United States       Prevention, Pesticides     EPA712-C-98-424
          Environmental Protection    and Toxic Substances     March 1998
          Agency         (7101)
4»EPA    Product Performance
          Test Guidelines
          OPPTS 810.3600
          Structural Treatments

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                           INTRODUCTION
     This guideline is one  of a  series  of test  guidelines that have been
developed by the Office of Prevention, Pesticides and Toxic Substances,
United States Environmental  Protection Agency for use  in the testing of
pesticides and toxic substances, and the  development of test data that must
be submitted to the Agency  for review under Federal regulations.

     The Office of Prevention, Pesticides and Toxic Substances (OPPTS)
has  developed this guideline through  a process of harmonization that
blended the testing  guidance  and requirements that  existed in the Office
of Pollution Prevention and  Toxics  (OPPT) and appeared in Title  40,
Chapter I,  Subchapter R of the Code of Federal Regulations  (CFR),  the
Office of Pesticide Programs (OPP) which appeared in publications of the
National Technical  Information Service (NTIS) and the guidelines pub-
lished by the Organization  for Economic Cooperation and Development
(OECD).

     The purpose of harmonizing these  guidelines  into a single set of
OPPTS  guidelines is to minimize variations among the testing procedures
that must be performed to meet the data  requirements of the U. S. Environ-
mental Protection Agency  under the Toxic  Substances  Control Act  (15
U.S.C. 2601) and the Federal Insecticide, Fungicide and Rodenticide Act
(7U.S.C. I36,etseq.).

     Final  Guideline Release: This guideline  is available from the U.S.
Government Printing Office, Washington, DC 20402 on The Federal Bul-
letin  Board.   By  modem  dial   202-512-1387,  telnet   and   ftp:
fedbbs.access.gpo.gov  (IP 162.140.64.19), or  call 202-512-0132 for disks
or paper copies.  This  guideline is also available electronically in ASCII
and PDF (portable document format) from EPA's World Wide Web  site
(http://www.epa.gov/epahome/research.htm) under the heading "Research-
ers and  Scientists/Test Methods and Guidelines/OPPTS  Harmonized Test
Guidelines."

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OPPTS 810.3600   Structural treatments.
     (a) Scope—(1) Applicability. This guideline is intended to meet test-
ing requirements of the Federal Insecticide, Fungicide, and Rodenticide
Act (FIFRA) (7 U.S.C. 136, et seq.)

     (2) Background. The source material used in developing this har-
monized OPPTS test guideline  is OPP guideline  95-12  Structural  treat-
ments (Pesticide Assessment  Guidelines, Subdivision G: Product Perform-
ance, EPA report 540/9-82-026, October 1982).

     (b) Overview. This guideline concerns the guidance  on efficacy data
for evaluation of invertebrate control pesticides used to control pests such
as termites,  wood-destroying beetles, wharf borer, carpenter ant,  and car-
penter bee in structures such as buildings,  structural members,  and stored
lumber.

     (c) General considerations—(1) Site selection.  When selecting an
application  site  for testing invertebrate  control agents against  structural
pests, such  factors as temperature, humidity, moisture,  soil texture, and
freezing-thawing conditions should be considered and reported.

     (2) Number  of trials. A minimum of 3 large-scale geographically-
separated  trials are generally necessary, but the number of trials can vary
somewhat due to the accessibility of infestations, fluctuations in pest popu-
lation pressures, behavior,  and  other important considerations in the biol-
ogy of the target pest.

     (3) Residual  considerations. The soil residual potential for termite
control products is important in determining the length of time that such
pesticides will be  effective, and is measured by the time over which the
toxic barrier resists penetration. Soil  treatments require that special care
be exercised to  assure that water supplies  are not contaminated  with the
pesticide and that the treatment does not cause intolerable injury to build-
ing foundations, plants, shrubs, and other ornamental plants.

     (4) Application  techniques and  equipment. Data should be devel-
oped to support the use of pressurized, impregnation, or other specialized
types of application equipment:

     (5) Evaluation and reporting procedures—(i) General. The proce-
dures used to evaluate product performance should be specified in the data.
Reports should include  insect counts, amount of damage, or to the meas-
ures  of determining  the  effectiveness  of the test product. Results should
include  the  average infestation reduction  throughout the sampled  post-
treatment  period compared with that in untreated controls. Data  on pest
counts or  other measures of control should be summarized. The  test data
should indicate that there are no adverse effects such as warping  or  stain-
ing to wallpaper, paint,  tile,  varnish, or other surfaces if they are  likely
to be contacted by the product  when applied according to label directions

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for use. The data should also indicate that the  material does not impart
long-lasting objectionable  odors  to furniture, cabinets, or other indoor
treatment sites which may be specified on the label.

