12.2 Categories 2a & 2b: Wood-Destroying Organisms, WDIIR & TARF Reporting
Key Takeaways
- Arizona splits wood-destroying organism work into Category 2a, treatment by means other than a fumigant, and Category 2b, inspection only — and the inspection category expressly excludes preparing treatment proposals.
- Wood destruction work carries its own financial security: a business performing termite treatments needs $100,000 of surety or policy rider for termite damage due to negligent treatment, and a business issuing inspection reports needs $100,000 for errors and omissions.
- A Termite Action Report Form must be submitted to the PMD within 30 days of completing a pretreatment, new-construction treatment, final grade treatment, initial corrective termite treatment or a WDIIR, with the fee and any late penalty.
- The dominant Arizona subterranean termite is the desert species Heterotermes aureus, which drives the state’s pretreatment-heavy construction practice and its very high volume of termite reporting.
Categories 2a & 2b: Wood-Destroying Organisms, WDIIR & TARF Reporting
Core Principle: Termite work is the most heavily reported activity in Arizona pest management, and the reason is structural: the desert subterranean termite is ubiquitous, nearly every new slab is pretreated, and almost every real estate transaction generates an inspection report. Arizona responds with a dedicated reporting system and a deliberate split between the person who inspects and the person who sells the treatment.
The Category Split, and Why It Exists
| Category | Scope |
|---|---|
| 2a — Wood-destroying organism treatment | Inspecting for the presence or absence of wood-destroying organisms and treating for them in or about a residential or other structure, by a means other than use of a fumigant |
| 2b — Wood-destroying insect inspection | Inspecting for the presence or absence of wood-destroying insects only, and excluding preparing treatment proposals |
| Wood preservation | Applying pesticides labeled for utility poles or railroad ties directly to structural wood or wood products not part of an existing structure, including drilling a cavity, inserting methylisothiocyanate or a similar product, and sealing the cavity |
The exclusion in 2b is an ethics control written into the licensing scheme. A wood-destroying insect inspection report frequently governs a property sale, and the incentive to find findings that justify a contract is obvious. By separating the factual report from the commercial proposal, Arizona reduces that pressure structurally rather than relying on good intentions. Fumigation for drywood termites is a Category 6 activity, not 2a.
The Arizona Termite Complex
| Organism | Practical significance |
|---|---|
| Heterotermes aureus — desert subterranean termite | The dominant structural species across the low desert. Forages actively in warm conditions, builds drop tubes from above as well as shelter tubes from below, and is the reason Arizona construction is pretreatment-heavy. |
| Reticulitermes spp. | Present at higher elevations and in cooler parts of the state. |
| Drywood termites | Do not require soil contact; infest sound dry wood. Localised treatment or fumigation, and fumigation moves the job to Category 6. |
| Wood rot and decay fungi | Moisture-driven. Correcting the water source is the control; chemistry alone fails. |
| Wood-boring beetles | Identification determines whether the infestation is active or a legacy of infested lumber. |
Treatment Methods
Pre-construction (pretreatment). A continuous horizontal chemical barrier applied to the soil beneath and around the slab before concrete placement, with vertical barriers at footings, plumbing penetrations and expansion joints. Continuity is everything: a gap is a highway. If a treated barrier is disturbed after treatment, the disturbed area must be re-treated.
New-construction treatment. Applied during construction after the pretreatment stage, again subject to the continuity requirement.
Final grade treatment. Establishing the exterior vertical barrier once grading is complete.
Post-construction corrective treatment. Trenching and rodding the exterior perimeter, drilling through slabs and hardscape to inject beneath, and treating voids in block walls. Baiting systems provide a monitoring-and-elimination alternative where drilling is impractical.
For pretreatment, new-construction and final grade work establishing an exterior vertical barrier, the report must state the chemical used and its EPA registration number, the amount used, the percentage of active ingredient, and the square and linear footage treated. For a post-construction corrective treatment, it must state the type of treatment, the target organism, the chemical and EPA registration number, the amount used and the percentage of active ingredient.
Financial Security Riders
General business licensing requires at least $500,000 of financial security under A.R.S. § 3-3615. Wood destruction work adds two specific $100,000 per business license requirements:
| Trigger | Requirement |
|---|---|
| The licensee performs termite treatments | A surety bond, or a liability insurance policy rider, of $100,000 for actual damages including reasonable costs of collection suffered as a result of termite damage due to negligent treatment |
| The licensee provides wood-destroying insect inspection reports | A surety bond or policy rider of $100,000 for actual damages plus reasonable costs of collection arising from errors and omissions in the reports |
Where the security is liability insurance, the required endorsements include care, custody and control, and wood-destroying insect inspection report errors and omissions.
The Reporting System: WDIIR and TARF
WDIIR — Wood Destroying Insect Inspection Report. The applicator submits the completed WDIIR within seven days of completing the inspection (R3-8-501). The business licensee records on it the TARF number; and if the property is under warranty, the account number, target pest, date of initial treatment and date of warranty expiration; plus the TARF number of each subsequent TARF completed for the property.
TARF — Termite Action Report Form. Submitted electronically to the PMD within 30 days of completing each of:
- a pretreatment, including pretreatment of an addition that does not abut the slab of a previously pretreated structure;
- a new-construction treatment, including such an addition;
- a final grade treatment;
- an initial corrective termite treatment at a site; and
- a WDIIR.
Each TARF carries a fee, plus any penalty under R3-8-103. Failing to submit the form or fee within 30 calendar days exposes the licensee to a penalty of not more than $100 per form under A.R.S. § 3-3631.
When a TARF is not required: after a supplemental WDIIR; and after the first initial corrective termite treatment at a site where the licensee performed the pretreatment or new-construction treatment, filed a TARF for it, and performs the corrective treatment under R3-8-309(D) or under a warranty.
Completion, for reporting purposes. A pretreatment or new-construction treatment is complete when no further preventative treatment is necessary until the final grade treatment — unless a disturbed continuous chemical barrier must be re-treated. On a multi-unit project, it is complete when no further preventative treatment is necessary for the last unit at the project.
WDIIRs are retained three years, as are service records, inspection reports and contracts.
A technician certified only in Category 2b inspects a home for a real estate transaction, finds evidence of subterranean termites, and prepares a written treatment proposal with pricing for the seller. What is the problem?
A business licensee completes a final grade treatment on a single-family home on 3 March. By what date must the Termite Action Report Form be submitted, and what is the exposure for missing it?
A pest management business performs termite treatments and also issues wood-destroying insect inspection reports. Beyond the base financial security, what additional coverage does A.R.S. § 3-3615 require?
Why does Arizona construction practice rely so heavily on pre-construction soil treatment, and what does the continuity requirement mean in practice?