Board Sends Another Notice Regarding “Eton Square Rodent Control Program”

Our thorough response can be found below.

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Tuesday, September 3, 2019, 11:30 am

From: Marck Rossy

To: Eton Square

Subject: Eton Square Rodent Control Program

September 3, 2019

Eton Square Residents,

The Board of Directors has approved expanding the rodent bait stations program to all 15 buildings on Ellingham Circle.  Four bait stations will be installed outside each building, and serviced monthly thereafter for at least three months.  Installation is scheduled for the end of this week.  Expansion of the program is necessary to control the rodent populations, with sightings reported at other buildings.  No sightings have been reported on Brindle Heath Way.

The stations are tamper resistant, authorized by the United Stated Environmental Protection Agency (EPA), and will be serviced by a qualified pest control professional.  Dogs and cats are not able to get into the bait inside, but use caution and keep pets away from the boxes.  In conjunction with this program, residents are reminded that bird seed and other food sources are prohibited on the patios and balconies or on the common grounds surrounding the buildings.  Storage of items and general clutter are not permitted on patios, as this could be used by rats as a nesting area. 

It is the Board’s intention to keep this a clean, rat-free community.  Thank you for your attention to this message.

Sincerely,

Marck Rossy, CMCA, AMS

Community Association Manager

11351 Random Hills Road, Suite 500 | | Fairfax, VA 22030

Main 703.385.1133

Please share this information with neighbors that may not have received it.


1) “The stations are tamper resistant”

Risks for Pets

However, tamper-resistant bait boxes will not protect pets from secondary poisoning.

Unfortunately, bait stations cannot stop all routes of exposure. House sparrows have been seen entering bait stations in urban environments. Other wildlife species may disturb and attempt to break in to bait stations. Cockroaches and other invertebrate species enter bait stations to feed. They are not affected by anticoagulant products but scatter bait material and carry the poison in their own bodies raising the potential for secondary poisoning.

2) “authorized by the United Stated Environmental Protection Agency (EPA)”

Please note that legality does not equate to safety or morality. Most of these poisons are second generation anticoagulant rodenticides (SGARs). Due to the high risk level, SGARs are NOT available to the general public.

Several local municipalities in the US have successfully rejected the usage of rodenticides, and more actions are currently underway. From Bill “AB-1788 Pesticides: use of anticoagulants.”, the State of California: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201920200AB1788 :

While all anticoagulant rodenticides have a harmful impact on nontarget animals, second generation anticoagulant rodenticides (SGARs) are particularly dangerous to nontarget wildlife as SGARs are higher potency than prior generations and a single dose has a half-life of more than 100 days in a rodent’s liver. Due to high toxicity and concern for impact on nontarget wildlife, the Department of Pesticide Regulation banned consumer sales and use of SGARs in 2014, restricting their purchase and use to certified pesticide applicators.

Despite the 2014 regulations issued by the Department of Pesticide Regulation, scientific research and state studies have found no significant reduction in the number of nontarget wildlife with detectable levels of SGARs in their system. From 2014 through 2018, the Department of Fish and Wildlife found SGARs in more than 90 percent of tested mountain lions, 88 percent of tested bobcats, 85 percent of protected Pacific fishers tested, and 70 percent of northern spotted owls tested. Such data indicates that a consumer sales and use ban of SGARs has been insufficient to reduce rodenticide exposure in nontarget animals and further steps must be taken.

Rodenticides can be counterproductive to rodent control by poisoning, harming, and killing natural predators that help regulate rodent populations throughout California.

Additional scientific information about rodenticides (Oregon State University): http://npic.orst.edu/factsheets/rodenticides.html

Rodenticide baits are made to attract animals. Pets and wildlife may take the bait if they find it. When an animal eats the bait directly, it is called primary poisoning. Secondary poisoning is caused by eating poisoned prey. It may also be called relay toxicosis.

You may find that there are other things you can do to control rodents, in addition to using rodenticides. Find out what kind of rodent you have and learn about its habits, abilities, likes and dislikes. Try to block entry points and remove any food and water sources. This is called Integrated Pest Management (IPM).

Additional scientific information regarding rodenticides (Safe Rodent Control Resource Center) : http://saferodentcontrol.org/site/got-rats-new-safe-rodent-control-website-to-the-rescue/

The information presented on this website is backed by solid scientific data based on studies from well-regarded sources, as well as recommendations from government agencies, such as EPA. It examines the risks of using rodenticides, guidelines for maintaining a rodent-free home and ways to treat a rodent infestation. Learn how the state and federal government regulate rodenticides.

http://saferodentcontrol.org/site/risk-for-pets/

Dogs, cats, and other domesticated animals are all too commonly exposed to toxic rodenticide baits. Sadly, these chemicals make the top-ten list of toxins responsible for pet poisonings, according to American Society for the Prevention of Cruelty to Animals (ASPCA). The US EPA states that more than 100 pet deaths are reported each year from exposure to rodenticides.

