Legality of Using Household Soap
to Control Chinch Bug in Canada

Unfortunately, the PMRA position on the legalities of using household soap to control chinch bug (or any other pests) is somewhat ambiguous and officials, for some reason or another, are wont to clarify the PMRA position. A number of government website sites in Canada (including sites at municipal, provincial and federal levels) advise use of household soap to control chinch bug so it appears the PMRA is not partiuclarly concerned about this issue, or not very vigilant about it. If anyone can provide more definitive information on this matter, I would appreciate receiving it. (Please send it to dp@versicolor.ca.) Some details of what I have been able to find out (and not find out) about this matter are given below.
-dp

Whether or not it is legal for individual residents to 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 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 might have been adequately dealt with by applications of household soap.

*Clean Nova Scotia in 2003 and Ecology Action Centre in 2004

However when I was putting materials together for this website in the spring of 2004, the legality of using household soap to control chinch bug seemed unclear. Several federal, provincial and municipal web sites advised use of household soap as a control for chinch bug and a U.S. publication commented that

Household detergents/soaps not sold for pesticidal purposes are not regulated as pesticides. Legally they can be used on plants, at the risk of the applicator.[V17]

I surmised that the same may be true in Canada, especially in view of efforts to harmonize pesticide regulations between Canada and the U.S. To clarify the situation, I posed these questions (amongst others) to the PMRA on 24 April, 2004:

3. Is it permissible for an individual resident to use ordinary soap at approx. 2% concentration to control chinch bugs in lawns?

4. Is it permissible for a lawncare company to use ordinary soap at approx. 2% concentration to control chinch bugs in lawns?

I received the following, clear answer (no):
For questions #3, 4, Ordinary Soap
Ordinary soap is not considered to be a pesticide. It is considered basically for monitoring purpose. This product is not registered under the Pest Control Product Act and therefore it is illegal to use it to control the chinch bug.

A CBC report on August 23 suggested that the PMRA had changed their stance on this matter, and I sought further clarification. On Aug. 30, following a detailed response from the PMRA, I posted the comments shown below ("It's OK to Use Household Soap").

However, some subsequent communications with the PMRA on related issues raised some doubt in my mind whether I had correctly represented their position on use of household soap. On Sept. 10, I sent a further request for clarification to the PMRA. That request has been acknowledged and a response promised, however none has yet been received. (On Oct. 6, the PMRA wrote that they hoped to get a response back in the next few weeks.)

I have emphasized to the PMRA that "I am not challenging PMRA authority, simply trying to figure out what the regulations are and how we go about living within them or getting them changed via the routes you have set up for that (e.g., by encouraging manufacturers to apply for registration for particular uses)".

Hopefully this issue will get sorted out soon. - David Patriquin (15 Nov. 2004)
Report posted on this site on August 30

SOAP UPDATE:

"The bottom line, can environmental organizations encourage individuals to use dish soap as an alternative method of physical control for chinch bugs? Yes."
- PMRA, 27 Aug. 2004

Different Soaps, Different Regulations,
and Different Effects

This recent clarification by the PMRA* is welcome news, as it gives individuals another alternative to Diazinon or Sevin for treating existing infestations of chinch bug.

Precuations
There is a wide range of chemicals in household soaps (which include detergents), and some precautions should be taken in selecting a household soap for use as a pesticidal agent, e.g. testing it on a small area of grass. See Household Soaps.

We still need access to insecticidal soap
It is still NOT permissible under PMRA regulations for lawncare enterprises to use household soap to control pests. Nor is it permissible for lawncare enterprises (or individual residents) to use Insecticidal Soap to control chinch bug. As well as not allowing use of a product that is superior to household soap, this constrains the abilities of lawncare enterprises to cater to the rapidly growing market for alternatives to traditional pesticides. However, the PMRA only responds to requests from manufacturers to register new products or new uses for products; the PMRA does not, apparently, seek or encourage companies to register new products in order to fill certain voids. Hence if new products are needed, potential users (lawncare enterprises and their associations) should make their needs known to manufacturers. Hopefully with some initiatives of this sort, insecticidal soap products and diatomaceous earth will be registered for use on chinch bug by next season.

*The PMRA has, apparently, modified its stance on this matter and I have changed the information on this site accordingly. Materials previously posted on this site indicating that it is NOT legal to use household soap to control chinch bug were based on clear questions put to and clear answers received from the PMRA in late April/early May of 2004.1 The PMRA was asked to review the materials related to PMRA regulations, which they did and, while they requested certain changes, there was no request to change the statements related to household soap. Following some further questions forwarded to the PMRA on August 20 and 23, the PMRA apparently reconsidered its position — or how it classifies use of household soap (now as a physical control) — and on Friday, Aug. 27 stated clearly that individuals can use household soap to control chinch bugs. 2. As before, to avoid any ambiguity in reporting on these issues, the questions and answers related to this matter are provided as posed and received. — dp

1. Questions To and Answers From the PMRA Apr 23-30, 2004.
(Posted 5 May, 2004)

2. Questions To and Answers From the PMRA Aug. 20-27, 2004.
(Posted 29 Aug. 2004)
Page posted 30 Aug. 2004