Legality of Using Soap to Control Chinch Bug
(in Canada)

Comments and conclusions based
on PMRA documents and
correspondence with the PMRA
April 27 to Dec. 8, 2004.

Contents

Different Soaps, Different Regulations, and Different Effects

For background information about use of soap to control chinch bug, see ACUTE CONTROLS: Insecticidal Soap and More About Soaps, Detergents and Insecticidal Soaps.

Posted 7 Feb. 2005

Overview

Currently, the only pesticides that are permitted by the PMRA for control of chinch bug are diazinon (an organophosphate) and Sevin (carbaryl, a carbamate pesticide). (See List). Both are cholinesterase inhibitors that are recognized as unsafe in the domestic environment by pesticide regulating agencies in Canada and the U.S, particularly for children, and have been targeted for removal from the domestic market. In the U.S., several alternative, much more benign materials for humans and the environment, or 'soft' pesticides, are also registered for control of chinch bug, such as insecticidal soap. (Insecticidal soap is a refined natural soap which is no more hazardous than natural soap; its advantages over household soap are consistency of product, generally higher efficacy and lower toxicity to plants.)

However, while several insecticidal soap products are registered in Canada for use against a variety of pests on houseplants and in gardens, none have been approved for use against chinch bug.

The befuddling result is that the only pesticides that can legally be used against chinch bug in Canada are those which the PMRA itself considers unsafe in the domestic environment, while we cannot use insecticidal soap in our own backyards. (Nor can lawncare companies use household soap as a substitute.)

Why are insecticidal soap products not approved for use against chinch bug in Canada? It could be because (i) no manufacturer has applied for a product extension that would allow such use, or (ii) because applications for such extensions have been turned down by the PMRA. It's possible that an application(s) for a product extension to include chinch bug in the list of target pests is currently being considered.* We are not privy to this information because the PMRA does not provide any information unless and until an application is actually approved.
*See the 2004 Pesticide Bylaw Overview (www.halifax.ca/pesticides/), page 14: "EAC has encouraged two manufacturers in Canada to register their products".

Conclusion: Insecticidal Soap

For now it is clearly illegal (in Canada) for lawncare companies, as well as for individuals acting on their own, to use insecticidal soap to control chinch bugs.

Manufacturers of insecticidal soap should be encouraged to apply for product extensions so that their insecticidal soap products can be used against chinch bug in Canada (as in the U.S.). Our public officials and elected representatives should be encouraged to appeal to Health Canada to expedite this process.

In the meantime, the only materials approved by the PMRA for use against chinch bug are pesticides which the PMRA acknowledges pose significant health risks, especially for children.

Household soap can be used in place of insecticidal soap to control chinch bug (and other pests), although it may be less effective, and should be tested for possible damage to grass. Natural soaps, rather than detergents are safest. (See Household Soap.) Correspondence with the PMRA indicates very clearly that lawncare companies are NOT entitled to use household soap for pest control. The situation in regard to individuals, however, is not clear.

Whether or not individuals can use household soap to control chinch bug is an important issue. In 2003 and 2004, the 3rd parties responsible for issuing pesticide permits in Halifax Regional Municipality (Clean Nova Scotia in 2003 and Ecology Action Centre in 2004) understood they could NOT legally advise residents to try using household soap to control chinch bugs. Many of the situations in which permits were issued for use of diazinon or Sevin to control chinch bug could have been dealt with adequately by applications of household soap, (or by Insecticidal Soap if it had been registered for this use).

Over the period April 23 to Dec. 8, 2004, I made use of the PMRA Pest Managament Information Service (www.pmra-arla.gc.ca/english/aboutpmra/infoserv-e.html) to attempt to clarify whether it is legal for individuals to use household soap to control chinch big (and other lawn pests)

I was told very clearly in the spring that the answer is NO, such use is illegal. However during a CBC interview in August, a PMRA official was questioned about this and said that

" ..lawncare companies cannot use dish soap as this would become a product/service rendered making a pesticidal claim, thus subject to the PCPA but individuals may use dish soap on their properties as this is not a method that requires registration under the PCPA. "
I followed up with further queries to the PMRA to confirm the statement and was told, yes, soap can be used as a physical control for chinch bug. I noted that the word 'physical' was inserted in all subsequent references to use of household soap.

