says Your argument here is that because some things are part of structural pest control, they cannot be fit into an ipm framework. If we define IPM and someone is doing all the things without calling it IPM, it doesn't mean that we must cease defining it as such. That is a matter of language and does not preclude the definition of the elements. It is as if someone wrote a wonderful novel and used parts of speech and sentence structure that had been defined by a teacher of composition and writing, and someone said that we cannot use the teacher's definitions of sentence composition because the writer did it on his own without giving it structure of nomenclature.. Using things named that are part of a process does not preclude their being part of the process just the same. Your interpretation of the fallacy of composition in this regard is flawed and incorrect.. If we say that steps a b c d and e are part of IPM process and someone does all steps but doesn't call it ipm, it does not mean we must stop calling it ipm.. the reality is that in many many instances a firm may be doing a b and e but not c and d, and then by definition, it is not ipm... however, if a b and c are teh key elements and d and e are variants, then we can still say it is ipm even if sometimes d and e may not be necessary to achieve the control result... we can dissect it to pieces, but the main point is that the elements we know and recognize are there,, and if that is the case, then lo and behold.. IT IS IPM Rich wrote 2. Can’t be properly defined or recognized in a structural pest control situation. Sam replies I can define it and have done so for a long time in the structura setting. name a sitaiution and i can put it into that frame work.. Read Marcos Kogan's definition. Read MY BOOK.. on IPM in Housing Rich 3. That IPM is so broad as they are attempting to apply it to structural pest control that it allows for IPM to be defined and redefined unendingly to suit some new philosophical flavor of the day. Sam there is no such thing as you put it - flavour of the day..ll. .. it is about common sense... and a scientific approach using reasoning... If i know the biology of an insect and find it in a setting, and then understand how it got there and how it is thriving, and find ways to prevenit entry and change habitat or to apply pesticides appropriately... that's IPM by every measure. Rich says Almost twenty years ago I was director of training at a company that implemented an IPM program in a school system in the Cleveland, Ohio area; the first in Ohio and probably most of the country. Most people had never even heard of IPM twenty years ago, including people at the EPA who are big promoters of it, and one of the EPA Region Five people admitted that to me when I confronted him. In reality, it wasn’t really IPM any more than any of these other so-called IPM programs are. They are in reality anti-pesticide programs, because that is what the radicals in the community wanted. That is not IPM. IPM is an agricultural concept…period. The only reason to make such demands is because pesticides, properly applied, are causing health problems. That isn’t just a logical fallacy….it is a factually fallacy. Sam says Your argument here is flawed Rich... I am amazed that you cannot see it.. you would be surprised at what people don't know.. being part of EPA doesn't mean you know this or that.. it depends on exposure and on education. Nor can you impune an agency on the limited anecdotal experience of seeing some individuals who are not well versed.. this is a generalization that would be considered prejudicial in most cases, as if you met a few people of a particular ethnic or racial group and drew a broad conclusion about the group on that limited sample. Rich wrote We may be calling it IPM; but it was not in the past, it is not now, and it will not be in the future. The only reason it exists in structural pest control is because the government says it exists. So spare me any admonition about coming around. I have been around this issue longer than most, including these grant chasers who go around the country promoting it. Sam wrote your prejudice shows through here again Rich... "grant chasers" is about as p;rejudicial as it gets... you expose your hand there very openly... this is another common informal fallacy.. i am sure yuo know it.. it is an ad hominem argument.. Attack the person of your opponent to support your view rather than using logic or facts or reasoning. Rich wrote Based on your comments I wonder if you really understand the concept of “threshold limits”. One thing that is patently obvious; you don’t have a clue as to the origins of IPM, (of which you are so passionate about) nor are you capable of understanding anything that I am saying. Sam wrote Rich,, more ad hominem arguments.... really!!!! it is so transparent.. i think it is you who are taking an ideological stance because of your reaction to regulation of any sort. I understand your words very well as i understand the stand of creationist proponents but i also know the folly of such positions and the unbelievable acrobatics of distortion it takes to argue against such sound p;rinciples. I once had a creationist try to convince me that bombardier beetles were the prime example of why evolution was bunk... the argument being that evolution could not result in creatoin of a system of toxic defense without it being pre-planned by a supreme creator.. Any basic student of biology knows that there are systems of creating strong acids based on cellular processes and of course the bombardier beetle's physiology is known by scientists and the ability for this to have evolved is obvious in context even if the specifics may be more elaborate.. I gave up arguing with that fellow as it was hopeless to teach him. He was so wrapped up in religious dogma that if God himself had come down and told him Darwin was right, he would have questioned if God knew what he was talking about.. Rich, i am done with the argument.; i know what IPM is.;. and | will continue to promote this important concept and methodology, and you can keep pretending it is not so with all kinds of ridiculous convolutions of argument to support your essentially political position. \ the methodology works.. it is a way of thinking.. it is grounded in common sense and we need more people in the industry to think like this... i am a small voice, but others recognize the value and will continue promoting the process and education of all stakeholders.. i apologize to newyorkvsbedbugs for the length here, but it is important that negative arguments intended to destroy valuable reasoned processes must be refuted.. without IPM the situation in pest management is going to get worse, and we have a responsibility to protect people against unprofessional tactics of treatment that were so prevalent before the 80's and are still happening out there every day.............. I hear it every time i speak to a group about bed bug management and people cry about being treated countless times as well as about 10 minute services. If a firm is doing an excellent job at a fair price with responsibility, i don't care if they call it Rich's excellent method. and most likely it will be an IPM approach in all elements regardless of whether Rich just says it is good pest control. I agree with that. IPM is good pest control. Sam Rich, if you don’t mind my calling you by first name and i extend that courtesy to you if you so choose, … i do appreciate the piece on the fallacy of composition. I should have researched this more carefully. I didn’t find it listed on the list i found on the net, so i appeciate the education on that. So, i yield on that point.

