Update: Federal Register notice published; public comment period ends January 21, 2010.
When we noticed the talk about the active consideration by EPA of Section 18 emergency exemptions for bed bugs, it wasn’t clear which pesticides were being discussed.
The Columbus Dispatch reported today that Ohio is in a position to get propoxur for bed bugs.
The story about today’s Central Ohio Bed Bug Summit has Matt Beal of the Ohio Department of Agriculture citing University of Kentucky trials:
In tests at the University of Kentucky, the chemical killed 100 percent of the bedbugs exposed to it within 24 hours and kept on killing after eggs hatched, Beal said. That compared with a 16 percent kill rate after 72 hours for a commonly used household insecticide against one strain found in Cincinnati, and 40 percent in another strain.
The stakes are high as we all know. “Overwhelmed” and “bleak” are the words from Paul Wenning and Susan Jones.
Will this happen?
Getting the U.S. EPA to sign off will be a high hurdle, Beal said.
I’m curious to know what you make of this.
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pretty much scorched earth policy – but if used properly by pros, for a limited time, it might help to get infestation rate down to manageable levels.
Maybe. One can only hope.
What I’m thinking is that maybe essentially doomed exercises like this one — something we see repeated every so often in different places around the country (shouldn’t there be city and state advisories about these things? What you are about to attempt doesn’t actually work…) — may have a better chance.
Propoxur will help the professionals, but it will not get rid of the problem. EPA has made it clear that this will only be released as a Restricted Use Product, and how effective it will be for professionals will also depend on the label restrictions. One of the primary problems; label restrictions and directions that the EPA will agree with. EPA can queer the efficacy of this product with the labeling alone. Furthermore, if the general public has no access to inexpensive efficacious products the problem will never go away.
As for the EPA; we know that propetamphos (old Safrotin and now Catalyst) absolutely wipes out bedbugs and yet when a Zoecon representative asked an EPA official at the NPMA convention if they would allow them to bring it back in this setting…. he said no. . Remember that Catalyst is still available for use in restaurants and food service operations, so it isn’t if they would have to do anything extra except change the label. He then asked him if bedbugs had been a transmitter of diseases would they reconsider. He said no.
This section 18 request is important for three reasons.
1. Matt Beal is plowing new ground as the EPA has “never in memory” had a section 18 indoor request.
2. Other states are watching to see what happens. If this goes through they will probably follow suit using Matt Beal’s work as a template.
3. If EPA agrees to this it will be a tacit agreement on their part that the problem is inadequate chemistry. It is not a lack of communication, it is not a lack of education, it is not about exotic treatment methods…it is inadequate chemistry.
As this problem escalates the entrenched mentality at the federal level will not play well at the state level; where the poorest and most needy people will be suffering the most.
Thank you, Rich. Needless to say, we’re going to be glued to this. Don’t know anything about catalyst, will look it up.
Renee,
APSCRO stands for the Association of Structural Pest Control Regulatory Officials, and they are in favor of EPA approving Ohio’s Section 18 request. Furthermore, these other states have shown interest and are likely to follow suit; Alabama, Florida, Georgia, , Kansas, Nebraska, New Jersey, Massachusetts, Michigan, Missouri, New Mexico, North Carolina South Carolina, Texas, West Virginia , Wyoming and the Virgin Islands. These states may be interested depending on the product and the labeling; Arizona, Delaware, Maine, New York, New Hampshire, Oregon, Vermont, Wisconsin. Labeling is going to be a big issue for efficacy. Once again….EPA can queer the efficacy with the label instructions.
It might be noted that ASPCRO agrees with the most nationally recognized researchers in pest control that current pesticide products are inadequate at many levels and as a result enhances resistance. They are also unimpressed with these expensive, ineffective and exotic treatments that don’t amount to much more that scams and homemade pesticides and remedies which can lead to real trouble. In the final result it must be clear to all reasonable people that the problem is a problem of effective chemistry. Eventually it must become clear that inexpensive, efficacious chemistry in the hands of homeowners is what will ultimately be the answer to this problem just as it was in 1946.
Rich K.
Rich, while I agree with most of the second paragraph, i shudder to think of pesticides like Catalyst, readily available to homeowners like my chain smoking neighbor who pours old paint and varsol down the sewer in front of his house while idling his 20 yr old car in the driveway .