     (ii) Subterranean termites. Subterranean termite attacks in a struc-
ture are prevented or controlled through impregnation of soil with a termite
toxicant beneath  and adjacent to the structure.  Protection  of wood from
attack by subterranean termites may also be provided by impregnation of
the wood by a termite toxicant.

     (iii) Dampwood termites. Dampwood termites are evaluated by the
same procedures that are practical for the control of subterranean termites.

     (iv) Drywood termites. Drywood termites  are controlled by fumiga-
tion or treatment of channels with dusts,  liquids, or spot fumigants for
the elimination of drywood termites and should be evaluated by observing
the effect of such treatments under field conditions. Absorptive dusts have
been used  as  a protective barrier treatment and should be evaluated  on
this basis in field treatments.

     (d)  Specific  considerations  and  suggested  performance  stand-
ards—(1) Subterranean termites are by far  the most important struc-
tural pests. These insects damage wood and other cellulosic building ma-
terials causing major property damage particularly in the  southern areas
of the United  States. Control procedures usually are reflective of the fact
that colonies of these termites require  contact  with the soil as opposed
to drywood or dampwood termites which may exist independently of soil
moisture.

     (i) Preventive treatments—soil barriers—(A) Data considerations.
Subterranean termite  attacks in a  structure are prevented or  controlled
through toxicant impregnation of the soil beneath and adjacent to the struc-
ture. Data  should indicate that the treatment  does not cause intolerable
injury to building foundations, plants, shrubs, or  to other ornamentals. The
effectiveness of prophylactic termite treatments  is measured by the time
over which the toxic  barrier remains effective in resisting  penetration  by
the termites. Therefore, the efficacy data should  indicate the establishment
and maintenance of this toxic barrier.

     (B)  Test methods.  Published laboratory methods are not currently
recognized by the Agency as giving a reliable  evaluation of soil toxicants
for termite control, but three field tests are  recognized as giving a reliable
evaluation  of soil toxicants: The Stake method, the Ground board method,
and the Modified  ground board method.

     (C) Suggested performance standards. Data derived from such test-
ing should provide complete resistance to  termite attack for a period of
5 years, based upon annual reinspection. The tests should be in geographic

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areas which  provide  year-around pest pressure (usually in the  southern
U.S.).

     (ii) Preventive treatment—wood impregnation—(A) Data consid-
erations. Subterranean termite damage in a structure is also prevented by
treatment of susceptible materials. Those treatments are applied  as dips,
brush-on applications, sprays, or pressure treatments. The activity of the
materials is such that damage  to the  treated cellulosic  substance is pre-
cluded or reduced either because the treated material is toxic upon inges-
tion or sufficiently repellent that ingestion does not occur.  The effective-
ness of such treatments  is determined by a measurement of the duration
for which the treated material resists termite attack.

     (B) Test methods. Modifications  of the Stake method,  Ground board
method, and Modified ground board method are acceptable in evaluating
impregnated wood products.

     (C)  Suggested performance  standards. When acceptable  data  de-
rived from testing for at least 2 years but less than 5 years  shows a com-
plete resistance to termite attack, the product may be registered contingent
upon a  restriction which specifies annual reinspection.  The tests should
be conducted in geographic areas which provide year round pest pressure
(usually in  southern U.S.).

     (iii) Infested sites—(A) Data considerations. Data should be derived
from experiments  utilizing field  infestations.  These experiments  must
evaluate the effects of the treatment as related to the infested site.

     (B) Test methods. [Reserved]

     (C)  Suggested performance standards. Data should indicate  not
only that the insects are killed, but that those insects in  egg and nymphal
instars at the time of treatment  will be controlled either by immediate or
residual toxicity. The data  should clearly indicate that the entire colony
is  destroyed by isolation from the essential water source by the establish-
ment of a pesticidal barrier, through the penetration of all wood galleries
by the pesticide, or by both routes.

     (2) Dampwood  termites  and drywood termites.  Dampwood ter-
mites may  exist in  structural members where a water source is constantly
available to the colony due to faulty plumbing, roof leaks, or other factors.
Drywood termites can colonize  in wood or other cellulosic  substances re-
gardless of any apparent water source, since they are capable of metaboliz-
ing sufficient moisture from the materials they ingest. For this reason,  ap-
plications of pesticides for the control  of these pests are  usually preventa-
tive or eradicant treatments of actual infested material. These wood treat-
ments generally parallel those  for subterranean termites, and paragraphs
(d)(l)(ii) and (d)(l)(iii) of this guideline address the data considerations,

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testing procedures, and performance standards which are  also applicable
to compounds used against dampwood and drywood termites.

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