Rich said “you have only recently discovered that what you have been doing right along has in reality been IPM. That alone strengthens my argument ”

Sam says.. your point here is completely inaccurate on both statements you make. I never said that I only recently discovered lPM. You misread what i wrote totally.. and it hardly strengthens your argument by any means.
I don’t want to write a four page exposition here again. This is really becoming a lot like arguing with someone who supports creationism as an argument to refute Darwin’s insightful understanding of evolution. I don’t think that cluttering the pages of newyorkvsbedbugs is going to serve the cause.
notwithstanding my accepting that there is indeed a fallacy of composition, i still find your arguments against IPM to be fallacious and empty of value, and steeped in political context and accusations.
the common elements in agricultural and structural ipm are obvious…
knowledge of the pest and its habitat as a requirement…
designing methods of prevention in order to be able to manage the pest cost – effectively .. and the term, “manage” does not suggest that the ideal threshold in strucural should be more zero. I once saw a manual on cockroach control put out by a misiguided and inexperienced health promoter who should have known better, who tried to set an acceptable threshold in homes. I am sure her threshold was zero but she thought she could apply a higher threshold to those less fortunate than herself. Having said that, the reality of thresholds of existing infestation can and are used in structural pest control as part of decision rules for treatment when considering structures with many dwellings. One must understand the distinctions between economic thresholds in agriculture, and thresholds in structural pest control. We don’t do a full building treatment for one infestation of roaches or bed bugs, but decisions can be made about the extent of action — i.e. decision rules.. and this is IPM … no matter how you want to label it as something not applicable to structural.

Rich says
1.IPM is merely pest control and doesn’t truly exist in structural pest control as some different from of structural pest control.

Sam says
Your argument here is that because some things are part of structural pest control, they cannot be fit into an ipm framework. If we define IPM and someone is doing all the things without calling it IPM, it doesn’t mean that we must cease defining it as such. That is a matter of language and does not preclude the definition of the elements. It is as if someone wrote a wonderful novel and used parts of speech and sentence structure that had been defined by a teacher of composition and writing, and someone said that we cannot use the teacher’s definitions of sentence composition because the writer did it on his own without giving it structure of nomenclature..
Using things named that are part of a process does not preclude their being part of the process just the same.
Your interpretation of the fallacy of composition in this regard is flawed and incorrect..
If we say that steps a b c d and e are part of IPM process and someone does all steps but doesn’t call it ipm, it does not mean we must stop calling it ipm..
the reality is that in many many instances a firm may be doing a b and e but not c and d, and then by definition, it is not ipm…
however, if a b and c are teh key elements and d and e are variants, then we can still say it is ipm even if sometimes d and e may not be necessary to achieve the control result…
we can dissect it to pieces, but the main point is that the elements we know and recognize are there,, and if that is the case, then lo and behold.. IT IS IPM

Rich wrote
2. Can’t be properly defined or recognized in a structural pest control situation.

Sam replies
I can define it and have done so for a long time in the structura setting. name a sitaiution and i can put it into that frame work.. Read Marcos Kogan’s definition. Read MY BOOK.. on IPM in Housing

Rich
3. That IPM is so broad as they are attempting to apply it to structural pest control that it allows for IPM to be defined and redefined unendingly to suit some new philosophical flavor of the day.

Sam
there is no such thing as you put it – flavour of the day..ll. .. it is about common sense… and a scientific approach using reasoning… If i know the biology of an insect and find it in a setting, and then understand how it got there and how it is thriving, and find ways to prevenit entry and change habitat or to apply pesticides appropriately… that’s IPM by every measure.

Rich says
Almost twenty years ago I was director of training at a company that implemented an IPM program in a school system in the Cleveland, Ohio area; the first in Ohio and probably most of the country. Most people had never even heard of IPM twenty years ago, including people at the EPA who are big promoters of it, and one of the EPA Region Five people admitted that to me when I confronted him.

In reality, it wasn’t really IPM any more than any of these other so-called IPM programs are. They are in reality anti-pesticide programs, because that is what the radicals in the community wanted. That is not IPM. IPM is an agricultural concept…period. The only reason to make such demands is because pesticides, properly applied, are causing health problems. That isn’t just a logical fallacy….it is a factually fallacy.

Sam says
Your argument here is flawed Rich… I am amazed that you cannot see it.. you would be surprised at what people don’t know.. being part of EPA doesn’t mean you know this or that.. it depends on exposure and on education. Nor can you impune an agency on the limited anecdotal experience of seeing some individuals who are not well versed.. this is a generalization that would be considered prejudicial in most cases, as if you met a few people of a particular ethnic or racial group and drew a broad conclusion about the group on that limited sample.

Rich wrote

We may be calling it IPM; but it was not in the past, it is not now, and it will not be in the future. The only reason it exists in structural pest control is because the government says it exists. So spare me any admonition about coming around. I have been around this issue longer than most, including these grant chasers who go around the country promoting it.

Sam wrote
your prejudice shows through here again Rich… “grant chasers” is about as p;rejudicial as it gets… you expose your hand there very openly… this is another common informal fallacy.. i am sure yuo know it.. it is an ad hominem argument.. Attack the person of your opponent to support your view rather than using logic or facts or reasoning.

Rich wrote
Based on your comments I wonder if you really understand the concept of “threshold limits”. One thing that is patently obvious; you don’t have a clue as to the origins of IPM, (of which you are so passionate about) nor are you capable of understanding anything that I am saying.

Sam wrote
Rich,, more ad hominem arguments…. really!!!!
it is so transparent..
i think it is you who are taking an ideological stance because of your reaction to regulation of any sort. I understand your words very well as i understand the stand of creationist proponents but i also know the folly of such positions and the unbelievable acrobatics of distortion it takes to argue against such sound p;rinciples. I once had a creationist try to convince me that bombardier beetles were the prime example of why evolution was bunk… the argument being that evolution could not result in creatoin of a system of toxic defense without it being pre-planned by a supreme creator.. Any basic student of biology knows that there are systems of creating strong acids based on cellular processes and of course the bombardier beetle’s physiology is known by scientists and the ability for this to have evolved is obvious in context even if the specifics may be more elaborate..
I gave up arguing with that fellow as it was hopeless to teach him. He was so wrapped up in religious dogma that if God himself had come down and told him Darwin was right, he would have questioned if God knew what he was talking about..
Rich, i am done with the argument.; i know what IPM is.;. and | will continue to promote this important concept and methodology, and you can keep pretending it is not so with all kinds of ridiculous convolutions of argument to support your essentially political position. \
the methodology works.. it is a way of thinking.. it is grounded in common sense and we need more people in the industry to think like this… i am a small voice, but others recognize the value and will continue promoting the process and education of all stakeholders..
i apologize to newyorkvsbedbugs for the length here, but it is important that negative arguments intended to destroy valuable reasoned processes must be refuted..
without IPM the situation in pest management is going to get worse, and we have a responsibility to protect people against unprofessional tactics of treatment that were so prevalent before the 80′s and are still happening out there every day………….. I hear it every time i speak to a group about bed bug management and people cry about being treated countless times as well as about 10 minute services.
If a firm is doing an excellent job at a fair price with responsibility, i don’t care if they call it Rich’s excellent method. and most likely it will be an IPM approach in all elements regardless of whether Rich just says it is good pest control. I agree with that.
IPM is good pest control.
Sam

