Comments on: The NYC Health Department regresses http://newyorkvsbedbugs.org/2009/09/26/the-nyc-health-department-regresses/ A bed bug policy advocacy group Wed, 28 Jul 2010 04:37:51 +0000 hourly 1 http://wordpress.org/?v=3.0.1 By: Rich Kozlovich http://newyorkvsbedbugs.org/2009/09/26/the-nyc-health-department-regresses/comment-page-1/#comment-16106 Rich Kozlovich Sat, 03 Oct 2009 22:24:50 +0000 http://newyorkvsbedbugs.org/?p=3889#comment-16106 Dear Renee, Manufacturers are in business to make money. If they undertake some action that is all feel good and fuzzy, but bad business, then we all suffer in the long run. There is a difference between doing ‘good’ and doing business. If they run their businesses well then people can do whatever good they choose; but profitability must come first or there is no money to do good! As for being perceived by the public as evil jerks; we can thank the EPA and the greenie for that. Have some of the been evil jerks in the past. Probably! We some be evil jerks in the future. Probably! But that doesn’t alter economic realities. You can do ‘good’ if there are no profits to tap in to, and the manufacturers will not jump into this without some public support from the government; and I think rightly so because this was caused by government action. We still keep coming back to the RUP issue. I think I need to outline this issue as I see it. 1. It is clear that if the public doesn’t have efficacious inexpensive products at their disposal to eliminate their bedbug problem. 2. As a result, instead of making one or two efficacious applications, they will make more and more applications at higher and higher rates and accomplish nothing. 3. As long as that continues the problem will never go away. 4. If people of moderate means cannot afford to pay for pest control companies to get rid of their bedbugs the re-infestation rate will continue unendingly. 5. If these people cannot find relief through registered and tested products they will turn to other means, including manufacturing their own pesticides. There is a site in Canada (which has been in the forefront when it comes to banning or restricting pesticides) that explains how to do that. 6. If this happen then we had better be prepared for the law of unintended consequences. Those consequences may not be pleasant. People will not let their families continue to suffer without doing something. 7. If exposure is really the concern over this issue, we have to look at when all of these products were available to the public. a. What were the health issues during that time period? b. Is there any link between disease and these pesticides? 8. We also have to ask; what is the real risk of pesticides? a. How many people have died over the last 65 years from pesticide exposure? b. How many people have died on the nation’s highways in the last 65 years? 9. In spite of the theoretical health claims from the greenies, pesticides do not cause cancer, endocrine disruption, asthma or anything else the greenies babble on about 10. By making pesticides “restricted” when they do not meet the level of toxicity that already exists under established regulations we will be changing the rules just to change the rules. And that brings us right back to the reason as to why pesticide manufactures are unwilling to step up and be counted. Who can blame them? For them it is a no win situation. If there is a moral crisis here; it is at the regulatory level, and nowhere else. Dear Renee,

Manufacturers are in business to make money. If they undertake some action that is all feel good and fuzzy, but bad business, then we all suffer in the long run. There is a difference between doing ‘good’ and doing business. If they run their businesses well then people can do whatever good they choose; but profitability must come first or there is no money to do good!

As for being perceived by the public as evil jerks; we can thank the EPA and the greenie for that. Have some of the been evil jerks in the past. Probably! We some be evil jerks in the future. Probably! But that doesn’t alter economic realities. You can do ‘good’ if there are no profits to tap in to, and the manufacturers will not jump into this without some public support from the government; and I think rightly so because this was caused by government action.

We still keep coming back to the RUP issue. I think I need to outline this issue as I see it.

1. It is clear that if the public doesn’t have efficacious inexpensive products at their disposal to eliminate their bedbug problem.
2. As a result, instead of making one or two efficacious applications, they will make more and more applications at higher and higher rates and accomplish nothing.

3. As long as that continues the problem will never go away.

4. If people of moderate means cannot afford to pay for pest control companies to get rid of their bedbugs the re-infestation rate will continue unendingly.

5. If these people cannot find relief through registered and tested products they will turn to other means, including manufacturing their own pesticides. There is a site in Canada (which has been in the forefront when it comes to banning or restricting pesticides) that explains how to do that.

