No-Spray Columbus

Columbus Public Health (the organization that sprays for mosquitos in Columbus and Worthington) asked for feedback on their mosquito control program (follow this link for program documentation, titled Consolidated Vector Control Program Standard Operating Procedures). What follows is feedback provided to CPH (to be reviewed at an upcoming meeting):

1.   Introduction

Thank you for sharing the collection of operating procedures. They lend great insight into how CPH conducts mosquito control. However, in addition to and directing these procedures, Columbus needs CPH to develop a management plan that

·      Defines concrete objectives;

·      Lists requirements;

·      Lists stakeholders (and their objectives);

·      Discusses how divergent objectives are to be weighed and balanced;

·      Discusses responsibilities; and

·      Discusses decision-making processes (e.g., deciding when certain procedures will be executed and when they’ll be suspended).

After CPH has developed a management plan, the Consolidated Vector Control Program Standard Operating Procedures should be reviewed and, where applicable, adjusted or supplemented to ensure support for and alignment with the management plan.

Both the management plan and the supporting procedures should be reviewed by experts to ensure that both the plan and procedures embrace best current practices and are compliant with applicable Federal and Ohio laws.

2.   Gaps in Operating Procedures

Several items are missing from the CPH-provided procedures document. While a great deal of the document is given to instruction on data entry, there is no coverage for training of the folks who actually apply the pesticide. The training of the actual applicators is paramount to ensure compliance with Federal and Ohio laws regarding pesticide use.

In addition, licensing required of CPH to apply pesticides should be detailed in the procedures.  The training, certification, and continuing education (all legal requirements for said licensing) should be covered in conjunction with the steps taken to ensure ongoing compliance.

The operating procedures should also include the steps required to protect waterways (as required by Federal law). Examples of steps that should be taken include turning off fogging when approaching/crossing bridges and avoiding spraying in proximity to waterways when wind will carry poisons over the waterways.

The operating procedures should also outline steps taken to minimize exposure of pedestrians, bicyclists, children in schoolyards and recreation centers, companion animals, food crops, households, at-risk/infirm residents, etc. to poisons. For example, the US CDC advises parents to prevent their children from eating dirt in an effort to reduce intake of  pesticides (permethrin as well as malathion).

Finally, the operating procedures should include steps to be taken in keeping the public informed of the various stages of infestation and in-progress management. Such steps should included not only updating google maps, but explicitly contacting members of the press, community groups, health organizations supporting high-risk individuals, etc.

3.   Items to Support a Comprehensive Management Plan

To create a comprehensive management plan, various items should be included.

The management plan should include the explicit criteria that will be used to decide when to disregard “no fog” requests. There should be clearly defined criteria so as to avoid even the appearance of arbitrary decision-making.

The management plan should include details about when to release information to the press or otherwise publicizing the decisions regarding spraying. This is critical so that citizens and officials can take actions to minimize the exposure to themselves, their children, their companion animals, their food crops, their households, their students, their at-risk/infirm neighbors and charges, etc.

The CPH-provided document mentions the need for citizen education for source reduction and mosquito avoidance. Indeed, a true integrated pest management plan would strive to avoid using pesticides; it would view the use of pesticides as a last resort—as a failure of the rest of the plan to achieve some stated (and measurable) goals. However, the CPH-provided document includes no procedure for effecting education. As education is the most effective mechanism for curtailing infection from mosquitos (and since an effective integrated pest management plan for mosquito control requires public education), CPH should include education prominently in their plans and procedures

An effective mosquito control plan should contain clear goals and objectives.  The only statement of a goal in the CPH-provided document is a nebulous one: “The program objective is the prevention of vector[-]borne disease transmission to humans and domestic animals”. To support this statement, CPH should include more details about goals and objectives in their mosquito management plan:

·      How the objective (prevention of disease transmission) is measured;

·      Other factors that constitute a successful program;

·      Indicators that provide insight in real-time about how the program is working;

·      Indicators that support the expenditures and risks at a given management threshold/step (e.g., costs of pesticides and application; risk of provoking asthma attack or other harmful physical reaction in susceptible individuals, etc.);

·      Diseases targeted;

·      Acceptable disease infection rates (e.g., if one person is infected, was the program a failure?); and

·      The program’s cost and the expected return for these costs (in terms of disease prevented and associated costs of disease avoided).

An effective public health program (including one to control mosquitoes) requires modern management techniques that are de rigueur in the commercial world. CPH’s mosquito management plan should include:

·      Metrics that can be tracked to indicate success or the need for escalation in disease-preventing action; and

·      Explicit thresholds for deciding when to pursue more aggressive responses.