]]> By: Rich Kozlovich http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/comment-page-1/#comment-7535 Rich Kozlovich Sat, 04 Jul 2009 11:50:04 +0000 http://newyorkvsbedbugs.org/?p=2785#comment-7535 Dear Mr. Bryks, First off, I find it remarkable that you have only recently discovered that what you have been doing right along has in reality been IPM. That alone strengthens my argument that: 1.IPM is merely pest control and doesn’t truly exist in structural pest control as some different from of structural pest control. 2. Can’t be properly defined or recognized in a structural pest control situation. 3. That IPM is so broad as they are attempting to apply it to structural pest control that it allows for IPM to be defined and redefined unendingly to suit some new philosophical flavor of the day. Almost twenty years ago I was director of training at a company that implemented an IPM program in a school system in the Cleveland, Ohio area; the first in Ohio and probably most of the country. Most people had never even heard of IPM twenty years ago, including people at the EPA who are big promoters of it, and one of the EPA Region Five people admitted that to me when I confronted him. In reality, it wasn’t really IPM any more than any of these other so-called IPM programs are. They are in reality anti-pesticide programs, because that is what the radicals in the community wanted. That is not IPM. IPM is an agricultural concept…period. The only reason to make such demands is because pesticides, properly applied, are causing health problems. That isn’t just a logical fallacy….it is a factually fallacy. We may be calling it IPM; but it was not in the past, it is not now, and it will not be in the future. The only reason it exists in structural pest control is because the government says it exists. So spare me any admonition about coming around. I have been around this issue longer than most, including these grant chasers who go around the country promoting it. Based on your comments I wonder if you really understand the concept of “threshold limits”. One thing that is patently obvious; you don’t have a clue as to the origins of IPM, (of which you are so passionate about) nor are you capable of understanding anything that I am saying. Your lines of logic are truly amazing. Allow me to expand your views regarding the Fallacy of Composition, which is commonly found among those arguments used to promote irrational green policies, including IPM. Along with the Fallacy: Ignoring a Common Cause, Fallacy: Misleading Vividness, Fallacy: Personal Attack, Fallacy: Poisoning the Well, Fallacy: Post Hoc, Fallacy: Questionable Cause, Fallacy: Red Herring and quite frankly, those who have drunk the Kool-Aid and now live in the Green Fever Swamps violate most of the fallacious arguments. However, those who may be accused of the Fallacy of Doggedness aren’t always incorrect. Fallacy: Composition ________________________________________ Description of Composition The fallacy of Composition is committed when a conclusion is drawn about a whole based on the features of its constituents when, in fact, no justification provided for the inference. There are actually two types of this fallacy, both of which are known by the same name (because of the high degree of similarity). The first type of fallacy of Composition arises when a person reasons from the characteristics of individual members of a class or group to a conclusion regarding the characteristics of the entire class or group (taken as a whole). More formally, the "reasoning" would look something like this. 1. Individual F things have characteristics A, B, C, etc. 2. Therefore, the (whole) class of F things has characteristics A, B, C, etc. This line of reasoning is fallacious because the mere fact that individuals have certain characteristics does not, in itself, guarantee that the class (taken as a whole) has those characteristics. It is important to note that drawing an inference about the characteristics of a class based on the characteristics of its individual members is not always fallacious. In some cases, sufficient justification can be provided to warrant the conclusion. For example, it is true that an individual rich person has more wealth than an individual poor person. In some nations (such as the US) it is true that the class of wealthy people has more wealth as a whole than does the class of poor people. In this case, the evidence used would warrant the inference and the fallacy of Composition would not be committed. The second type of fallacy of Composition is committed when it is concluded that what is true of the parts of a whole must be true of the whole without there being adequate justification for the claim. More formally, the line of "reasoning" would be as follows: 1. The parts of the whole X have characteristics A, B, C, etc. 2. Therefore the whole X must have characteristics A, B, C. That this sort of reasoning is fallacious because it cannot be inferred that simply because the parts of a complex whole have (or lack) certain properties that the whole that they are parts of has those properties. This is especially clear in math: The numbers 1 and 3 are both odd. 1 and 3 are parts of 4. Therefore, the number 4 is odd. It must be noted that reasoning from the properties of the parts to the properties of the whole is not always fallacious. If there is justification for the inference from parts to whole, then the reasoning is not fallacious. For example, if every part of the human body is made of matter, then it would not be an error in reasoning to conclude that the whole human body is made of matter. Similiarly, if every part of a structure is made of brick, there is no fallacy comitted when one concludes that the whole structure is made of brick. Examples of Composition 1. A main battle tank uses more fuel than a car. Therefore, the main battle tanks use up more of the available fuel in the world than do all the cars. 2. A tiger eats more food than a human being. Therefore, tigers, as a group, eat more food than do all the humans on the earth. 3. Atoms are colorless. Cats are made of atoms, so cats are colorless. 4. "Every player on the team is a superstar and a great player, so the team is a great team." This is fallacious since the superstars might not be able to play together very well and hence they could be a lousy team. 5. "Each part of the show, from the special effects to the acting is a masterpiece. So, the whole show is a masterpiece." This is fallacious since a show could have great acting, great special effects and such, yet still fail to "come together" to make a masterpiece. 6. "Come on, you like beef, potatoes, and green beens, so you will like this beef, potato, and green been casserole." This is fallacious for the same reason that the following is fallacious: "You like eggs, ice cream, pizza, cake, fish, jello, chicken, taco sauce, soda, oranges, milk, egg rolls, and yogurt so you must like this yummy dish made out of all of them." 7. Sodium and Chloride are both dangerous to humans. Therefore any combination of sodium and chloride will be dangerous to humans. Regards, Rich Kozlovich, Exterminator Dear Mr. Bryks,

First off, I find it remarkable that you have only recently discovered that what you have been doing right along has in reality been IPM. That alone strengthens my argument that:

1.IPM is merely pest control and doesn’t truly exist in structural pest control as some different from of structural pest control.
2. Can’t be properly defined or recognized in a structural pest control situation.
3. That IPM is so broad as they are attempting to apply it to structural pest control that it allows for IPM to be defined and redefined unendingly to suit some new philosophical flavor of the day.