6. If this happen then we had better be prepared for the law of unintended consequences. Those consequences may not be pleasant. People will not let their families continue to suffer without doing something.

7. If exposure is really the concern over this issue, we have to look at when all of these products were available to the public.
a. What were the health issues during that time period?
b. Is there any link between disease and these pesticides?

8. We also have to ask; what is the real risk of pesticides?
a. How many people have died over the last 65 years from pesticide exposure?
b. How many people have died on the nation’s highways in the last 65 years?

9. In spite of the theoretical health claims from the greenies, pesticides do not cause cancer, endocrine disruption, asthma or anything else the greenies babble on about

10. By making pesticides “restricted” when they do not meet the level of toxicity that already exists under established regulations we will be changing the rules just to change the rules.

And that brings us right back to the reason as to why pesticide manufactures are unwilling to step up and be counted. Who can blame them? For them it is a no win situation. If there is a moral crisis here; it is at the regulatory level, and nowhere else.

]]> By: Renee Corea http://newyorkvsbedbugs.org/2009/09/26/the-nyc-health-department-regresses/comment-page-1/#comment-16100 Renee Corea Sat, 03 Oct 2009 20:39:11 +0000 http://newyorkvsbedbugs.org/?p=3889#comment-16100 Gosh, Rich. I think the manufacturers should consider the good press that will accrue to them! If there is any sense that they are holding back because they want to leverage the bed bug epidemic for some other agenda, the public will think they're evil jerks. Oh wait, they already do! (I'm being facetious, but you know this is going to be a public relations battle and I can already see some of the arguments, according to whether people hold that pesticides are evil or beneficial, and the bed bug itself all but forgotten. <em>What can bed bugs do for me</em>, remember?) I think we still disagree about the restricted use label. I don't see how this will happen without it. Gosh, Rich. I think the manufacturers should consider the good press that will accrue to them! If there is any sense that they are holding back because they want to leverage the bed bug epidemic for some other agenda, the public will think they’re evil jerks. Oh wait, they already do! (I’m being facetious, but you know this is going to be a public relations battle and I can already see some of the arguments, according to whether people hold that pesticides are evil or beneficial, and the bed bug itself all but forgotten. What can bed bugs do for me, remember?)

I think we still disagree about the restricted use label. I don’t see how this will happen without it.

]]> By: Rich Kozlovich http://newyorkvsbedbugs.org/2009/09/26/the-nyc-health-department-regresses/comment-page-1/#comment-15980 Rich Kozlovich Fri, 02 Oct 2009 22:15:33 +0000 http://newyorkvsbedbugs.org/?p=3889#comment-15980 Dear Renee and Jody, The manufacturers are gun shy for good reason. There are going to be some added costs involved and they aren't going to step forward unless they can get authorization to maximize their sales, which means that they will want to avoid a restricted use label and sell to the public. This is especially true since the “Restricted” category is based on toxicity and these products never fell under that category. If they restrict these products they will be going against established regulations. They know that the EPA doesn’t want these products re-established in society and they simply don’t trust the EPA, and since EPA has the tendency to change the rules to suit the latest philosophical flavor of the day; their gun shy attitude is more than understandable. They do have liability concerns, which could be ameliorated by the Congress which could exempt them from damages to some extent. This would be a similar action that Congress took to override the Hill vs. TVA SCOTUS decision regarding the snail darter and the Endangered Species Act. As far as this being a Public Health Crisis, I think that you will find that the mood is changing rapidly. In those cities where this is a massive problem it was a public health crisis big enough to have impacted elections. As this grows there will be no more talk about whether this is a public health crisis or not. It is! The fact that there is no evidence of bedbugs being vectors is immaterial. It is a public health crisis because it is a quality of life crisis for the public that is infested. Infested and suffering with no relief in sight. Make no mistake about this; it still comes back to the federal government and the EPA. If they really want this done, they will make it so attractive to the manufacturers that it will come into being overnight. Since they are not really working to do that we can assume that the EPA doesn’t really want this done and the manufacturers know it. Let’s stop putting this on the manufacturers. Ultimately it is all in the EPA’s court in one way or another. Rich Kozlovich Dear Renee and Jody,

The manufacturers are gun shy for good reason.

