AEPMA notes on updates to AS 3660-2 2017

The newly updated AS 3660.2 ‘Termite Management – In and Around Existing Buildings and Structures 2017’ represents some significant changes to the way we conduct termite work and although much has remained consistent with its predecessor, there are new additions and procedures.

Some of these changes will be welcomed while others will be more challenging, however the following synopsis should not be viewed as a critique but merely an attempt to create some consistency with the way these changes may be interpreted.  AEPMA has consulted stakeholders throughout the industry including insurers, manufactures, AEPMA members and those who represented our industry in the creation of this Standard.
When reading this synopsis it’s important to note the following:
  • This is not a complete account of the document and only highlights some of the changes between the Standards. If you are undertaking work to this Standard then you should own a copy, read it, understand it and make your own judgments as to its interpretation in unison with your insurer and other relevant bodies.
  • You need to ensure your paperwork is updated to accurately reflect the changes and where appropriate, speak to your paperwork provider.
  • It should be noted that this synopsis is not an endorsement of this Standard and that some of the issues highlight the importance of our own industry’s Codes of Practice.
The preface specifically states that ‘each system manufacturer’ claiming ‘conformance’ with the new Standard needs to demonstrate that it conforms to AS.3660.3 2014. Accordingly, unless the label states as much you will need to seek clarification from the product manufacturer. 
Section 1: Scope-
There is a greater recognition of the potential for damage by dry and dampwood termites but the Standard again stresses that it does not deal with their management. If discovered however, the inspector does have a ‘duty to warn’ if there is potential for these species to have adverse effects on the structure.
Within the scope there is also a reference to the National Construction Code and bushfire construction requirements. In section 2, it requires that the installation of a termite management system should not affect bushfire management systems and places the onus upon the pest controller to address this issue with the owner.
The following definitions been added – 
  • Baiting system: For the purposes of this Standard, this term is used to cover aggregation system and systems where a termiticide is applied either in a bait matrix or onto termites feeding in baits.
  • Competent person: A person who has acquired through training, qualification, experience or a combination of these, the knowledge and skill enabling that person to correctly perform the required task. NOTE: Australian competency standards relevant to termite risk management are currently under the specifications for CPP30115—Certificate III in Urban Pest Management. Achieving competence in the field typically requires a degree of experience and local knowledge.
  • Colony:  A termite colony consists of a group of termites that share a gallery system and work with a degree of cooperation. A colony may contain one or more reproductive groups.
  • Monitoring system: Aggregation system and systems where the provision of a highly palatable food source is used as a bait or lure to aggregate termites and/or allow the exposure of termite activity. NOTE: This does not exclude a monitoring system that utilizes a food source that contains a termiticide in a bait matrix.
  • Pesticide register: The government body responsible for the registration of pesticides. NOTE: Currently, the Australian Pesticides and Veterinary Medicines Authority (APVMA) coordinates the registration scheme.
  • Shall: Indicates that a statement is mandatory.
  • Should: Indicates a recommendation.
  • Termiticide: A chemical product, approved by the pesticides registrar which is used to kill termites.
A contentious definition is the ‘competent person’, the definition of which is not too dissimilar to the previous standard and does leave the door open for varying degrees of competency based on ‘experience’ and the like. Positively however, it does specify Cert III in Urban Pest Management as a recognised qualification for competency making it harder to prove competency without the attainment of this qualification. This is a reference to a minimum standard of competency and some States and Territories require Units 8 and 10 as part of their licence while some insures require these units before they will insure someone to perform termite management independently.
Section 2: Identification and Management of Termite Risk
This Standard has elevated the importance of ‘integrated pest management’ and very much focuses on drainage and soil moisture as an important part of risk management. A table of important indictors of drainage issues is also provided within this section of the Standard which you should review.
Further, we must also make comment if the building elements don’t comply with AS 3660.1 and the way that this may impact any termite management system. For example if a concrete slab or soil chemical system are forming part of the existing termite management systems then its appropriateness must be assessed.
Some confusion has come about regarding what is deemed an accessible area within subfloors as the Standard references a table where subfloor access is not in fact specified. However, the subfloor access requirements are addressed by referencing AS 3660.1 s.3.2.2 which requires 400mm clearance between bearers and other elements such as ducting and plumbing and the finished ground level or reduction to 150mm within 2m of an accessible area. Roof space 600x600.
Section 3: Inspection and Detection
The new Standard recognizes the requirement for different types of inspections as follows-
  • - AS 4349.3 timber pest inspections must be used for property prior to their purchase, this does not preclude its use in the same way that a regular inspection is applied. 
  • - “Regular inspections” are termite inspections as part of new or on-going termite management, and not to be spaced more than 12 months apart. Such inspections are a clear and specific requirement of the Standard prior to any actions to control termites.
  • “Special inspections” may be undertaken as part of actions to control termites, and should be no more than 6 months apart. They may include intrusive inspections if agreed with client.