Almost twenty years ago I was director of training at a company that implemented an IPM program in a school system in the Cleveland, Ohio area; the first in Ohio and probably most of the country. Most people had never even heard of IPM twenty years ago, including people at the EPA who are big promoters of it, and one of the EPA Region Five people admitted that to me when I confronted him.

In reality, it wasn’t really IPM any more than any of these other so-called IPM programs are. They are in reality anti-pesticide programs, because that is what the radicals in the community wanted. That is not IPM. IPM is an agricultural concept…period. The only reason to make such demands is because pesticides, properly applied, are causing health problems. That isn’t just a logical fallacy….it is a factually fallacy.

We may be calling it IPM; but it was not in the past, it is not now, and it will not be in the future. The only reason it exists in structural pest control is because the government says it exists. So spare me any admonition about coming around. I have been around this issue longer than most, including these grant chasers who go around the country promoting it.

Based on your comments I wonder if you really understand the concept of “threshold limits”. One thing that is patently obvious; you don’t have a clue as to the origins of IPM, (of which you are so passionate about) nor are you capable of understanding anything that I am saying.

Your lines of logic are truly amazing.

Allow me to expand your views regarding the Fallacy of Composition, which is commonly found among those arguments used to promote irrational green policies, including IPM. Along with the Fallacy: Ignoring a Common Cause, Fallacy: Misleading Vividness, Fallacy: Personal Attack, Fallacy: Poisoning the Well, Fallacy: Post Hoc, Fallacy: Questionable Cause, Fallacy: Red Herring and quite frankly, those who have drunk the Kool-Aid and now live in the Green Fever Swamps violate most of the fallacious arguments. However, those who may be accused of the Fallacy of Doggedness aren’t always incorrect.

Fallacy: Composition
________________________________________
Description of Composition
The fallacy of Composition is committed when a conclusion is drawn about a whole based on the features of its constituents when, in fact, no justification provided for the inference. There are actually two types of this fallacy, both of which are known by the same name (because of the high degree of similarity).

The first type of fallacy of Composition arises when a person reasons from the characteristics of individual members of a class or group to a conclusion regarding the characteristics of the entire class or group (taken as a whole). More formally, the “reasoning” would look something like this.

1. Individual F things have characteristics A, B, C, etc.
2. Therefore, the (whole) class of F things has characteristics A, B, C, etc.

This line of reasoning is fallacious because the mere fact that individuals have certain characteristics does not, in itself, guarantee that the class (taken as a whole) has those characteristics.

It is important to note that drawing an inference about the characteristics of a class based on the characteristics of its individual members is not always fallacious. In some cases, sufficient justification can be provided to warrant the conclusion. For example, it is true that an individual rich person has more wealth than an individual poor person. In some nations (such as the US) it is true that the class of wealthy people has more wealth as a whole than does the class of poor people. In this case, the evidence used would warrant the inference and the fallacy of Composition would not be committed.

The second type of fallacy of Composition is committed when it is concluded that what is true of the parts of a whole must be true of the whole without there being adequate justification for the claim. More formally, the line of “reasoning” would be as follows:

1. The parts of the whole X have characteristics A, B, C, etc.
2. Therefore the whole X must have characteristics A, B, C.

That this sort of reasoning is fallacious because it cannot be inferred that simply because the parts of a complex whole have (or lack) certain properties that the whole that they are parts of has those properties. This is especially clear in math: The numbers 1 and 3 are both odd. 1 and 3 are parts of 4. Therefore, the number 4 is odd.

It must be noted that reasoning from the properties of the parts to the properties of the whole is not always fallacious. If there is justification for the inference from parts to whole, then the reasoning is not fallacious. For example, if every part of the human body is made of matter, then it would not be an error in reasoning to conclude that the whole human body is made of matter. Similiarly, if every part of a structure is made of brick, there is no fallacy comitted when one concludes that the whole structure is made of brick.

Examples of Composition

1. A main battle tank uses more fuel than a car. Therefore, the main battle tanks use up more of the available fuel in the world than do all the cars.

2. A tiger eats more food than a human being. Therefore, tigers, as a group, eat more food than do all the humans on the earth.

3. Atoms are colorless. Cats are made of atoms, so cats are colorless.

4. “Every player on the team is a superstar and a great player, so the team is a great team.” This is fallacious since the superstars might not be able to play together very well and hence they could be a lousy team.

5. “Each part of the show, from the special effects to the acting is a masterpiece. So, the whole show is a masterpiece.” This is fallacious since a show could have great acting, great special effects and such, yet still fail to “come together” to make a masterpiece.

6. “Come on, you like beef, potatoes, and green beens, so you will like this beef, potato, and green been casserole.” This is fallacious for the same reason that the following is fallacious: “You like eggs, ice cream, pizza, cake, fish, jello, chicken, taco sauce, soda, oranges, milk, egg rolls, and yogurt so you must like this yummy dish made out of all of them.”

7. Sodium and Chloride are both dangerous to humans. Therefore any combination of sodium and chloride will be dangerous to humans.