Johnnycakes,
I understand your concerns, but we have to stop thinking in such narrow terms. We live in a risk benefit world. Everything has an element of risk and everything has a beneficial element. How many people have died from pesticides over the last 60 years? I have the happy privilege of being a member of the American Council on Science and Health. You may wish to visit their site and peruse their RISKOMETER, http://riskometer.org/
Click the “exposure” link to see the enlarged features and explanations. Here you will find true risks based on actually science and not foolish speculation and theoretical risks, which is what most of these so-called “studies” propound.
When we replace efficacious products with products that are less efficacious we actually increase the risk to those exposed because they have to be exposed over and over again. When you actually read these “studies” that make claims about how detrimental pesticides are you find that they are filled with weasel words. I invite you to read the article I published in my blog, Paradigms and Demographics, called Weasel Words and Phrases.
http://paradigmsanddemographics.blogspot.com/2008/07/weasel-words-and-phrases.html
Best wishes,
Rich K.
I apologize, Rich, your comment got caught in the filter. Rescued.
“When we replace efficacious products with products that are less efficacious we actually increase the risk to those exposed because they have to be exposed over and over again. ” AGREE
Yes life is a risk, but my brain tells me that use of powerful pesticides by untrained people is not a simple risk. My brain also tells me that just because science has not progressed far enough to determine the long term affects of exposure to substances we barely understand is not a reason to proclaim them relatively safe, at least when used by the average guy.
Yes , there are a lot of scare mongers and tree huggers that would not allow any use of pesticides, i am not one of them, but, there is no refuting the build up of DDT and the damage that it caused.
” weasel words ” or not, my faith in humans does not extend to pesticide use, i don’t even trust the drive thru attendant to put a sugar packet with my coffee, let alone administer pesticides.
very informative bog by the way.
Johnnycake,
Thank you for the compliment. You may wish to expore the links in my blog. As you follow the articles you may find your views developing broader horizons. For an even larger article inventory please visit the Ohio Pest Management Association web site under the section called “Insight on the Issues”.
http://www.ohiopma.org/insight_issues.php
Best wishes,
Rich K.
I have to agree with Johnnycake on this issue. I deal with landlords and tenants on a daily basis and the fight against bedbugs. Some of there folks do not read labels and put down anything, anywhere because of their fear of bedbugs. They want the quickest fix and will put it anywhere. The products that are being considered should not be available to the general public. This will continue to happen and will possibly cause preventable injury. The bugs will soon become immune to some of the chemicals if everyone has them and everyone knows they are affective. We will be back in the same boat looking for another product to be approved from the EPA. Change tactics, switch up chemicals and do not use the same ones at every bedbug infestation. Stop the immunity cycle. Let the professionals use the restricted products.
Jeremy Hessel, R.S.
Hamilton County Public Health
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Hey Jeremy-
Good to see you. I think that the debate over restricted use is academic. General use labels will never happen. And I have similar concerns. I do respect Rich’s position and I understand where he’s coming from, because I think that we all need to put our brains together about how to solve the access to pest control services problem — this has to be a priority policy objective. Until it is, we will go nowhere.
Jeremy,
Regarding the cycle of resistance….we will never find a way out of that because it is part of nature’s cycle. We will always be in that proverbial boat you refer to.
When DDT was first being used everyone thought that the magic bullet had been found. Later resistance developed in some insect populations because we fell into the pattern that already existed in nature without knowing it.
Most of the pesticides we will come in contact with are naturally occurring in the food we eat, and most of the carcinogens we consume are naturally occurring in our food, ninety five percent actually….and at a higher level of carcinogenicity than most manmade chemicals.
Plants don’t have claws, they don’t have thick hides and they can’t run away. The only way that they can protect themselves is through chemistry. They create their own pesticides and repellants. Pests then become resistant to those chemicals and as a result the plants will start manufacturing some other chemical to protect themselves. This is the pattern we fell into and we are prepared to deal with it by producing new chemistry. We absolutely know that resistance will eventually develop in the pests we are attacking in every product we use.
Resistance isn’t a mutation. “Resistance is a genetic phenomenon” where-in some insects are already resistant to the chemical introduced into their environment. As we develop chemistry to deal with pests we will find that these resistant ones are the only ones left breeding, since the non-resistant ones are killed off. Eventually almost the entire population will be resistant. We then must change materials just as plants do in nature. So the argument for not releasing these products based on a concern for resistance is not appropriate in my opinion. In fact, by not releasing this product we are hastening resistance in the products that are available because they are being applied at a much higher rate than would be necessary than using a product that works in one or two applications.
