You know how we’ve spent all this time saying that bed bugs in our city merit a determination of public health concern?
You will not believe this but it turns out that bed bugs have been deemed a pest of public health importance—sorry, a pest of significant public health importance—since 2002.
No, no. We’re talking statutory definition—or is it regulatory definition?
Check this out: the Environmental Protection Agency’s Pesticide Registration (PR Notice) Notice 2002-1: List of Pests of Significant Public Health Importance (PDF)
On page 7 you will see those familiar words, bed bug, Cimex lectularius.
What is the purpose of the List of Pests of Significant Public Health Importance?
It’s essentially guidance, but it’s supposed to be a tool:
Section 28(d) of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) requires the United States Environmental Protection Agency (EPA), in coordination with the United States Department of Health and Human Services (HHS) and United States Department of Agriculture (USDA), to identify pests of significant public health importance and, in coordination with the Public Health Service, to develop and implement programs to improve and facilitate the safe and necessary use of chemical, biological and other methods to combat and control such pests of public health importance. Issuance of this list fulfills the requirement of FIFRA sec. 28(d) to identify pests of significant public health importance as a part of this process.
Right.
So, now these agencies are going to develop and implement programs to improve and facilitate the safe and necessary use of methods to combat and control bed bugs, right?
Hmm? It’s the law.
These pages may be of related interest:
- A pest of significant public health importance, cont’d
- Bed bugs and public health at the 6th International IPM Symposium
- Extraordinary (breaking) news: an EPA bed bug conference in Washington on April 14
- NYC Health Code, Pest Prevention and Management
- Public health significance of bed bugs: a new tool for action
Renee,
Please consider the entire scope of the list. Your frustration is appreciated, however, have you ever led a campaign against spiders, cockroaches, flies, mosquitoes, geese, or all of the species of birds that are on the list? Probably not, because they don’t bother you like the bed bugs do. The intent of the list is to point out the species of “pests” that the pest control industy is being asked to respond to. We’ve done a nice job on the majority of the pests on the list. And, the fact is, the pest control industry is capable of doing its’ job to eliminate bed bugs. What the industry is researching is for a quicker, less invasive, method that will eliminate bed bugs. Not only are PCO’s presented the challenge of performing extensive inspections, and having to use a broad approach when determining a treatment plan, but we are challenged with trying to keep the cost of the treatment down AND having residents do their part, as well. What the industry is researching is for a treatment that will not have to rely as much on a resident following the now established protocol. The cost of a treatment is expensive enough, now. Imagine what the cost would be if PCO’s were required to pick up clutter, do laundry, bag items, vaccuum, remove and dispose of a persons items, return two days latter and do more laundry and more vaccuuming, pick up more clutter, return 2 – 3 days later….and it goes on and on. Treating for bed bugs is more of a challenge than other pests. The industry has done a wonderful job in developing products to eliminate a broad list of pests. And consumers have grown accustom to our success in doing so. This time, it’s not so easy and the customer has to do some work themself.
Actually, I am considering the scope of the list.
The bottom line is that they’re on the list. State agencies should be in dialogue with the relevant federal agencies, especially EPA, already, not just thinking about it.
I don’t know where you live, Rich, but where I live there is a little problem called treatment failure. And it is NOT simply a matter of tenants not cooperating. I’m disappointed that after all our conversations you are still putting the responsibility for treatment failure squarely on the shoulders of tenants. It’s self-serving and not persuasive. The sooner we start to work together on all the challenges we face, the sooner we can achieve control.
Renee,
No, I do not place the responsibility of treatment failure squarely on the shoulders of tenants. If you think back to some of our earlier discussions, I was in complete agreement with you when you commented about the treatment techniques used by some PCO’s. I, too, am disappointed when I hear of inadequated treatment plans being implented by pest control companies. For example, just two weeks ago (initial treatment) and again this week (first follow-up treatment), I was involved in a case where Terminex had provided a plan which DID NOT include encasing mattresses and box springs. Their initial plan was to treat baseboards and bedroom furniture ($199.00 + tax), and then follow-up with MONTHLY treatments ($66.00 per treatment) for the next eleven months. As you well know, the $1,000.00 that would have been spent over the next year wouldnot have remedied the problem. The customer further stated that Terminex failed to inform them of their responsibiliy to launder clothing, remove clutter, or any of the other list of items that are common protocol for bed bug treatments. The person hired my company, and, after our initial treatment, the following week three bed bugs were observed by the customer (all of which were moving very “slowly”), and since the first follow-up treatment, no bed bugs have been observed. However, the customer, after using our service, was provided the correct protocol, has followed the protocol, and I am certain that after 2 – 3 more weekly follow-up treatments, will be bed bug free. Further, I am in complete agreement that, with the severety of the bed bug problem, and the number of PCO’s who are not knowledgable in the area of proper bed bug treatment, that there should be an additional license endorsement required by PCO’s who treat for bed bugs. If a company is going to treat for bed bugs, they should be able to demonstrate that they have the know how, and they should be required to follow the protocol. Those companies that do not, should be sanctioned and/or fined. But, that’s my personal opinion, and it’s not well accepted by my peers. I am as frustrated with you when I hear of companies that were hired for bed bug treatments, and the company makes the customer feel all warm and fuzzy only to provide substandard services. It is indeed a problem in the industry.