Regards,

Rich Kozlovich, Exterminator

]]> By: sam bryks http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/comment-page-1/#comment-7491 sam bryks Thu, 02 Jul 2009 20:27:03 +0000 http://newyorkvsbedbugs.org/?p=2785#comment-7491 Dear Rich, I apologize for misspelling your name. It was an accident in the heat of furious keyboarding. My reference to pigheaded was an actual fallacy of argument, and if it applied by context, as I perceive your flawed argument and no actual fallacy of composition that i could find, it was in the form of how arguments sometimes go. Churchill was famous for his quips, and I am afraid that I am not up to his capabilties in that aspect, but i do try. There is a difference of course between the fallacy of pigheadeness and one of standing up for principles and facts. When Banting and Best presented their findings about insulin and diabetes in the British Medical Journal, one of the most famous members of the American Diabetic Society, a former president of that august body, dismissed their findings as nonsense. Sadly, all he accomplished was to make himself a fool in his reaction to these two Canadian upstarts working out of a hot attic in the University of Toronto with very limited funds making one of the most dramatic medical breakthroughs of the 20th century. They were certainly not pigheaded. We need to be clear about the distinction between fighting for a solid grounded concept based in facts and resisting reality. This is not pig headedness as you would describe it. It may have stubbornness in it, but not pigheadedness. And there is a distinction between courage and folly. Folly is to die for nothing. Courage is to risk death for high ideals. Many would argue against your principle of comparing terminology of IPM in agriculture to that in Structural pest control and say one is and one isn't IPM. There are thresholds in structural as well.. The threshold in a unit should always zero, but realistically, a threshold in a building as an ideal of zero is great, but practically it is often never achieved such as in roach control. And this can vary from type of structure to type of structure depending on a variety of conditions, but to say that IPM doesn't exist in structural pest control remains nonsense in my view. I have used it, done it practiced it.. with numbers and calculations and demonstrable results. Let's be clear about this. Your argument is a pure fallacy -- and just because one situation is different than another in practical terms (i.e. agriculture vs structural pest control) does not mean that the concept and the practices of IPM cannot be applied. Your calling LIncoln as an authority on nomenclature is funny of course. But if something looks like a tail and is used for support, just because it is a tail doesn't mean it can't be used for support. The kangaroo is a good example of a tail being used as something like a leg..... not a leg, but sort of like a leg.. In the case of IPM in structural pest control, it is not like IPM -- IT IS IPM. not dependency on pesticides along, but using various methods as defined in IPM.. and assessment and inspecitons, and evaluations.. all elements of IPM.. Hey Rich, if it has 99% of the features of IPM , perhaps you might concede it is IPM. After all, an 8 x 10 view camera as used by Ansel Adams was a camera... It used huge negatives and was made of wood.. but it was a camera.. The new cameras don't even use film as such and have zero wood in them, but THEY ARE STILL CAMERAS..... THEY TAKE PICTURES.. AND IPM is intended to do smart pest management and reduce use of pesticides.. This is a logical and balanced argument and it refutes your denial quite fully an completely.. Live with it.. It is not an ideology.. It is a professional practice with methodology. Your argument is mostly ideology and little methodology and it is not logical. This is not child's play RIch. I have been at this too long and studied it and learned from field experience to allow you to demean the concept and the philosophy. Not ideology.. though we could argue what ideology actually means. It has the meaning of an idee fixee, as in those who would argue the point beyond reason, or it is a belief system grounded in reason. If we take ideology in the context of religious ideals, or moral positions based on fixed sources such as biblical references, then you can have ideology at worse.. and at extreme that is what fascism was about. Half baked bad ideas outside of moral consideration, and grounded in a kind of pseudo-Darwinian survival of the fittest interpretation. We don't want to revert to that kind of horrible ideological bent, but base arguments on facts and on results and on best practices intended, as in Marcos great definition of IPM, to benefit society and the environment. That should be the ideal. Do the best we can, and do no harm as much as we can, except of course to eliminate organisms that threaten our well being . your reference ot pest control practices in the 1950's and prior to the 70's is unrealistic for the most part (not entirely). The olden days you refer to had little or no education of the public, except perhaps in isolated cases as driven by the very authorities you vilify. The food protection acts in Britain and the U.S. were driven by poisoning as was the urgency of managing water due to a typhus outgreak in London England back in the 1600's or 1700's. Driven by scientists who proved the risks and by legislation to ensure protection was afforded the public. Certainly the NPCA set standards and ideals starting at hte beginning, but if you know the industry, many many firms did not follow these practices very well. A lot of lip service. I know this factually. I have seen it close up.. so please don't preach to me about how Pest Control embraces all these elements and we can't called it Integrated Pest Management. Spraying of pesticides in schools did not include the elements you preach about classical peset control and IPM DOES!~ Why were the methods so terrible? The reason is driven by money.. Low quotes for public housing pest control. and the result was repetitive spraying. REALITY... that is fact.. no argument.. it takes principles of IPM to change that.. and it is slowly happening all over the place..... in spite of your really silly claims here.. Get real Rich.... your argument is devoid of logic and is fallacious by more informal fallacies than i have time to present here. I don't argue the benefits of longer life in our society, but this has to be seen in the bigger context.. It is about regulation of food, and of good water, and of destruction of vectors .. pest control has been a very major part of this.. no doubt of that whatsoever, but it comes back to the risk / benefit aspect. There is a risk to polio vaccine, but the risk of polio is greater.. Now we don't have polio in North America or Europe, no one is getting the vaccine.. NO ONE.. The same applies to applicaitons of pesticide.. it is a matter of when and why and how.... and if we can reduce risk.. and gain benefit.. great!!!! the risk of malaria remains high, but this is not so much from discontinuation from use of DDT as the mosquitoes were developing resistance, as it is more making netting available, and dealing with breeding sites, and also due to resistance of the parasite itself to medicaiton and in some cases, not having treatment available due to economic considerations. It is not the simplistic argument about reduction in use of some pesticides or DDT as some would like to make histrionics about.. There are classic approaches to IPM in structural pest control and well known... no point in teaching it to you here.. I don't have the time. I have never heard a proponent of IPM from EPA or respected researchers say .. IPM is about getting rid of pesticides altogether, but if i have a situation in which i can achieve control without pesticides, believe me I will do it and not use pesticides as a matter of GOOD PRACTICE.. and there are quite a few situations like that.. I have heard complaints about regulations for a long time. And my point about Rachel Carson remains.. Time Magazine considered her to be one of themost significant people in the world in the 20th century and recognized her for her achievements in alerting to risk and I respect her for that ... The industry rants about her are so low and stupid as to be almost unimaginable.. Let it go... she's been dead for 40 years and more people respect her than not.. She will remain an icon for common sense and sensibiity and a supporter of use of pesticides within the context of the risk management assessment. There are loads of horror stories about industry causing damages to people. Look at MInimata and Erin Brocovitch.. real stories.. Let's not have our industry in that bad light.. We need to have proper stewardship of use and sensibility and the framework is IPM... i know you don't like it, but get used to it.. it is the way of the future, and it is how we will get the bed bug situation under control. Pesticides are only part of the total picture.. Your use of the Chamberlain Quisling Churchill metaphor was demagoguery and if that ain't politics, I don't know what is. You want to characterize your opponents with these labels rather than face