The actions of Eton Square Board of Directors Kill Pets, Wildlife and Wastes Community Funds – A Briefing
This statement regards rodent control in Eton Square. To clarify, this is not an objection to rodent control itself, but the manner in which it is being addressed by the Community Manager and the Board of Directors (BOD).
In May 2019, the Community Manager and BOD claimed that Eton Square had a “rat problem”. One resident was asked to remove a bird feeder from outside the patio. The resident immediately complied. Effective pest control requires Integrated Pest Management (IPM): exclusion and sanitation. This industry-accepted practice was not considered. Rather than wait to see if food and / or water source removal (exclusion) would solve the “problem”, or address garbage issues (sanitation), the Board had a contractor set out fifteen (15) poison bait stations – a week later. Despite frequent objections, the Board continues to employ poison without utilizing good practices of IPM. This poses significant safety risks to all and requires unnecessary increased costs to the community.
Despite several inquiries, we still don’t know what constitutes a “problem” and how long the Board intends to poison our community.
WHAT IS CONSIDERED A “PROBLEM”?
Old world rats and mice adapted well to living around people. So well, in fact, that they are commonly called commensal rodents. The word “commensal” comes from the Greek word meaning “with” and menna meaning “table.” Commensal literally means a “companion at meals,” an apt description in many rodent infestations. Wherever there are people, there is food, water, and harborage for commensal rodents. Rats and mice most often become pests when people mismanage trash, provide easy access to food and water, allow entry inside buildings, and practice poor sanitation. The best way to control rats is to discourage them from taking up residence in the first place.
Rats are rodents that do actually serve a purpose in the ecosystem. They are scavengers and opportunistic eaters. They will eat garbage and other things that people throw away. Rats play an important role in prompting tree growth around the world by spreading seeds. Plus, rats are important as part of the predatory ecosystem. Owls, falcons, hawks, and other predatory animals feed on rats. The animal ecosystem is a delicate balance and losing one element within it can be detrimental to the entire system. Some lizards, reptiles, and snakes prefer to feed on rodents such as rats, for example.
As they are an inherent part of the natural ecosystem, seeing one rat is not cause for alarm.
Despite numerous requests, the ESBOD has not provided evidence of infestation.
ASSUMING THERE IS A “PROBLEM”. NOW WHAT?
Rodent control is not simple. Rodents are intelligent, adaptable, prolific, and secretive. So secretive and wary, in fact, that hundreds of them can be living in, under, and around a complex of buildings and few people in the area will be aware of their existence. Rats and mice can also survive even in the most adverse conditions. Because they are so successful as pests, the most effective way to deal with rodent problems is to use an “integrated” approach to prevent rodent outbreaks and to manage rodent problems for the long term.
What is Rodent IPM? Integrated Pest Management (IPM) is a system of managing pests that integrates prevention (through pest-proofing, improving housekeeping, good trash management, etc.) with corrective measures (trapping, baiting, product disposal, etc.) to kill or otherwise eliminate pests. At the same time, IPM minimizes risks to people and the environment from rodenticides and other control measures. Rodent IPM differs most from traditional rodent control in that it does not normally depend on automatic application of rodenticides. Prevention of rodent problems is emphasized.
Take, for example, the case where rats have been seen by the dumpsters located behind an apartment building. The typical action of a pest control technician might be to install a dozen bait stations, which would be serviced at each subsequent visit and rodenticide replaced as needed. As long as the bait was being taken, the technician would figure he was doing his job. This could go on for months or years.
But, of course, the technician has it backwards. If the bait continues to be taken, there are still rats at the site. Rats might be dying, but the problem is still ongoing, and the apartment manager still has a problem, and a larger crisis is just waiting to happen. IPM approaches the problem differently. The causes of the problem need to be figured out prior to starting control. Some basic questions need to be asked, such as: Why did the rats suddenly appear? What are they feeding on? Where are they nesting? Where did they come from? What can be done to prevent them from invading the site in the future?
Whatever the root of the problems, in IPM the goal is to make the changes necessary to remove food and eliminate harborage that were attracting the rats to the site in the first place.