The Standard stipulates the conditions under which ‘special non-destructive tools’ should (recommended) be applied i.e. when areas of moisture that can’t be readily explained or termite activity is suspected. This does not preclude you from recommending an invasive inspection first.

Additions to the specific details required in an inspection written report include:

  • Time of the inspection,
  • Weather conditions,
  • The potential for associated damage arising from the termite activity,
  • The potential for associated damage where evidence of termites is located,
  • Inspection records kept for 3 years (this is the minimum however, keeping your records for 10 years would be in keeping with the standards requirements for treatment certificates) 
  • An assessment must be made as to the presence and maintenance of any termite management system, and where evidence of previous chemical treatment is observed, report the period of protection per label if the chemical can be identified,
  • Construction aspects such as non-durable timber in contact with the ground must be reported.
Greater importance is made on the identification of termite species including genus and species (samples may need to be taken).
Photos are now a necessity to form part of the site record and a camera must be available during an inspection (see below)
The Standard lists the tools required for an inspection and separates these between shall (must) and should (recommended).   You must have:

(a) Bright light (torch or similar portable device).

(b) Camera.

(c) Ladder, providing access 3.6 m above ground or floor level.

(d) Measuring tape or ruler.

(e) Moisture meter.

(f) Probe or knife.

(g) Protective clothing and respirator (where inhalation risks are identified).

(h) Tapping tool (‘donger’).