the reality of sound and strong irrefutable arguments.. Just take your medicine and learn Rich. I did err in the Bugs Burger story.. My point is that at the time, he did all he had to do to solve the problem in the absence of other approaches, but he made the client responsible. I do not subscribe to his methods today, but I remember him chiding the industry for their bs practices in not solving the problem and being fully accountable and making the client accountable. I think some are doing that in hotel bed bug management because of the risk to business and threat of litigation. I will be happy to check out your web site once more. I did once to see the argument against IPM that REnee had told me you held, and I felt then that this was a nonsensical argument, though I did respect a lot of the material about ecosystems. I have been practicing IPM in structural pest control now for about 28 years, though perhaps I didn't take on the term until about 4 or 5 years into my career in pest management, but I used the concept in my work and i faced lots of hot situations and my fortune in having a good education in science and some wonderful teachers enabled me to use common sense and sound reasoning in solving pest problems without playing the blame game that is sometimes the common practice in this industry.. client blames company and company blames client. I still see that happening,. It is about accountabilty.. and doing the right thing.. When i present facts to clients about a situation or to contractors.. such as why a rat infestation got into structure, it is based on facts.. and on who should have done what, and why not, and how to solve the problem now as quickly as possible. and then a learned lesson for all...... because the lesson learned is part of the education of IPM... the frame work of it works in structural pest control most wonderfully and it is a strong concept supported by many smart people.. You can join Rich.. not too late.. Sam Dear Rich,
I apologize for misspelling your name. It was an accident in the heat of furious keyboarding.
My reference to pigheaded was an actual fallacy of argument, and if it applied by context, as I perceive your flawed argument and no actual fallacy of composition that i could find, it was in the form of how arguments sometimes go. Churchill was famous for his quips, and I am afraid that I am not up to his capabilties in that aspect, but i do try.
There is a difference of course between the fallacy of pigheadeness and one of standing up for principles and facts. When Banting and Best presented their findings about insulin and diabetes in the British Medical Journal, one of the most famous members of the American Diabetic Society, a former president of that august body, dismissed their findings as nonsense. Sadly, all he accomplished was to make himself a fool in his reaction to these two Canadian upstarts working out of a hot attic in the University of Toronto with very limited funds making one of the most dramatic medical breakthroughs of the 20th century. They were certainly not pigheaded. We need to be clear about the distinction between fighting for a solid grounded concept based in facts and resisting reality. This is not pig headedness as you would describe it. It may have stubbornness in it, but not pigheadedness.
And there is a distinction between courage and folly. Folly is to die for nothing. Courage is to risk death for high ideals.
Many would argue against your principle of comparing terminology of IPM in agriculture to that in Structural pest control and say one is and one isn’t IPM.
There are thresholds in structural as well.. The threshold in a unit should always zero, but realistically, a threshold in a building as an ideal of zero is great, but practically it is often never achieved such as in roach control. And this can vary from type of structure to type of structure depending on a variety of conditions, but to say that IPM doesn’t exist in structural pest control remains nonsense in my view. I have used it, done it practiced it.. with numbers and calculations and demonstrable results. Let’s be clear about this.
Your argument is a pure fallacy — and just because one situation is different than another in practical terms (i.e. agriculture vs structural pest control) does not mean that the concept and the practices of IPM cannot be applied.
Your calling LIncoln as an authority on nomenclature is funny of course. But if something looks like a tail and is used for support, just because it is a tail doesn’t mean it can’t be used for support. The kangaroo is a good example of a tail being used as something like a leg….. not a leg, but sort of like a leg..
In the case of IPM in structural pest control, it is not like IPM — IT IS IPM.
not dependency on pesticides along, but using various methods as defined in IPM.. and assessment and inspecitons, and evaluations.. all elements of IPM..
Hey Rich, if it has 99% of the features of IPM , perhaps you might concede it is IPM. After all, an 8 x 10 view camera as used by Ansel Adams was a camera… It used huge negatives and was made of wood.. but it was a camera.. The new cameras don’t even use film as such and have zero wood in them, but THEY ARE STILL CAMERAS….. THEY TAKE PICTURES.. AND IPM is intended to do smart pest management and reduce use of pesticides.. This is a logical and balanced argument and it refutes your denial quite fully an completely.. Live with it..
It is not an ideology.. It is a professional practice with methodology. Your argument is mostly ideology and little methodology and it is not logical. This is not child’s play RIch. I have been at this too long and studied it and learned from field experience to allow you to demean the concept and the philosophy. Not ideology.. though we could argue what ideology actually means. It has the meaning of an idee fixee, as in those who would argue the point beyond reason, or it is a belief system grounded in reason. If we take ideology in the context of religious ideals, or moral positions based on fixed sources such as biblical references, then you can have ideology at worse.. and at extreme that is what fascism was about. Half baked bad ideas outside of moral consideration, and grounded in a kind of pseudo-Darwinian survival of the fittest interpretation. We don’t want to revert to that kind of horrible ideological bent, but base arguments on facts and on results and on best practices intended, as in Marcos great definition of IPM, to benefit society and the environment. That should be the ideal. Do the best we can, and do no harm as much as we can, except of course to eliminate organisms that threaten our well being .
your reference ot pest control practices in the 1950′s and prior to the 70′s is unrealistic for the most part (not entirely). The olden days you refer to had little or no education of the public, except perhaps in isolated cases as driven by the very authorities you vilify. The food protection acts in Britain and the U.S. were driven by poisoning as was the urgency of managing water due to a typhus outgreak in London England back in the 1600′s or 1700′s. Driven by scientists who proved the risks and by legislation to ensure protection was afforded the public.
Certainly the NPCA set standards and ideals starting at hte beginning, but if you know the industry, many many firms did not follow these practices very well. A lot of lip service. I know this factually. I have seen it close up.. so please don’t preach to me about how Pest Control embraces all these elements and we can’t called it Integrated Pest Management. Spraying of pesticides in schools did not include the elements you preach about classical peset control and IPM DOES!~
Why were the methods so terrible? The reason is driven by money.. Low quotes for public housing pest control. and the result was repetitive spraying. REALITY…
that is fact.. no argument.. it takes principles of IPM to change that.. and it is slowly happening all over the place….. in spite of your really silly claims here.. Get real Rich…. your argument is devoid of logic and is fallacious by more informal fallacies than i have time to present here.
I don’t argue the benefits of longer life in our society, but this has to be seen in the bigger context.. It is about regulation of food, and of good water, and of destruction of vectors .. pest control has been a very major part of this.. no doubt of that whatsoever, but it comes back to the risk / benefit aspect. There is a risk to polio vaccine, but the risk of polio is greater.. Now we don’t have polio in North America or Europe, no one is getting the vaccine.. NO ONE..
The same applies to applicaitons of pesticide.. it is a matter of when and why and how…. and if we can reduce risk.. and gain benefit.. great!!!!
the risk of malaria remains high, but this is not so much from discontinuation from use of DDT as the mosquitoes were developing resistance, as it is more making netting available, and dealing with breeding sites, and also due to resistance of the parasite itself to medicaiton and in some cases, not having treatment available due to economic considerations. It is not the simplistic argument about reduction in use of some pesticides or DDT as some would like to make histrionics about..