Rodenticides are not only poisonous for rodents. Rodent baits can be lethal to any mammal or bird that ingests them or feeds on a poisoned rodent. That’s why controlling rodents with rodenticide baits puts pets at high risk of becoming ill or dying – either through direct ingestion (primary poisoning) or by eating poisoned rodents (secondary poisoning).

Safeguarding your home from rats, mice, and other rodents doesn’t require the use of potentially hazardous poisons. Safe, effective, and affordable solutions can help you rodent-proof your home while ensuring the health of your pets.

However, tamper-resistant bait boxes will not protect pets from secondary poisoning.

Risks for Wildlife

Rodenticides are designed to kill mammals such as rats and mice. It should therefore come as no surprise that these products commonly poison non-target wildlife species. Numerous studies have documented harm to mammals and birds. Other vertebrate species, such as reptiles and amphibians, are also at risk. Most rodenticides work by disrupting the normal blood clotting or coagulation process so that dosed individuals suffer from uncontrolled bleeding or hemorrhaging. This hemorrhaging can occur spontaneously or from any cuts or scratches. Because internal hemorrhaging is difficult to spot, often the only indication of poisoning in exposed wildlife is that they are weak or listless. Signs of bleeding from the nose or mouth may be visible on occasion. Affected wildlife may be more likely to crash into structures or moving vehicles or to be killed by predators. This makes these poisonings even more difficult to document.

Unfortunately, bait stations cannot stop all routes of exposure. House sparrows have been seen entering bait stations in urban environments. Other wildlife species may disturb and attempt to break in to bait stations. Cockroaches and other invertebrate species enter bait stations to feed. They are not affected by anticoagulant products but scatter bait material and carry the poison in their own bodies raising the potential for secondary poisoning.

Rats and mice that feed on these baits can take several days to die. The poisoned rodents become increasingly weak, making them easy prey for predators. Hungry raptors or other wildlife can receive a lethal dose when they feed on the poisoned rats and mice. This is tragic not merely because hawks, owls, foxes and other animals are dying, but because wildlife predators provide us with valuable rodent control services – unless of course we kill them first.

Rodenticides may now be the single most important source of mortality for some wildlife species. Where second-generation compounds are used, entire food chains are contaminated. Residues are even detected in species that typically feed on birds rather than on rodents.

Rodenticides: Background & Hazards

The first line of defense against rodents should be exclusion and trapping. These methods do not pose a poisoning risk to children, pets and wildlife.

Regulatory Outlook

In addition to federal regulation, rodenticides are typically regulated at the state level by the responsible state agency. In addition to meeting federal registration requirements under FIFRA, manufacturers may also need to meet particular state law requirements.

In practice, most states do not have separate registration systems. However, some states, such as California, New York, Florida and Washington, do have additional regulatory review of pesticides.

Use of second-generation anticoagulants under state and federal restrictions still left harmed wildlife that consumed poisoned rodents. Because of the widespread exposure of wildlife to second-generation anticoagulant rodenticides, in 2019, Cal DPR once again opened a re-evaluation of second generation anticoagulant rodenticides to determine what additional restrictions were needed to reduce the significant adverse impacts to wildlife.

From the National Park Service: https://www.nps.gov/samo/learn/management/rodenticides.htm

Avoiding Unintentional Poisoning

Avoiding Unintentional Poisoning

Take Action Against Anticoagulant Rodenticides: https://www.nps.gov/samo/learn/management/take-action-against-anticoagulant-rodenticides.htm

If your rodent problem is too big for you to control, contact a pest-exclusion company that uses sustainable practices. Pest control companies that practice Integrated Pest Management should be able to help you get to the root of the problem; seal up holes and trap rodents without the use of poisons.

https://www.epa.gov/rodenticides/identify-and-prevent-rodent-infestations

EVEN THE EPA suggests using alternate methods before resorting to poison: “Identify and prevent rodent infestations — it is always a good idea to try these simple methods first.”

3) “Dogs and cats are not able to get into the bait inside.”

Rats and mice that feed on these baits can take several days to die. The poisoned rodents become increasingly weak, making them easy prey for predators. Hungry raptors or other wildlife can receive a lethal dose when they feed on the poisoned rats and mice.

Smaller mammals, such as squirrels or chipmunks can enter the boxes. Any animal that enters can also exit. Once a contaminated animal is in the environment, any other animal can become poisoned by encountering and / or eating the contaminated animal. This is called “relay toxicosis” or “secondary toxicosis”. Non-target animals – wildlife and pets – can be killed as a result, including birds, hawks, eagles, vultures, dogs, cats, foxes and others. Humans, including children can also come into contact with poisoned, contaminated animals.