Speaking of prevention, in a good IPM program, the rat problem at the dumpsters might never have occurred. IPM would have included regular monitoring of the site that should have identified the trash management problems, potential nesting areas, and adjacent problem sites before the rats began causing problems.
From: Rodent Control. Maryland Pesticide Applicator Training Manual. Category 7D. https://mda.maryland.gov/plants-pests/Documents/Rodent_Manual.pdf
Rodent management programs face many challenges. First, the program should utilize thorough and up-to-date knowledge of rodent control. This includes knowledge of rodent biology, IPM practices, rodent control devices, and the characteristics and risks associated with rodenticides. Such knowledge is critical not only to achieving successful control but also to providing the public, proactively and on demand, with information on the area’s rodent control program.
Plans should provide for the abatement of potentially unsanitary conditions attractive to rodents, such as trash in open containers, accumulations of junk and clutter, overgrown and noxious vegetation, stagnant water sources and improperly maintained structures. Rodent management programs cannot rely solely on traps and bait. Proper enforcement is a key component of effective rodent management.
WHAT HAS ESBOD DONE SO FAR?
Wed, May 15, 2019
The first proposal provided by Alexandria Pest Services:
Location: Eton Square (6914 Ellingham Circle), Alexandria, Virginia [THIS IS ONE BUILDING]
According to records, only one pest control company was originally consulted. This proposal contains several “remediation recommendations”, most of which have not been addressed:
- “areas requiring structural repair & pest proofing and strategic locations for rodent elimination asset installation”
- “Remediation of sanitation issues of concern and other such matters”
- “Remove water source around Coffer.”
- “Replace vent on pipe located up against foundation”
Additional 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.
“Initial installation of 15 exterior Evo rodent stations: $525.00 APS will install stations no more than 5 days after an executed contract is received.
Monthly re-inspection/rebaiting: $95.00”
Also in this proposal is a section titled “documentation” that lists details of data that APS will provide. Quote: “Rodent harvest will be suitably documented for subsequent review as needed to attain optimal control program results.” Requests for this documentation have been ignored.
May 24, 2019
Without warning, fifteen (15) bait stations were installed behind buildings 6914, 6924, 6934
August 6, 2019
Location: Eaton [sic] Square
This proposal contains several recommendations, which have not been addressed:
“Trash should be placed in containers/trashcans to prevent rodent activity.
- “Compost piles makes perfect harborage for rodents to nest in.”
- “Standing water will attract rodents/wildlife for drinking.”
- “Pet feces should be picked up to prevent rodents from using as a food source”
- “areas requiring food/water/nesting removal and strategic locations for rodent elimination asset installation.”
- “Remediation of sanitation issues”
“Initial installation of 120 exterior decorative rodent stations around 30 buildings (4 stations per building): $4,200.00.
Initial Installation of 120 EVO rodent stations (black stations): $3,000.00
Monthly re-inspection/rebaiting: $175.00”
September 3, 2019
Email to Eton Square from Marck Rossy, Community Manager
“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.”
ACCORDING TO IPM, WHAT ISSUES NEED TO BE ADDRESSED, SPECIFIC TO ETON SQUARE?
When a rodent problem requires action, IPM looks first to those methods not requiring rodenticides. Emphasis is placed on those methods that work over the long term, or that prevent pests in the first place, such as pest-proofing (exclusion) and improved sanitation (good housekeeping, proper trash management, etc.).
Rodent control begins with sanitation. While rodents find warmth and shelter inside structures, food is their first reason for living in and around structures.
Eton Square needs to address the multiple issues with garbage and refuse. 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.
Water management is also important for rat control. Outdoors, water should not be allowed to puddle around structures. Faulty grades should be filled to slope away from the structure. Gutters and downspouts should be kept free of debris. Water should not be allowed to stand around air-conditioning units.
Eton Square needs to address issues with water sources, such as leaking, damaged hoses and hose bibs; french drain puddles; air conditioning runoff and more.
As a rule, anything that will make a structure less hospitable to rodents should be considered important. Along with sanitation, exclusion is the first line of defense against rodents.
Sanitation and exclusion work together to enhance the effectiveness of trapping and baiting; all are components of an integrated rodent management program.
Eton Square needs to address issues with nesting materials, such as compost piles.
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.