There are going to be some added costs involved and they aren’t going to step forward unless they can get authorization to maximize their sales, which means that they will want to avoid a restricted use label and sell to the public. This is especially true since the “Restricted” category is based on toxicity and these products never fell under that category. If they restrict these products they will be going against established regulations.

They know that the EPA doesn’t want these products re-established in society and they simply don’t trust the EPA, and since EPA has the tendency to change the rules to suit the latest philosophical flavor of the day; their gun shy attitude is more than understandable.

They do have liability concerns, which could be ameliorated by the Congress which could exempt them from damages to some extent. This would be a similar action that Congress took to override the Hill vs. TVA SCOTUS decision regarding the snail darter and the Endangered Species Act.

As far as this being a Public Health Crisis, I think that you will find that the mood is changing rapidly. In those cities where this is a massive problem it was a public health crisis big enough to have impacted elections. As this grows there will be no more talk about whether this is a public health crisis or not. It is!

The fact that there is no evidence of bedbugs being vectors is immaterial. It is a public health crisis because it is a quality of life crisis for the public that is infested. Infested and suffering with no relief in sight.

Make no mistake about this; it still comes back to the federal government and the EPA. If they really want this done, they will make it so attractive to the manufacturers that it will come into being overnight. Since they are not really working to do that we can assume that the EPA doesn’t really want this done and the manufacturers know it.

Let’s stop putting this on the manufacturers. Ultimately it is all in the EPA’s court in one way or another.

Rich Kozlovich

]]> By: Jody http://newyorkvsbedbugs.org/2009/09/26/the-nyc-health-department-regresses/comment-page-1/#comment-15957 Jody Fri, 02 Oct 2009 16:52:43 +0000 http://newyorkvsbedbugs.org/?p=3889#comment-15957 I correct myself. Here's the language from EPA "Section 18 of FIFRA authorizes EPA to allow an unregistered use of a pesticide for a limited time if EPA determines that an emergency condition exists." and "when there are no alternatives for controlling the pest". You're right that a State or a Federal Agency can request the Section 18 but for bed bugs it would have to be under the "Public Health Emergeny Exemption" where a significant risk to human health exists. As we know, bed bugs are not widely viewed this way. I correct myself. Here’s the language from EPA “Section 18 of FIFRA authorizes EPA to allow an unregistered use of a pesticide for a limited time if EPA determines that an emergency condition exists.” and “when there are no alternatives for controlling the pest”. You’re right that a State or a Federal Agency can request the Section 18 but for bed bugs it would have to be under the “Public Health Emergeny Exemption” where a significant risk to human health exists. As we know, bed bugs are not widely viewed this way.

]]> By: Renee Corea http://newyorkvsbedbugs.org/2009/09/26/the-nyc-health-department-regresses/comment-page-1/#comment-15953 Renee Corea Fri, 02 Oct 2009 16:19:49 +0000 http://newyorkvsbedbugs.org/?p=3889#comment-15953 Yeah. I think they've highlighted this roadblock (they meaning NPMA; the statements about the active consideration of Section 18 by EPA that I remember came from Bob Rosenberg), that it's up to the manufacturers, who have liability concerns. In any case, I doubt we'll get any Section 18 exemptions here in NYS because my understanding is that it's <em>the state</em> that has to request them? I don't see that happening anytime soon. Yeah. I think they’ve highlighted this roadblock (they meaning NPMA; the statements about the active consideration of Section 18 by EPA that I remember came from Bob Rosenberg), that it’s up to the manufacturers, who have liability concerns. In any case, I doubt we’ll get any Section 18 exemptions here in NYS because my understanding is that it’s the state that has to request them? I don’t see that happening anytime soon.