During a private meeting, in response to safety concerns, representatives of Alexandria Pest Services stated “You know, we take say safety, whether it’s dogs, kids, very seriously at APS. Again, we’ve been in business for over 20 years and we’ve never had any issues, any lawsuits with non-target pets or kids or anything. We just never had that issue.”

This Group feels that while this response may be “true” to they experience, it does not address proven safety concerns and risks regarding poison bait stations. It is not a defensible response.

See also #1 and #2 above.

3) “other food sources”

Garbage is a food source for rodents. Despite numerous and repeated reports regarding issues with garbage, there seems to be no action being taken by the Board.

Further notes:

4) Throughout the “industry”, Integrated Pest Management (IPM) is the accepted process for addressing pest concerns. There are several other structural improvements and repellent options available. The proposals provided by Alexandria Pest Services list a number of recommendations. None of these have been considered or enacted.
Long-term, effective actions include structural improvements, such as sealing gaps, installing L-shaped barriers, removing access to water sources (leaking hose bibs), eliminating food sources (garbage), etc.

Not only are bait stations are considered to be ineffective long term, but ignoring IPM practices is not financially responsible and ensures program failure.

5) Members of this group have repeated requested information from the Board regarding this decision making process. All inquiries have gone unanswered or ignored. These requested have been documented in the Activity Log. https://www.poisonatetonsquare.com/2019/06/background-information/

  • We request any and all documentation, metrics, data and photos that APS has submitted to the Community Manager (CM) and/ or the Board of Directors (BOD) in reference to rodent control.
  • What metrics are being utilized by APS to determine “success” of the initial 3-month program? Please provide this data.
  • What metrics are being utilized to justify the increase of stations and costs? Please provide this data.
  • Prior to approving the proposal submitted by APS, has there been any independent research regarding poisons done by the CM of BOD? If so, please provide that material.
  • With regards to utilizing poison, to what extent has risk assessment been performed by the CM and / or BOD? Have the risks been explored beyond the statement of one contractor, who lacks scientific credibility (entomology concerns insects, not mammals) and stands to profit?
  • What actions has the CM and/or BOD performed in order to prepare for potential legal liabilities (harm or death to humans and/or pets)?
  • At what point were any of these above concerns discussed or considered by the CM and / or BOD?
  • If the above concerns were not considered, please provide documentation as to how the decision-making process proceeded. What information was considered “best for the community”?
  • It is understood that ultimately the BOD is responsible for the decisions of the community. How can residents trust that the BOD are making fully-informed decisions, when information is not being considered and communications are not transparent?
  • Please provide confirmation that:
    this request has been received,
    has been transmitted to the BOD,
    and provide an approximate estimate date as to when this requested information will be available.

6) From the Board of Directors meeting on August 12, 2019:

“NEW BUSINESS • Pest Control. A proposal from Alexandria Pest Services to install and service rodent bait stations around all 30 buildings is attached. The setup cost is $3,000 to $4,200 for regular or decorative options, and $175 per month for inspection and servicing of the stations. The pest control budget of $4,000 will be exceeded.
Action: Review ………………………………………………………………………………………………………………….. 8”

During the meeting, this portion of NEW BUSINESS was TABLED until October. How was this proposal approved if the business was tabled? Was there an executive session? How were residents consulted or notified?

See details of the proposal, here: https://www.poisonatetonsquare.com/2019/08/new-pest-control-proposal/


WHAT YOU CAN DO:

We have received numerous reports from residents concerned about retaliation. Several residents have stated that they have observed a pattern: they submit a property complaint and then immediately receive a violation notice regarding their unit. A number of residents have said that they are hesitant to sign a petition (for anything with regards to Eton Square), for fear of this retaliation. This Group understands and sympathizes with the hesitation.

However, please voice concerns to the Board of Directors. Unfortunately, the community has NOT been provided direct contact information for the Board members and we do not have other means of contacting the board members directly. Therefore you may voice your concerns to the Property Manager listed below. Please be advised that there is no guarantee that correspondence sent to the Manager is passed along to the Board.

We suggest submitting concerns in writing, with the added request of:
“Please provide confirmation that:
• this request has been received,
• has been transmitted to the BOD,
• and provide an approximate estimate date as to when [this requested information] will be available.”

Community Association Manager / Property Manager:

Marck Rossy
FirstService Residential
11351 Random Hills Road, Suite 500
Fairfax, VA 22030
Marck.rossy@fsresidential.com
Main 703-385-1133
Direct 703-679-1524

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