People will not tolerate this problem without doing something to protect their families. We still come back to the fact that people are using things that are homemade and many times are using techniques that are far more dangerous than having propoxur as an over the counter product.
As I have stated in the past. People will do foolish things, but people have always been just as foolish about this things in the past as they are today and will be tomorrow, so as we look back in time we have ask ourselves; how many people were killed by these products? None that weren’t attempting to kill themselves as far as I can tell. How many were impacted negatively in other ways by these products which did have over the counter labels? That number has always been very small, especially when you consider the hundreds of millions of applications that have been made over the last 60 years by professionals and non-professionals alike.
However, when we look at the results of all of those applications we find that we created a largely pest free environment that we grew accustomed to, and rightly so, including an environment free of bedbugs. As a result of all of those professional and non-professional applications our homes and businesses are mostly pest free and healthier as a result.
We, as a society, have created chemical fears that are unbalanced and irrational. In short; we are the healthiest chemophobes in the world. I believe that the reality is in the history. The solution in 1946 was effective and inexpensive chemistry that was available to the public; and it will have to be the answer in 2010.
Every product and technique out there today is failing. The numbers of bedbugs are growing in size and location. Worse yet, we are finding more and more resistant populations and some are so resistant that nothing available will kill them at all. We need effective, inexpensive chemistry that is available to the public if this plague is to be cured. Let’s make no mistake about it; if these pests carried the plague we wouldn’t be having this conversation.
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Rich,
I agree that the product should be available, but to only the professionals licensed to use restricted use pesticides. Here at the Hamilton COunty Public Health we see it weekly where a consumer purchases a product over the counter and applies it. When you ask “Did you read the label on where it can be applied, how to apply it, or what did the label say it was for?” Most of the answers are “The landlord gave it to me, I purchased it on the internet, or the neighbor used it and said it worked.” I am not a baby sitter and people can do what they want, but if we can prevent a future issue with exposure to a chemicals by allowing it as an over the counter product, then we should. The professional exterminator who has knowledge should have access to this product. Do you see where I am coming from. This is a constant problem with landlords and tenants who are paranoid and will do anything to get rid of the bugs.
We recently had an incident here in Cincinnati where a family was using 90 % isopropal alcohol and sprayed a bed down and then a cigarette was lit. The apartment caught fire and 12 people were displaced. There needs to be responsibility placed on the purchaser of the product to read the label and apply it correctly, but this is not a perfect world. Lets leave the applying to the professionals.
I am not making light of others misfortunes but i can’t stop laughing at the stupidity of those alcohol users, and that was JUST alcohol, a chemical which has been around for thousands of years. people with that level of intelligence would probably use a product like catalyst as baby soap.
Jeremy,
I understand exactly what you are saying, and I have conceded the point that people do stupid things and it is true that they don’t follow label instruction well or at all.
I am a fellow Ohioan so I am aware of the Cincinnati incident. Additionally there was twenty thousand dollars plus in damages along with these poor people being seriously inconvenienced. However, this actually supports the point that I am trying to make; and that is people will use home remedies and techniques that are far more dangerous than applying a pesticide once or twice.
I hate to keep coming back to the risk versus benefit argument, but we have over sixty years of background to show that pesticides available to the public had an overall beneficial impact. True, people did stupid things and once again they don’t follow directions well, but the risk is miniscule compared to the benefits.
We keep talking about exposure as if any exposure to pesticides is terrible. I am sorry, but this just isn’t so. Exposure and toxicity are two different things and the Litulis Kilgore incident in Lorain County shows just how resilient the human body is.
As for the alcohol remedy…that was recommended by one of the County Health Departments in Ohio. Lighting the cigarette was his own idea. So then….which is dumber and more dangerous…using alcohol, smoking, or using pesticides? Just a thought!
Best wishes,
Rich Kozlovich
Wondering what sort of label this would have; it’s rather stinky no?
If this should come into being it appears that it will be in an oil based formulation and yes it will stink. Not unbearably, but it will smell. As for the lable instructions…..that is the bone of contention as I understand it.