Thanks, Rich. Yes, I do recall when you stated that and apologize for misrepresenting your view.
Our hope is that successful treatments will be within the reach of everyone. Since they are not at the moment, we all have a shared interest in ensuring that there is better training, more knowledge, more education out there, for everyone. I am unpersuaded by those who object to training for PCOs. None of the arguments they offer are sound.
Perhaps proper training, and licensing, for PCO’s who treat for bed bugs should be added to your lobbying efforts. Let’s step back for a moment, and take an objective look at the challenges that face us. A more systmatic, and honest, approach may be in the best interest to everyone. My open mic remains open.
Actually, we do advocate training for pest control professionals. It’s part of our list.
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AFTER READING THROUGH THE THE E-MAILS FROM RENEE AND RICH ALL I CAN CONCLUDE IS HOPEFULLY WE’RE AN THE SAME PAGE AS FAR AS PUBLIC EDUCATION IS CONCERNED. HOWEVER, THE REAL PROBLEM STILL IS INCONVENIENCE AND COST.
UNFORTUNATELY NEITHER CAN BE AVOIDED.
THE CUSTOMER IS PROVIDED WITH A PREPARATION GUIDE ,
WHICH IS EXTENSIVE , AND MOST PEOPLE CANNOT OR WON’T
COMPLY 100%. THE OTHER PROBLEM IS COST- WHICH I HOPE THE LANDLORDS OR MANAGEMENT COMPANIES WOULD ABSORB OR AT LEAST SHARE. EVEN IF THE CUSTOMER IS WILLING TO SELF-PAY – A TRAINED AND LICENSED TECHNICIAN DOES NOT COME CHEAPLY. THE TREATMENT IS EXTENSIVE AND TIME CONSUMING( NOT TO MENTION CHEMICAL COSTS).
FURTHERMORE THE COST OF BEDDING ENCASEMENTS OR
REPLACEMENTS ARE PROHIBITIVE TO SOME. EITHER WAY EVEN
IF A CUSTOMER FULLY COMPLIED AND PROSCRIBED TREATMENT
WAS APPLIED, BEDBUGS ARE ALMOST IMPOSSIBLE TO ERADICATE
WITH ONE TREATMENT. THE THOUGHT OF REVISITING THE
INCONVENIENCE IS ABHORRENT TO THOSE AFFECTED —AND THUS THE PROBLEM PERSISTS.
FULLY TRAINED AND LICENSED PROFESSIONALS ARE THE ONLY WAY TO APPROACH THIS PUBLIC HEALTH NUISANCE SO AS TO INSURE THE CORRECT USE AND APPLICATION OF EFFECTUAL
PESTICIDES.
WE CANNOT LEGISLATE THE CONSUMER TO TREAT FOR BEDBUGS
(SOME ARE WILLING TO “LET THE BEDBUGS BITE”) BUT WE CAN EDUCATE ON THEIR TRANSMISSION PROCESS AND STEM THE SPREAD.
I’m actually optimistic today, John! In fact I think I’m close to being happy because of this EPA news. I really do believe that we can achieve control of the ridiculous bed bug (it’s really a fragile bug and yet it endures, what a fantastic creature) through hard work, smart organization and just intelligent, coordinated action. Bed bugs have had the run of our city, and probably the whole country, for too long. People in other eras fought back, there is no reason we can’t.
However, maybe this time we’ll be less arrogant and more compassionate. We can actually kill the stigma if we’re smart. And we can make it better for the poor schmos who’ll get bed bugs 20 years from now.
John,
You are right; bed bugs can be eradicated, however it takes time and a lot of effort. Regarding the matter of public awareness, I’m not certain that areas that are not in the “highly infested” category are up to speed on the issue; out of sight, out of mind. And, the “stigma” of having bed bugs seems to cause people in my area to keep their problem to themselves…which, of course, can compound the matter. In the mean time, stay on target, stay positive, and good luck!
The bed bug is a problem everywhere in the US!!
State, County and Municipal EH Professionals are reluctant to enforce ordinances in dealing with this “pest of public health significance” because what they have on the books relate to KNOWN disease vectors such as mosquitoes.
The bed bug is not a KNOWN disease vector so, walk away if you can’t do anything.
