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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