You should have (one or more):
  • Radar
  • Termite detector animal
  • Thermal camera 
Again the Standard has given greater importance to the identification of any conducive conditions that are caused by structural issues. The inspection shall include the potential for or presence of water or dampness in unintended locations, as follows: 
  • Absent or ineffective moisture barriers,
  • Poor drainage or ventilation,
  • Water entry due to, for example— 
  1. Leaks through damp-proof courses or flashings; 
  2. Leaks through waterproofing membranes; and 
  3. Leaks from roof and stormwater disposal system. 
  • Excessive moisture in building elements. 
It may be challenging for termite inspectors to give advice on building details such as damp proof courses, flashings and air vents spacing, since training in these technical matters may not be included in Cert III courses. It may be appropriate for the inspector to report on detecting symptoms such as dampness or pooling water and recommend that client seeks professional advice for that particular building detail. In other instances, such as where air vents are obstructed, the inspector should be able to report on these including the implications of compromised ventilation.
Section 4: Termite Management Plan
This is an entirely new and challenging section within the Standard and is intended to set out the desired outcome of a treatment, the time scale to which it will be performed and the methods used to manage the termite risk identified. It is aimed at reducing the risk of misunderstanding between contractor and client and promotes an understanding of the process. It specifically sets out that it is not to be considered a quote rather it is an independent document. Further, it states that no treatment can claim to conform with the Standard unless the requirements under a termite management plan have been met.
In short, this is a new process requiring a document that includes findings from the inspection report and is to be issued prior to a management action. Paperwork providers are currently working on how to best implement this new requirement in a streamline way. They may produce forms which incorporate the plan into a proposal, and reference the inspection report. You should speak to your paperwork provider.
The Standard sets out the minimum content for the plan (but does allow for additions) as follows:
Property and Client details: self-explanatory 
Summary of relevant findings from the inspection report: The focus of this section is on termite activity, damage or risk of infestation as documented in the inspection report. It specifies a need to identify, as far as practicable, the termite species and effects that this species may have on the treatment or risk assessment. It specifies that limitations described in the inspection report do not need to be replicated.
Risk Assessment: The risk assessment shall include detail as to the known capabilities of the termites, the likely consequences of inaction and all risks associated with the proposed management actions, including chemical used and the risk to off-target organisms.
The proposed course of action:  This section is required to include:
  • The proposed action to manage the termite risk,
  • Include options of treatments and state why a particular treatment is preferred,
  • Where a sole option is offered an explanation as to why,
  • All steps to be taken within the plan,
  • The time expected on site and the quantity of visits required,
  • A list of all works required, and 
  • A list of any changes needed to be completed prior to the commencement of the proposed work, for example access hatches to be created or the removal of perimeter water tanks etc.
Anticipated outcome: A summary is required explaining the expected outcomes, ongoing management requirements, duration of works and the number of visits and criteria to measure success or failure.
Section 5 Termite Management Actions
Section 5 of the new Standard has effectively merged both section 5 and 6 from the old Standard and included appendix D (certification of termite treatment). It focuses on risk mitigation (conducive conditions), treatment sequence and methods. 
If the inspection report lists general risk factors, steps must be taken to reduce the risk. They include
  • Cultural
  • Improved inspectability
  • Physical or chemical TMS
Again, these risk factors will need to be highlighted with a recommendation for the client to address them.
Monitoring systems may be installed. It does not state the circumstances or purpose of monitoring systems, and does not clarify that they may be used for long term risk reduction if chemical soil applications can’t be done. The time between monitor inspections (services) must not exceed 3 months.
There is a central focus on colony control measures followed by chemical soil application- it provides no further discussion of monitoring systems.
The section gives a formula for an acceptable level of risk which they deem to be where the frequency of inspections combines with risk reduction measures creating a scenario where significant damage of undetected termite activity is unlikely to occur. There is potential for this equation to fail and the recommendation for further appropriate termite management systems should be made. 
The details of this section 5.3.3-5.4.3 are broad and will require closer examination but in short it states that ventilation, vegetation, drainage where they affect conditions of the structure as set out in the National Construction Code (NNC) , act as a conducive condition or compromise a termite management system shall (must) be rectified. The competence of a termite inspector to comment on the NCC needs clarification, but clearly the Termite Management Plan should describe the issue.
This Standard now specifies particular criteria for vegetation that either needs to be reported on or inspection provided, these include – 
  • The removal of all susceptible dead wood, stumps and roots over 50mm in diameter within 5m of structure, 
  • The removal of susceptible trees that will grow more than 10m in height that are planted within 5m of  the structure, and
  • All trees within 50m of the structure that are 200mm or greater in diameter are to be ‘inspected’.
The application of this advice will be hard for a pest manager to judge and again, may have to advise the client to consult and arborist who has good local knowledge of plants and council regulations.
An entirely new provision regarding natural predators to termites has been introduced. Natural predators should not be reduced due to the implementation of a termite management plan. The practicalities of this are hard to estimate.
Steps to control attacking termites
Actions to eliminate a termite colony or reduce their numbers need to be attempted prior to other measures.
A performance criteria has also been provided for colony eradication via the introduction of chitin inhibitors. A list of recognised symptoms of termites affected by IGRs is given.  It classifies the cessation of the reproductive function as an important part of causing colony collapse.
The Standard states that termiticide dusts must be ‘non-repellent’, and that the uses of arsenic trioxide dusts can no longer be used in occupied structures. 
The Standard states that ‘if insufficient activity is found to indicate the likely success with termiticide application through dusting, foaming or liquid applicant’ then baiting may be used. This suggests that the Standard regards baiting as less preferable to dusting\foaming etc. Also, requires the ability to ‘gauge’ the ‘level’ of activity in the structure as the dictating factor in determining the course of action rather than building design or points of entry.
Chemical soil application
The new Standard sets out similar conditions to the previous Standard but if application are not continuous then this should be documented and a recommendation for more frequent inspections must be made. 
In addition the Standard places heavy caveats on internal drilling of slabs where an engineer’s opinion must be sort to ensure that damage to the structural integrity of the slab and vapour barriers won’t be compromised.
The application method for chemicals now references to AS 3660.1 2014 as opposed to the previous Standard’s appendix E. 
Chemicals applications need to comply with Section 7 AS 3660.1 2014 and also allow for retrofitting of products to AS 3660.1 2014 and includes a note stating that products that meet CodeMark can be used to achieve this.
Cert of Installation
Certification needs full details of products and volumes. In particular, reticulation systems are singled as requiring details of volumes and pressures for each fill point. Certification also needs to specify the following:
  • The extent of the termite management systems and if integrates with other systems
  • Servicing requirements,
  • Advice on on-going management,
  • Contact details,
  • If concrete slab is part of system then conformance of the concrete to AS 2870 or AS 3600 is required.  Where a slab conformance cannot be ascertained then this is to be noted,
  • Certify details under a suspended floor including measurements of clearances and grading of surface for drainage, air vents, and treatment to stumps/ piers/ footings,
  • Keep records for 10 years,
  • Durable notice- Updating the durable notice will be required so the Standard should be consulted for the new details but most is not too dissimilar to the previous Standard. Notable changes include where reticulation systems are installed the notice must detail pressure and volume for any retic access point and recommendations for reapplication chemical type and dilution are also required. Must be in meter box or reasonable equivalent.
Clearly, a termite inspector may not be able to confirm compliances such as slabs to AS 2870, so it is probably appropriate to recommend to the client that they make enquiries and report back.