I then queried (Sept. 10, 2004) how the PMRA defines 'physical control' and where on their website one can find out what methods do NOT require registration under the Pest Control Products Act. In a reply issued on Dec 8, the PMRA did not address the specific questions, instead simply maintained that all of the needed information is on their website.



Conclusion: Household Soap
For some reason or another, the PMRA is reticent to clearly define if and how household soap may be used by individuals to control chinch bugs in their lawns, except to make it clear that commercial companies providing lawncare services cannot use household soap.

For several or more years, a number of government website sites in Canada (including sites at municipal, provincial and federal levels) have advised use of household soap to control chinch bug in lawns. Hence it seems there is a kind of tacit acceptance by the PMRA of individuals using household soap to control pests, and of agencies promoting this use.



-David Patriquin
5 Feb. 2005

Details of correspondence with the PMRA

A major objective of this web site is to present accurate information related to use of 'alternatives to pesticides' such as soap and for that reason that I have attempted to sort out the various issues related to use of soap. To avoid any ambiguities in reporting on what I have been told by the PMRA, the questions to the PMRA and answers received are given as posed and received in the following links.

  • Questions To and Answers From the PMRA Apr 23-30, 2004.

  • Questions To and Answers From the PMRA Aug. 20-27, 2004.

  • Correspondence with the PMRA on the 'Household Soap Issue' 30 Aug to Dec 8, 2004

            Separate: Letter of Sept. 10 with Specific Questions


    • UPDATE, August 2007

    Based on the PMRA's apparent change in position in regard to the use of household soap by homeowners, in 2005 the Ecology Action Centre Pesticide Project (which had the contract for administering the Pesticide By-law) began to advise residents who had applied for a permit to use a registered pesticide to control chinch bug to try household soap. I understand that initially they also distributed premixed 2% soap solution, but were told by the PMRA that while they could suggest use of household soap, they could not distribute a soap solution.

    The following is reported in the HRM's Pesticide By-law Program Overview Report for 2006.

    On-Site Education Programs
    One of the goals of the supporting educational programs of the By-Law programs has been to assist residents in transition to alternative methods for managing pest problems. Efforts are made to make one on one contact with the homeowner. Last year the Pesticide Management Regulatory Agency (PMRA), a branch of Health Canada, granted permission to demonstrate the use of household liquid dish soap (2% solution in water) to residents who have chinch bug problems. Only homeowners are allowed to use household liquid dish soaps on chinch bugs. Companies must use registered products, thus this does not provide a product that companies could sell as part of their products or services.

    Only one registered product (active ingredient), Carbaryl, was available for use on chinch bugs in 2006. The PMRA, for health and safety reasons, has been removing some pesticides from the market (e.g. Diazinon, chloropyrifos) and has made recommendations for future products removals. One such group of chemicals is carbamates, which includes Carbaryl. No timelines have been set for its removal and no alternative products are known to be in development as replacements. The HRM is working with partners and the federal government to determine the potential for registering a soap-based or other similar product that could then be used by both residents and companies.

    Response to soaps
    The experience so far is that, when the EAC meets a resident on-site and has the opportunity to work with them, the majority of residents are pleased to have an alternative they can pursue which is considered safer than the traditional pesticides for chinch bugs. Residents with chinch bug problems, that may have warranted a permit previously, are instead attempting to use a less toxic method before considering pesticides, restricted or regulated in HRM.

    Use of soaps may not be as successful in all cases due to a lack of technical expertise among residents and differences in their use of soap solutions. Ideally, it would be much better to have a registered insecticidal soap product available to companies. This would provide a better product, a role for companies, and improved outcomes for residents. This is a strategic initiative described later in this report.

    In 2007, a soap-pyrethrin product was registered by the PMRA, providing the first alternative to carbaryl that could be used by lawncare companies for chinch control. Since pyrethrins are permitted under the Pestcide By-law, no special permit from HRM is required for lawncare companies or individuals to use this product. However, pyrethins are far from innocuous materials, epsecially if used extensively, and there is still no pure insectidal soap product registered for use on chinch. See Update: Use of Pyrethrins and Neem Oil to Control Chinch Bug.



    Page posted 5 Feb. 2005
    (Completely revised from earlier Updates on the Soap Issue)
    Update added 18 Aug. 2007