The proposals provided by Alexandria Pest Services list a number of recommendations. Only one these have been considered or enacted.
According to both the scientific community and the pest control contractor, there are several other structural improvements and repellent options available. Only one of these have been considered or enacted.
Not only are bait stations are considered to be ineffective long term, but ignoring IPM practices is not financially responsible and ensures program failure.
ESBOD has not employed SANITATION or EXCLUSION factors in order to address the problems. Without an integrated approach, pest management will not be successful.
Several attempts to acquire data or information regarding this process have gone unanswered. Inquiries have been presented via email and via board meeting. Questions were either ignored or given insufficient responses.
WHAT ABOUT RODENTICIDES?
There are several issues with using rodenticides: 1) they are counterproductive, 2) they are unsuccessful, 3) they cause non target harm to pets, wildlife, children and adults, 4) there are currently poor practices with bait stations at Eton Square, 5) this constitutes wasteful spending.
Rodenticides can be counterproductive to rodent control by poisoning, harming, and killing natural predators that help regulate rodent populations.
Killing rodents can only provide short-term control of populations.
The principle of the “Poison Cycle” is described as such:
- Resident or Business complains about rats and calls pest company.
- Instead of looking at why rats are present (attractants) such as: ivy, garbage, water, pet food left outside, etc.,
- Pest Control Operator puts out poison BAIT.
- Poison bait boxes are now in your community.
- A rodent smells BAIT and eats poison. One feeding will kill, BUT death takes several days. The rodent grows weaker and is easily caught by beneficial predators.
Non target harm to pets, wildlife, children and adults
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 their experience, it does not address proven safety concerns and risks regarding poison bait stations. It is not a defensible response.
Several 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.
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.
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.
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.
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
Graphic: 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.
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.”
Poor practices with bait stations at Eton Square
Bait stations should not be placed where livestock, pets, or other non-target animals can disturb them. Non-target poisonings can occur in unusual ways. A zoo once lost monkeys to poisoning after they ate cockroaches that had fed on rodenticides.
Bait stations should not be placed in areas exposed to afternoon sunshine. Internal temperatures of bait stations exposed to the sun can be 20 to 30 percent hotter than the surrounding air — hot enough to melt bait blocks.
(Source: Bait Stations for Controlling Rats and Mice, University of Nebraska)
Bait stations should be numbered and labeled, and their locations mapped. A label on each station should warn of the rodenticide within, and include the user’s name and contact information. The station should also have a card or label on which technicians can record the date each station is checked. THERE ARE NO SAFETY LABELS or POSTED WARNINGS in Eton Square.
Over the years rodenticides have been overused along with being misused.
Professionals use rodenticides because they do offer a number of advantages: Rodenticides are effective when used properly. Rodenticides come in a wide variety of formulations and products. Baits are available in blocks, pellets, seeds, meal, liquid, and granules that are mixed with various food attractants. If one formulation is not accepted, there are others that can be substituted. Rodenticides are economical, because the use of them does not require much time on the part of the technician.
There are also disadvantages to using rodenticides, such as overdependence. A major disadvantage to using rodenticides is that technicians along with customers become dependent on them. It seems easier and cheaper to apply rodenticides every month rather than addressing improper trash handling practices, poor sanitation, or structural deficiencies.
This constitutes wasteful spending and is financially irresponsible.
A pest control program without Integrated Pest management will be unsuccessful. Using rodenticides alone incurs more costs, long-term. See below.
HOW IS ALL OF THIS A WASTE OF COMMUNITY FUNDS?
By ignoring accepted IPM practices, and not addressing issues with SANITATION and EXCLUSION, the pest management program will continue to fail.
[Note: The BOD has been asked for information regarding program “success”. These inquiries have gone unanswered. We do not know what constitutes “success” by the BOD.
- 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.]
For the contractor, as long as the bait is being taken, they figure they are doing their job. This could go on for months or years – with a neverending cycle of invoices and costs.
RODENTICIDE alone is not successful, and carries high safety risks along with repeated monthly costs.
Despite the fact that poisoning is not the best way to deal with most problems, the ESBOD continues to use poisons.
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) due to fear of 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 any 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:
11351 Random Hills Road, Suite 500
Fairfax, VA 22030