Questions for the Panel1) The draft Guidelines are organized around three types of tests: Laboratory Tests, Small-Scale Field Tests, and Field Tests Using Existing Structures and Buildings. For each type of test, methods and criteria are presented for evaluating the performance of bait products as preventive or remedial treatments. Please discuss:
(a) whether the laboratory tests described in the draft Guidelines produce sufficient data to determine whether a termite bait kills termites feeding directly on the bait ("direct kill") and kills other termites in the same population that have not fed on the bait ("secondary kill").?
(b) whether data from the laboratory tests showing that a termite bait
product causes both direct and secondary kill reasonably support an inference
that the termite bait product should be efficacious under conditions of
small-scale field testing?
2. The draft Guidelines present two differing approaches for small-scale field tests to evaluate the termite bait for structural protection - zero tolerance for structural infestation vs. termite population management. The former approach is based on the concrete block or concrete slab tests presented in the Guidelines that are similar to testing conducted for soil applied termiticides. The performance standard is 100% protection (0% infested with termites) for preventive treatments while infestations must be eliminated within 12 months in remedial treatments. The latter approach uses termite baits to "manage" or control termites at the population level with product evaluation emphasizing the ability of the bait product to suppress termite populations on an area-wide basis with a performance standard of 80% (4 of 5 treated colonies suppressed or exterminated). Please discuss:
(a) the feasibility and scientific soundness of each approach.
(b) whether the small-scale tests provide sufficient data to show whether or not a termite bait product works?
(c) to what extent do the proposed small-scale field tests mirror actual use conditions?
(d) which is the best method for testing termite baits?
(e) What modifications or additional tests could be recommended to improve small-scale field testing? In answering these questions, please address the following aspects of each method: the criteria used to select testing sites, the number of replicate observations at each site, the placement of the termite baits in the test system, and the applicability of the methods for the different species of termites.
3) The draft Guidelines present a method for field tests using existing
structures and buildings.
The evaluation criteria presented in the draft Guidelines are based on the presumption that termites must not infest a structure for a structure to be protected. The evaluation criteria presented in the draft Guidelines are based on visual inspection of structures for termite infestations, use of monitoring devices (acoustical emission devices, microwave devices, bait stations and bucket traps), and measurement of wood consumption before and after termite bait treatment at bucket traps or other non-bait product monitoring stations (independent monitors). . The performance standards for remedial and preventive treatments at existing structures are presented below
The product performance standard for remedial treatments should include elimination of an existing termite infestation in 12 months or less in 100% of the structures treated and the treated structure must remain termite free for 12 months following treatment. If termites are not detected from structures but remained active in the monitoring station or independent monitor (IM), then structural inspections every month are needed during the 12 month period. After baiting eliminates the infestation in the structure based on a structural inspection but the activity resumes during the 12-month post-baiting observation period at the monitoring station, additional bait application has to eliminate termite activity within 12 months at the station and IM following the re-application of baits without causing >10 percent of the maximum wood consumption as recorded in the IMs during the pre-baiting period. After the re-application of baits, termites should remain absent for another 12 months in the structure and IMs.
Preventive treatment tests must prevent structural infestation by termites in 100 percent of the structures for the duration of the field test, for a minimum of five years, as measured by 60 months of termite activity at the monitoring stations/bucket traps/wood stakes. Alate swarms, mud tubing, and presence of worker or soldier termites in or on the structure are indications of a termite infestation and can indicate the failure of a bait product to protect a structure.
(a) the criteria used in the selection of a structure for testing, the number of structures that should be included in each test, the bait placement intervals around the structure, and the applicability of the method for the different species of termites.
(b) are the evaluation methods and criteria for detecting termites in and around existing structures consistent with the state of the science for assessing termite activity? Would another measure be more informative and useful for the Guidelines?
(c) are the product performance standards appropriate to show if termite bait product work successfully when applied at existing structures?
(d) Termite bait technology is based on a sophisticated knowledge and understanding of termite biology and foraging behavior. Many regulatory Agencies at the State and Federal level are concerned about homeowner use because of structural damage that could occur if an application is not done correctly. Should the guidelines recommend field tests designed to evaluate the performance of termite bait products following homeowner applications? In answering this question, please provide a supporting discussion that addresses what is known about homeowner applied baits and why it may or may not be important to test product performance under this application scenario. If the answer to this question is yes, please discuss the design of such field tests including: the criteria used to select sites, the criteria used to select study participants, and the number of replicate observations at each site.
Questions for the Panel
4) Please provide comments on the clarity, accuracy and completeness of the draft Termite Bait Testing Guidelines. In your comments, please provide a supporting discussion that highlights any areas of the draft Guidelines that may need to be clarified and relevant topics that may be missing. Include references to any published literature that could help improve the completeness and clarity of the draft Guidelines.