There are classic approaches to IPM in structural pest control and well known…
no point in teaching it to you here.. I don’t have the time.
I have never heard a proponent of IPM from EPA or respected researchers say .. IPM is about getting rid of pesticides altogether, but if i have a situation in which i can achieve control without pesticides, believe me I will do it and not use pesticides as a matter of GOOD PRACTICE.. and there are quite a few situations like that..
I have heard complaints about regulations for a long time. And my point about Rachel Carson remains.. Time Magazine considered her to be one of themost significant people in the world in the 20th century and recognized her for her achievements in alerting to risk and I respect her for that … The industry rants about her are so low and stupid as to be almost unimaginable.. Let it go… she’s been dead for 40 years and more people respect her than not..
She will remain an icon for common sense and sensibiity and a supporter of use of pesticides within the context of the risk management assessment. There are loads of horror stories about industry causing damages to people. Look at MInimata and Erin Brocovitch.. real stories.. Let’s not have our industry in that bad light.. We need to have proper stewardship of use and sensibility and the framework is IPM… i know you don’t like it, but get used to it.. it is the way of the future, and it is how we will get the bed bug situation under control. Pesticides are only part of the total picture..
Your use of the Chamberlain Quisling Churchill metaphor was demagoguery and if that ain’t politics, I don’t know what is. You want to characterize your opponents with these labels rather than face the reality of sound and strong irrefutable arguments.. Just take your medicine and learn Rich.
I did err in the Bugs Burger story.. My point is that at the time, he did all he had to do to solve the problem in the absence of other approaches, but he made the client responsible. I do not subscribe to his methods today, but I remember him chiding the industry for their bs practices in not solving the problem and being fully accountable and making the client accountable. I think some are doing that in hotel bed bug management because of the risk to business and threat of litigation.
I will be happy to check out your web site once more. I did once to see the argument against IPM that REnee had told me you held, and I felt then that this was a nonsensical argument, though I did respect a lot of the material about ecosystems.
I have been practicing IPM in structural pest control now for about 28 years, though perhaps I didn’t take on the term until about 4 or 5 years into my career in pest management, but I used the concept in my work and i faced lots of hot situations and my fortune in having a good education in science and some wonderful teachers enabled me to use common sense and sound reasoning in solving pest problems without playing the blame game that is sometimes the common practice in this industry.. client blames company and company blames client. I still see that happening,. It is about accountabilty.. and doing the right thing.. When i present facts to clients about a situation or to contractors.. such as why a rat infestation got into structure, it is based on facts.. and on who should have done what, and why not, and how to solve the problem now as quickly as possible. and then a learned lesson for all…… because the lesson learned is part of the education of IPM…
the frame work of it works in structural pest control most wonderfully and it is a strong concept supported by many smart people..
You can join Rich.. not too late..
Sam

]]> By: Rich Kozlovich http://newyorkvsbedbugs.org/2009/05/24/blaming-epa-is-not-the-answer-either/comment-page-1/#comment-7489 Rich Kozlovich Thu, 02 Jul 2009 19:13:17 +0000 http://newyorkvsbedbugs.org/?p=2785#comment-7489 Dear Mr. Bryks, First of all my name is spelled with a “z” not an “s”. As for being pigheaded or dogged….well, perhaps that is in the eyes of the beholder; history is replete with dogged pigheaded people who have stood against the tide and have been proven right by the greatest test of them all…time. If they are wrong; then time will prove that out also. The only thing that we already know for sure is that one will be called courageous and the other a fool! I am willing to stand that test and take my chances. The only area in which IPM is a methodology is in agriculture and it is too expensive to practice there. Once again….it doesn’t exist in structural pest control because IPM is based on threshold limits and the threshold limit in structures is zero. Abraham Lincoln once asked; if you call a tail a leg how many legs does a dog have? He said the correct answer was four because calling a tail a leg doesn’t change the fact that it is still a tail. Calling various techniques in structural pest control IPM doesn’t make it IPM. IPM in structural pest control is an ideology…it is not a methodology. Monitoring, understanding the pests environment, educating the customer, and practical applications of pesticides has always been a part of pest control going back to the 1850’s. That is pest control, it is not IPM. As for the “old terrible methods” of treatment…..Why were they so terrible? Pesticides brought about advances in the human condition that can’t be praised enough. We live longer. We are healthier. We have better conditions than ever before in human history and pesticides have been a major part of that story. The only areas of the world that live in dystopia are those areas of the world where pesticides and the progress that pesticides and technology bring are not being practiced, and many times because of following greenie policies. . As for saying that I said anything about monitoring, alternative methods, repair, public education or any of the other tools of pest control not working; either you are being obtuse or deliberately misrepresenting my views. What I say is that this isn’t IPM…it is pest control, and there is no such thing as “classic rules” for IPM unless it is being practiced in agriculture. If these alleged rules were so “classical” then there wouldn’t have been so many definitions from so many different sources. Every state that requires IPM standards goes through this process of trying to define IPM and what it means! Why is that so if the rules are so “classical”? I have been a part of this process myself, and there is a reason for that. Simply stated; IPM is not a structural pest control concept….it is an agricultural concept. Let’s not lose sight of reality. The whole purpose and the goal of those pushing IPM is to encourage the elimination of pesticides by being able to say “we don’t need pesticides because we have IPM.” And that isn’t irrational or ludicrous; that is a fact. As for using Mike Potter as my authority…the only reason I brought Mike into this conversation is because you already had done so by saying; (“Sorry i forget to mention Richard Cooper, Michael Potter, and so many others who are working on better solutions and sharing knowledge of research on bed bug biology.”) inferring that he didn’t think that the elimination of certain pesticides by EPA was the problem. It is true that Mike is working on solutions, but that doesn’t mean that he doesn’t understand reality. As for the idea that history has shown that industry has shown a resistance to regulations infers that industry is wrong and the bureaucrats are right. Resistance to folly doesn’t make folly right, and Rachel Carson deserved the vilification she received from the industry. The rationale regarding Chamberlain, Quisling and Churchill has nothing to do with politics, it is an historical illustration to demonstrate that every organization, including pest control, is filled with appeasers, traitors and defenders and that everyone one of us fits into one of those categories. How did this illustration become “politics” to you? But to then go on to suggest that politics has no place in this discussion is irrational. Politics by the greenies and their acolytes in government and industry is behind this entirely; not science. And for someone to point this out is absolutely germane to the whole story of modern pest control. I am not quite sure why Bugs Burger enters into this conversation because he was very successful in eliminating pests with his approach, which undermines your argument about old pesticide application techniques not working. And Orkin didn’t buy him out, it was Johnson Wax who did and changed the name to Prism. They then later sold it to Orkin. We seem to have a problem of determining risk levels here. Misapplication of pesticides can put everyone in risk, not just children, but that risk is miniscule compared to the risk of eliminating pesticides, which will put everyone, including children, at a far greater risk. As for the “drivel” and lack of science that you claim that I spew out….I invite everyone to visit my blog. Paradigms and Demographics, (just Google it…it will come up first on the list) and determine for themselves as to whether my views are unfounded or not. One thing said by you that I am sure is correct. You have never heard of the fallacy of composition. Rich Kozlovich, Exterminator Dear Mr. Bryks,