The CPH-provided document says “Mosquito adulticiding is sometimes the only practical control technique available in situations where surveillance data indicate that it is necessary to reduce the density of adult mosquito populations quickly to lower the risk of WNV transmission to humans”. This should be expanded in a comprehensive management plan to include:

·      Details on appropriate surveillance data;

·      Details on the calculation of risks of WNV transmission to humans;

·      Thresholds that constitute a necessity to reduce the risk of WNV (or any other mosquito-borne disease) transmission;

·      Metrics, including the targeted mosquito density;

·      Thresholds on metrics that would contraindicate spraying, contraindicate outside activities (e.g., for schools, recreation centers, etc.), as well as thresholds that would prompt the declaration of a public health emergency;

·      Other control techniques, including details on their efficacy, cost, and practicality; and

·      Steps that could have been taken to prevent the high risk of WNV from developing (e.g., education, press conferences; consultation with/support from other non-governmental health and services organizations, etc.).

4.   Guidance on IPM, Examples of Mosquito Control Using IPM, and Ensuring the Use of Best Current Practices

The US EPA provides significant information on integrated pest management techniques. Their introductory document (http://www.epa.gov/opp00001/factsheets/ipm.htm) states that “IPM is not a single pest control method but, rather, a series of pest management evaluations, decisions and controls” – controls “with the least possible hazard to people, property, and the environment.” In addition, the document provides many on-line resources.

The recommendations of the Mosquito Control Collaborative (a project of the Association of State And Territorial Health Officials in partnership with The National Association of County and city Health Officials and supported by the US CDC) also provides significant guidance for mosquito control. Their findings are available at http://www.astho.org/pubs/FinalReportPDF.pdf

Locally, the Ohio State University hosts an extensive integrated pest management program (http://ipm.osu.edu). Professors and researchers at OSU would be significant assets in assessing and enhancing CPH’s mosquito management plan.

Examples of other locales’ comprehensive mosquito IPM plans and recommendations are readily available on the Internet. Some of these could be adopted virtually intact by CPH. Examples include:

·      Sacramento area Mosquito and Mosquito-Borne Disease Management Plan at http://www.fightthebite.net/download/Mosquito_Management_Plan.pdf

·      Lakewood, Ohio Response Plans and Guidelines for West Nile Virus at http://web.archive.org/web/20070813075421/http://ci.lakewood.oh.us/westnile_final_report_2.htm

·      Shaker Heights, Ohio West Nile Virus Response Plan at http://www.beyondpesticides.org/mosquito/documents/shaker%20heights.pdf

·      CDC WNV guidelines at http://www.cdc.gov/ncidod/dvbid/westnile/resources/wnvguidelines2001.pdf and at http://www.cdc.gov/ncidod/dvbid/westnile/resources/wnv_ReportOverview.htm

5.   Ensuring Compliance with Federal and Ohio Law

In light of previous application violations (e.g., the intentional disregard of the pesticide labeling by misinformed CPH staff, a direct violation of Federal law), the portions of the CPH mosquito management plan and procedures associated with pesticides should be reviewed by experts in pesticide application and associated regulations. Said experts should be from the US EPA or otherwise credentialed. Their findings should be in writing and available for review prior to any applications of pesticide in 2009 by CPH. In addition, any significant revision of CPH’s mosquito management plan (e.g., change of pesticide, change of application rate/mechanism, change of timing, change of threshold for initiating pesticide application, etc.) should be reviewed prior to effecting activities associated with said revisions.

Columbus Public Health (the organization that sprays for mosquitos in Columbus) has asked for feedback on their mosquito control program. They have provided a copy of their program documentation for review.

If you have comments, you can send them directly to the program administrator, Dale Harmon, post them as a comment here, or email them to info@nospraycolumbus.com.

A discussion of the program will be held on Thursday, November 20, 2008.  To be kept apprised of details, please send email to info@nospraycolumbus.com.

A Google map of opt-out locations (as of 25 August 2008) is available via this link:  Opt-Out Locations

Note that the locations are approximate (they’re based on Google’s interpretation of street addresses) and may be inaccurate by several hundred feet. If you have doubts about your opt-out status, you should contact Columbus Public Health’s vector control organization at 645-2483.

The following no-fog maps were received from the city on 25 August. They purport to show all of the homes in the Clintonville area that have requested exemption from the mosquito fogging. If you find your neighborhood but don’t see a dot near your house, you may have been omitted from the no-fog list.

To check on your no-fog status, contact Columbus Public Health’s vector control organization at 645-2483.

North Clintonville/South Worthington No-Fog Map

South Clintonville/OSU area No-Fog Map

The goal in meeting with the city was to understand their policy and position but also to establish a path to effect improvements to mosquito control policy, improvements to that policy’s execution, and improvements to communication. To that end, the meeting provided at least a preliminary understanding of the policy and the opportunity to voice concerns. However, additional work will be required to achieve the improvements befitting a world-class mosquito control program.