Disheartening!! Especially when kids are involved!
Do we need to go back to the books and redefine VECTORS and VERMIN in the context of “pests of public health significance” and the 21st Century??
Hi Amdy,
While this has been the situation up to now, I expect that we will begin to see changes. The sheer pressure of so widespread a problem, and the increasing notice by some government agencies, will start to work against the reticence of public health officials to get involved. But, yes, in the meantime it is very hard on people. And it’s harder because you know that in general people are indifferent to what is happening and too many people think bed bugs are a ridiculous issue.
Our position has always been that disease transmission is unnecessary to a determination of public health concern. This is not very hard to prove, actually, in practical terms. In NYC, our health department has always said that bed bugs don’t spread disease and it’s therefore not their purview, period. And yet, it is so easy to find in their efforts in other areas– like, infamously, a handsomely-produced insomnia brochure last fall– the lie contained in that statement.
But it’s also important for people to speak up about their problems and demand attention. The stigma of bed bugs that causes so many people to suffer in silence has not helped all these years.
I think things will change, I really do.
Hi Renee,
People are indeed speaking out now being better educated and more aware of the problem. No longer the stigma that it used to be.
However, we find a good number of apartment dwellers, homeowners and shelter residents not knowing where to turn to for help or unable to pay for exterminator fees. Meanwhile, problems associated with the infestation area staring them in the face with the attendant nightmares!!
Should there be a concerted effort to find grant funding and other help to enable victims to access and pay for professional services? I am thinking a coupon system modeled after a spay -neuter program that allows cash strapped pet owners to buy subsidized coupons that are presented to veterinarians in exchange for services rendered. A special fund then pays the difference to the Vet. Same model could be replicated in urban settings and may be fairly easy to administer. Also ensures timeliness of treatment!!
Thinking along these lines has become imperative since an individual’s bed bug problem can no longer be regarded with indifference and as an isolated case. Each infestation serves as a route for dissemination through unwary family members, neighbors and visitors to the infested premises.
When the elderly are involved, the infestation becomes a source for spread. Kids, grandkids, family, home health workers all fall victim.
Jumping on a bed bug infestation in the very early stages can make all the difference especially where the partners cooperate to tackle the problem.
I will comment later on how the level of cooperation between parties in an extermination effort can impact a bed bug treatment and control protocol/regimen.
Legislation alone may not address our concerns and inaction is unacceptable!!
That’s an interesting idea! Tell us more.
Improving access to pest control services is indeed the most challenging problem of all. It is where any urban control plan will founder if it is not considered.
We have been interested in, well, the dream of the availability of Bug and Scrub-type solutions– Bug and Scrub is a social purpose enterprise bed bug prep/treatment service in Toronto. Sliding scale. Employment creation. No pesticide application (I think).
Did you read that the federal gov’t is going to have a bed bug summit in Washington next month? Don’t want to sound negative, but with the way the feds are behaving lately, I’m not sure that we can expect much…but, maybe it’s a start.
http://abclocal.go.com/wpvi/story?section=news/health&id=6713851
Hi Rich!
We’ve been nothing but about this EPA meeting, ha ha.
Check it out: http://newyorkvsbedbugs.org/2009/02/23/extraordinary-breaking-news-an-epa-bed-bug-conference-in-washington-on-april-14/
I am actually very encouraged by this. Of course, who really knows. We shall see. But it’s certainly big.
I want to go but am not sure that I can…
First let me start off by saying I am mentally drained and can not believe that everyone I have told about this is acting like I’m crazy. I was told by my land lord and by the section 8 inspector that this is personal. I don’t travel, I have not been to any hotels, and I have tried to use pesticides since the beginning of February. I had to throw out my bed, my son twin beds and almost everything in my house. No one is helping me and accusing me of being careless. Who and what should I do. I need help immediately. The other tenents are acting like they don’t have them. If they don’t they will. How can I replace my furniture when the owner is saying it’s personal. I caught ten bugs put them in a bag and showed him. He still thought it was a joke and laughed. My son is in the 9th grade and is very embarrassed to go to school. It’s mentally effecting him to. What do we do. I am so hurt that I would be told this is personal.
Sherice,
I’m very sorry for your situation. In many jurisdictions the landlord is required to eradicate bedbugs in your apartment. You should check with the housing department or a tenant advocate organization where you live–and call the health department to see if they have any specific advice for you or information resources. You should confirm what the law is in your city before proceeding: many people are uninformed about bed bugs generally and about rights and responsibilities in rental apartments. Get official confirmation of who is responsible for eradication.
Throwing away furniture is not always recommended as it can be saved with treatment and, sadly, throwing it out very rarely solves a bed bug problem. Treatment by a pest control professional experienced in bed bug eradication is the best advice. I hope your landlord will come round once you present them with the right information.
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