First of all my name is spelled with a “z” not an “s”. As for being pigheaded or dogged….well, perhaps that is in the eyes of the beholder; history is replete with dogged pigheaded people who have stood against the tide and have been proven right by the greatest test of them all…time. If they are wrong; then time will prove that out also. The only thing that we already know for sure is that one will be called courageous and the other a fool! I am willing to stand that test and take my chances.

The only area in which IPM is a methodology is in agriculture and it is too expensive to practice there. Once again….it doesn’t exist in structural pest control because IPM is based on threshold limits and the threshold limit in structures is zero. Abraham Lincoln once asked; if you call a tail a leg how many legs does a dog have? He said the correct answer was four because calling a tail a leg doesn’t change the fact that it is still a tail. Calling various techniques in structural pest control IPM doesn’t make it IPM.

IPM in structural pest control is an ideology…it is not a methodology. Monitoring, understanding the pests environment, educating the customer, and practical applications of pesticides has always been a part of pest control going back to the 1850’s. That is pest control, it is not IPM.

As for the “old terrible methods” of treatment…..Why were they so terrible? Pesticides brought about advances in the human condition that can’t be praised enough. We live longer. We are healthier. We have better conditions than ever before in human history and pesticides have been a major part of that story. The only areas of the world that live in dystopia are those areas of the world where pesticides and the progress that pesticides and technology bring are not being practiced, and many times because of following greenie policies. .

As for saying that I said anything about monitoring, alternative methods, repair, public education or any of the other tools of pest control not working; either you are being obtuse or deliberately misrepresenting my views. What I say is that this isn’t IPM…it is pest control, and there is no such thing as “classic rules” for IPM unless it is being practiced in agriculture. If these alleged rules were so “classical” then there wouldn’t have been so many definitions from so many different sources.

Every state that requires IPM standards goes through this process of trying to define IPM and what it means! Why is that so if the rules are so “classical”? I have been a part of this process myself, and there is a reason for that. Simply stated; IPM is not a structural pest control concept….it is an agricultural concept. Let’s not lose sight of reality. The whole purpose and the goal of those pushing IPM is to encourage the elimination of pesticides by being able to say “we don’t need pesticides because we have IPM.” And that isn’t irrational or ludicrous; that is a fact.

As for using Mike Potter as my authority…the only reason I brought Mike into this conversation is because you already had done so by saying; (“Sorry i forget to mention Richard Cooper, Michael Potter, and so many others who are working on better solutions and sharing knowledge of research on bed bug biology.”) inferring that he didn’t think that the elimination of certain pesticides by EPA was the problem. It is true that Mike is working on solutions, but that doesn’t mean that he doesn’t understand reality.

As for the idea that history has shown that industry has shown a resistance to regulations infers that industry is wrong and the bureaucrats are right. Resistance to folly doesn’t make folly right, and Rachel Carson deserved the vilification she received from the industry. The rationale regarding Chamberlain, Quisling and Churchill has nothing to do with politics, it is an historical illustration to demonstrate that every organization, including pest control, is filled with appeasers, traitors and defenders and that everyone one of us fits into one of those categories. How did this illustration become “politics” to you? But to then go on to suggest that politics has no place in this discussion is irrational. Politics by the greenies and their acolytes in government and industry is behind this entirely; not science. And for someone to point this out is absolutely germane to the whole story of modern pest control.

I am not quite sure why Bugs Burger enters into this conversation because he was very successful in eliminating pests with his approach, which undermines your argument about old pesticide application techniques not working. And Orkin didn’t buy him out, it was Johnson Wax who did and changed the name to Prism. They then later sold it to Orkin.

We seem to have a problem of determining risk levels here. Misapplication of pesticides can put everyone in risk, not just children, but that risk is miniscule compared to the risk of eliminating pesticides, which will put everyone, including children, at a far greater risk. As for the “drivel” and lack of science that you claim that I spew out….I invite everyone to visit my blog. Paradigms and Demographics, (just Google it…it will come up first on the list) and determine for themselves as to whether my views are unfounded or not. One thing said by you that I am sure is correct. You have never heard of the fallacy of composition.

Rich Kozlovich, Exterminator

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