The main concerns voiced in the meeting came down to three things:

• mosquito-control policy,
• execution of that policy, and
• communication regarding (and as part of) policy execution.

A synopsis of specific concerns:

• the city’s mosquito control plan (their “integrated pest management plan for mosquito control”) hasn’t been updated since 1999 despite advances in understanding of West Nile Virus,
• the city fogged this season (and will continue to fog) with a pesticide toxic to cats (despite having told residents that they would use a less toxic pesticide),
• the city fogged pedestrians and bicyclists who were caught unaware, and
• the city fogged at least one Clintonville home that had requested (and received) an exemption from fogging.

On the policy concern: it’s not clear that there actually is a concrete policy in Columbus for mosquito control.

• During the meeting, the vector control administrator (Dale Harmon) indicated that it is more of “an art” (his words) to making the decision on when and where to fog.
• When asked about other cities’ policies of having very explicit thresholds and well-defined goals for escalating efforts at mosquito control, the administrator dismissed them derisively, indicating that such policies were unfounded and ill-conceived.
• When asked to review the city’s policy as part of the meeting’s agenda, the city provided with what turned out to be a synopsis of the policy–a synopsis found to be incorrect (see below).
• When residents received confirmation of opt-out status from the city, the letters indicated that the city would be using malathion in their fogging efforts. In addition, the policy synopsis indicated that they would be using equipment configured for malathion. Even the city’s web pages indicate that malathion will be used. However, the administrator admitted in the meeting that they actually used a permethrin-based insecticide. He said that an outdated letter had been mailed to folks. He said that the city had run out of malathion and decided to use the permethrin-based insecticide instead. The concern here is that permethrin is highly toxic to cats; had residents been alerted to the fact that the city was using permethrin, cat owners surely would have wanted to take precautions to protect their animals (especially their outdoor cats).
• The vector control administrator indicated that the city’s mosquito control policy (specifically their integrated pest management plan to control mosquitoes) had not been updated since 1999, this despite new and ongoing discoveries about West Nile Virus as well as new and ongoing studies about the effectiveness of associated public policy.

On the policy execution concern: it’s clear that the city is not even executing on their nebulous policy.

• The administrator indicated in the meeting that the policy is for the fogging to be discontinued when the driver sees people outside near the area to be fogged (drivers are “asked” to turn off fog when pedestrians or bicyclists are observed). Yet, the driver who fogged bicyclists on the Olentangy Bicycle Trail continued fogging even after being passed by several bicyclists and joggers.
• Fogging has occurred after sunrise (after 6:30am on July 29th in the case of the bike path fogging); it’s not clear here what the policy is–in some cases, there are indications that the policy is to continue “shortly after sunrise”; in the meeting, the administrator said that typically they’re finished fogging by 6:30AM; the CPH website indicates that they will fog between 4 and 6:00am.
• At least one house was fogged despite a letter from the city assuring that the house would not be fogged. The administrator showed maps of the fogging areas where no-fog requests were represented by high-lighter dots on the map. In this particular case, the home that requested an exemption from fogging was NOT indicated on the map.
  It’s clear that there is a need for a quality control process in handling the no-fog requests.

On the communication concern: it’s clear that the city should be doing a much better job at communicating their policy and intent to execute their policy.

• There is no pro-active attempt to notify local community groups (e.g., area commissions or registered neighborhood groups) that fogging will occur in the groups’ interest areas.
• There is no communication on what risk factors have appeared in a particular area to be fogged. There is a google map of the areas planned to be fogged, which is a great first step. However, it doesn’t provide information about what residents should be concerned about.
• The only attempts at education (one of the primary and most effective parts of an integrated pest management program according to a variety of experts–see nospraycolumbus.com for links) by the city appear to be press releases and (inconsistent) web pages.

As a result of the meeting, the city promised that:

• future Clintonville spraying will be proceeded by the city notifying Steve Soble (the city’s neighborhood liaison for Clintonville) who will notify the Clintonville Area Commission and other neighborhood associations.
• the city’s vector control administrator will provide a copy of the city’s actual integrated pest management plan for mosquito control.
• comments on the plan were welcome after the current mosquito season ends—probably sometime in September.

“Fogging” to kill mosquitoes might make some sense–if, for example, there were an exceptional risk of mosquito-borne disease and other mechanisms for prevention were insufficiently effective and the risks from the pesticides used in fogging were outweighed by the benefits of disease prevention.

But does it make sense to fog Columbus?  We’re scheduling a meeting with Dr. Teresa Long, the Columbus Health Commissioner to discuss the issue. If you’d like to be notified of the time and location of the meeting once it’s scheduled, please sign-up on the e-mail list.