Let’s recap what we learned this week:
- The New York Department of State has said that it does not intend to publish mattress sanitizing regulations because doing so would constitute an effective ban on reconditioned mattresses.
- The city’s Department of Consumer Affairs believes that poor New Yorkers—those who are least able to afford illness or the costs of eradicating an infestation—should nevertheless be able to buy a reconditioned mattress.
The state will not enforce the law and the city will not ban the sale of reconditioned mattresses—never mind the virtual petri dish of filth and arthropods included at no extra charge.
Have we mentioned lately that the bed bugs are winning?
There are no sanitizing regulations and none are forthcoming. Still, what would they look like? There are 26 states that have reconditioned mattress regulations. How do they sanitize used bedding?
Very laboriously and expensively, apparently. Let’s look at two states in order to get an idea of the regulatory and enforcement challenges.
These are the State of Nevada’s approved used bedding (used bedding includes such things as pillows and mattress pads as well as mattresses) sterilization methods:
- washing and boiling for at least 1 hour
- steam pressure for at least 30 minutes
- two streaming steam applications of 1 hour each at 6 hour intervals
- two forms of fumigation: formaldehyde and sulphur in a moist atmosphere and hydrocyanic acid gas
The State of California’s Bureau of Home Furnishings and Thermal Insulation (BHFTI) enforces the state’s sanitization law. The BHFTI regulations provide two methods for the sanitization of mattresses.
(a) The dry heat method may be used to sanitize mattresses, box springs, or similar items covered in whole by a porous material or fabric.
(b) In sanitizing by the dry heat method a temperature of 230 degrees F. shall be maintained in all parts of an approved chamber for such a period of time as may be necessary for sanitization, which shall in no case be less than one hour and 15 minutes. All chambers shall be equipped with racks or devices and the articles to be sanitized shall be so placed therein so that complete circulation of heat and gases around every article being sanitized shall be attained. All chambers shall be insulated sufficiently to insure maintenance of temperature and shall be tightly sealed to prevent any leakage of gases. A thermostat shall be connected with the heating device to provide and maintain a reasonably uniform temperature at 230 degrees F. + (plus or minus) 5 degrees.
and Chemical Disinfection:
(c) Mattresses, box springs or similar articles covered by a porous material or fabric may be sanitized with the chemical disinfectant, Steri-fab registered with the State of California, Environmental Protection Agency, Department of Pesticide Regulation for use as a disinfectant.
(1) Application of Steri-fab shall be in accordance with the chemical disinfectant manufacturer’s specification in order to provide adequate coverage by thoroughly spraying over all surfaces so that complete disinfection is achieved.
(2) The Steri-fab disinfectant shall be well mixed throughout the application to ensure adequate dispersion of the tracer chemical which can be detected on the mattress cover in the dry state by use of a hand held ultraviolet (black) light under magnification.
Okay, wait, Steri-fab? A state that prescribes dry heat as a sterilization method also accepts spray disinfectants as an alternative?
I mean, this is a mattress oven:
A mattress sterilization oven, image from American Plant & Equipment.
California law required that used/secondhand or renovated bedding be dry-heated in ovens, a sanitization process which takes two or three hours for each mattress, limiting the volume of used bedding that can be disinfected in a day.
Unlike the dry-heat method, the chemical disinfectant permits a tracing method to enforce compliance with the state’s sanitization laws. Steri-fab contains a fluorescent crystal suspension which, when exposed to ultra-violet light, can be seen, thus permitting inspectors to determine whether products have been properly disinfected.
With the alternative method the Bureau hopes that the less-than-honest renovators and businesses dealing in used/secondhand bedding will actually start sanitizing their products, rather than saying they had used the dry-heat process when in fact they had never done so. [Emphasis added.]
Of course, compliance… Using the heat, steam and fumigation methods outlined above must be a very expensive proposition. Steri-fab must therefore appear to be a cost-effective and efficient alternative. And when enforcement resources are limited, as they must be everywhere, a spray disinfectant, especially one with black-light inspection friendly qualities, must seem doubly attractive.
But, if you recall, the mattress dealer featured in the Dateline story had “boxes of Sterifab.”
I’m open to research findings on this matter, and I note that many bed bug sufferers and pest control technicians avail themselves well of Steri-fab and similar products, but it seems to me unlikely that a spray disinfectant is going to be the answer.
What sort of compromises emerge when complex used bedding sanitization regulations are actually put in practice?
In October 2006, when the State of Nevada’s Board of Health considered a variance request to the sterilization methods (link is a PDF of the minutes) from a hotel furniture dealer who wanted to use Steri-fab, the subject of bed bugs came up :
[Environmental Health Supervisor] Ms. Henderson feels that during the sterilization process it would be easy to miss the presence of bedbugs, especially their eggs and larvae. Sterifab is a surface treatment and bedbugs could be a problem inside the mattress and box springs. Sterifab dries in about 15 minutes and when this product is dry, the disinfectant factor is no longer active. Ms. Henderson indicated that it is unknown as to how deep the mattress and box springs are disinfected when using Sterifab.
The dealer cited employee worker safety concerns with the authorized methods and the previous issuance of similar variances. The fact the Steri-fab was approved for use in California was noted by the Board and they accordingly sought guidance from the lab at California’s Bureau of Home Furnishings and Thermal Insulation:
The lab employee clarified for [Environmental Health Specialist] Ms. Sylvas that the process of sterilizing the visibly soiled mattresses could not be determined; and clarified that the mattress’ visible outside fabric is sprayed not saturated with Sterifab, and was unsure of the depth of this treatment on the mattress. The lab employee indicated for Ms. Sylvas that CBHFTI had performed a test on the mattress and box springs disinfectant process using Sterifab and no information regarding the result of the test was currently available.
Just a note about the way everyone references the California regs. The Nevada Board of Health certainly did when ultimately approving the dealer’s variance request (“California has very stringent controls; and California has approved Sterifab as an acceptable product”). The Dateline NBC piece also noted California’s “strict laws and enforcement” with some surprise upon finding that all the mattress samples were contaminated, even the ones from mattresses made in California. Perhaps it’s time to adjust our perception of the California model?
It should be no surprise that New York vs Bed Bugs supports an outright ban on reconditioned mattresses. We do realize that this is a very complex problem and no one is saying that there is an easy solution. But perhaps we start by seeking to understand the depths of the challenges and by accepting responsibility.
Note: To find out what happened after the variance hearing, read this post about the Southern Nevada Health District’s mattress regs. This story has a happy ending.