]]> By: Jody http://newyorkvsbedbugs.org/2009/09/26/the-nyc-health-department-regresses/comment-page-1/#comment-15952 Jody Fri, 02 Oct 2009 16:01:39 +0000 http://newyorkvsbedbugs.org/?p=3889#comment-15952 As much as we'd like EPA to release new or old chemicals to address the issue of bed bugs ultimately it is up to a chemical product manufacturer to pursue registration of that chemical as a formulated product. Not up to EPA, it's up to the industry. Someone should apply for a Section 18 for a specific chemical and a particular use just to prove the efficacy. That might open the door. Of course this costs a ton of money. As much as we’d like EPA to release new or old chemicals to address the issue of bed bugs ultimately it is up to a chemical product manufacturer to pursue registration of that chemical as a formulated product. Not up to EPA, it’s up to the industry. Someone should apply for a Section 18 for a specific chemical and a particular use just to prove the efficacy. That might open the door. Of course this costs a ton of money.

]]> By: Renee Corea http://newyorkvsbedbugs.org/2009/09/26/the-nyc-health-department-regresses/comment-page-1/#comment-15346 Renee Corea Sun, 27 Sep 2009 03:55:10 +0000 http://newyorkvsbedbugs.org/?p=3889#comment-15346 Hi Rich, I hear you. I know how health departments have avoided this issue. But I disagree about the impact. In NYC, and in many places, public health agencies can actually help make things better for many people, if only they cared and assumed responsibility. Besides, I'm not prepared to sit and do nothing. The EPA process and whether they will or they won't, when, and all of that, is beyond anything I can influence. Hi Rich, I hear you. I know how health departments have avoided this issue. But I disagree about the impact. In NYC, and in many places, public health agencies can actually help make things better for many people, if only they cared and assumed responsibility.

Besides, I’m not prepared to sit and do nothing. The EPA process and whether they will or they won’t, when, and all of that, is beyond anything I can influence.

]]> By: Rich Kozlovich http://newyorkvsbedbugs.org/2009/09/26/the-nyc-health-department-regresses/comment-page-1/#comment-15293 Rich Kozlovich Sat, 26 Sep 2009 21:51:17 +0000 http://newyorkvsbedbugs.org/?p=3889#comment-15293 Renee, In spite of their responsibilities as public health officials, the health departments around the country are remarkably ignorant about pest control issues; not all, but most. They can't properly identify most pests, they didn't know what IPM was five years ago and now they are promoting it and attempting to regulate it (and they still don't know what it is...or at least what everyone thinks it is) and they don't know the chemicals or techniques needed to promote good pest control. I know this for a fact because I have done some classes for them over the years. So to expect them to understand the problems surrounding bedbugs is almost asking too much. Health departments aren't used to taking advice they only give it. That is part of their problem; they don't have a clue as to what to do about bedbugs. Easier to dismiss the gravity of the situation than admit that they don’t know what to do. I don't care how many regulations are passed, how many beds are thrown away, how much money is spent on unique pest control techniques, how much education is promoted to the public, or how much openness there is about infestations…..the problem will not go away until efficacious chemistry is made available to everyone. Whether health departments understand the issue and are sensitive to it or not is really a side bar that will not impact the problem to any large extent unless they start demanding that the EPA release effective chemistry. Then what they think and say will have some meaning, Best wishes, Rich Kozlovich, Exterminator! Renee,
In spite of their responsibilities as public health officials, the health departments around the country are remarkably ignorant about pest control issues; not all, but most. They can’t properly identify most pests, they didn’t know what IPM was five years ago and now they are promoting it and attempting to regulate it (and they still don’t know what it is…or at least what everyone thinks it is) and they don’t know the chemicals or techniques needed to promote good pest control. I know this for a fact because I have done some classes for them over the years. So to expect them to understand the problems surrounding bedbugs is almost asking too much.

Health departments aren’t used to taking advice they only give it. That is part of their problem; they don’t have a clue as to what to do about bedbugs. Easier to dismiss the gravity of the situation than admit that they don’t know what to do. I don’t care how many regulations are passed, how many beds are thrown away, how much money is spent on unique pest control techniques, how much education is promoted to the public, or how much openness there is about infestations…..the problem will not go away until efficacious chemistry is made available to everyone.

Whether health departments understand the issue and are sensitive to it or not is really a side bar that will not impact the problem to any large extent unless they start demanding that the EPA release effective chemistry. Then what they think and say will have some meaning,

Best wishes,
Rich Kozlovich, Exterminator!

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