[Technically Speaking] EPA Emergency Exemption — the Time Is Now!

The other day a fellow pest management professional asked if our industry should try to do something about the problem we are having killing bed bugs with the products currently available, i.e., should we ask the U.S. Environmental Protection Agency to reconsider the registration of products that have worked on bed bugs in the past? My gut feeling was “Why waste your time?” — but here I am making a case for EPA to undo what it (if only temporarily) unwisely did years ago — virtually eliminate every class of pesticide we had available except pyrethroids.

I can remember years ago (when I was still at the National Pest Management Association), many pest management professionals expressed concern about the loss of virtually all organophosphate and carbamate pesticides and the fact that we were being relegated to one major group of pesticides, pyrethroids. Those who called themselves “environmentalists” pushed for the demise of diazinon, bendiocarb, chlorpyrifos and other products in these groups applauded EPA’s action of removing virtually all of the registrations for these products.

Despite concerns expressed by many about the loss of these major groups of pesticides, the unlikely development of new products and fewer new classes of products for structural and public health pests, EPA was unwavering in its action. The agency reassured those concerned that if special needs arose, emergency exemptions would be considered. Well, EPA, the time for an emergency exemption is now!

THE RESISTANCE ISSUE. If we consider the major pest problems of the ’70s and ’80s, the cancellation of these product registrations may be understandable, although the consequences dire. The most serious pest problems of these decades were mosquitoes, flies, cockroaches and ants. Mosquitoes, flies and cockroaches posed the most significant pest management problems because of their high reproductive potential and the subsequent development of resistance to many of the insecticides then available. As a U.S. Army entomologist I spent three years (many of my civilian co-workers spent most of their careers) conducting resistance tests on these insects and providing recommendations on resistance management.
The resistance problem, along with a desire to reduce pesticide usage (some call it IPM), led to a major expansion of bait products and several new (but very limited) classes of insecticides. Most of these new active ingredients were formulated into baits focused on ant, cockroach and fly control. While mosquito management did not benefit to any significant degree from these developments, at the time there was no imminent threat from mosquitoes until the introduction of West Nile virus in the late ’90s that sent everyone scrambling.

Baits are very effective products and considered environmentally friendly and for the most part they overcame physiological resistance. However, they have had their failures with behavioral resistance in cockroaches. Unfortunately, baits target a very limited group of insects of structural and medical importance and are of no value with blood-feeding arthropods.

At this writing, our industry is faced with a pandemic — bed bugs. Despite what you hear at conferences and read in trade journals, we do not have the tools (products) to effectively and economically manage these blood-feeding insects, much less eradicate them. What we must do to reduce their numbers smacks in the face of IPM.

“TREATMENT” OPTIONS. I have been involved in bed bug treatments of thousands of apartments per year during the last seven years and I have on only a rare occasion seen situations where all of these touted alternatives, e.g., heat, steam, vacuuming, anoxia, etc., can be used effectively and economically to eliminate bed bugs in lieu of all out chemical warfare.

My customers include multi-family housing with as many as seven to eight individuals crowded into an efficiency apartment; tenants afraid for various reasons to notify management that they have bed bugs; and management unwilling to pay for alternative, labor-intensive options.

In addition, we have product manufacturers jumping on the bandwagon putting bed bugs on their label and making unjustifiable efficacy claims (or show me the data — not testimonials). Drs. Mike Potter (University of Kentucky) and Dini Miller (Virginia Polytechnic Institute) are showing us the data and it is not pretty. To sum it up, we have products (mostly pyrethroids) that kill some but not all bed bugs if you spray it on them; residual insecticides are relatively ineffective after they dry; dusts don’t work unless you have weeks or months to wait; there is documented resistance to registered insecticides; there are no new products on the horizon; and no one appears to re-examining those products we lost during the past 10 to 15 years. Perhaps the most successful technique is what I see in many apartments: crushed bugs and blood smears across the walls.

While it is not what I prefer to do I have had the greatest success in soaking all potential harborage sites with residual insecticides that appear from the research to kill the most bugs. As Dr. Potter once said regarding perimeter pests, this is not a hunt-and-peck approach to pest management, it is scorch and burn.

There may be a move afoot to look at some of our no-longer-registered products, most particularly organophosphates. I recently heard at the NPMA convention in Orlando that DDVP may be back in an aerosol form. But other than that, I suspect nothing is happening because if you are so far removed from the problem (EPA) why should you care unless you have slept in a bed bug-infested room? While re-examining these old products for efficacy is not the purview of EPA, it is the agency’s action that has left us in this predicament.

The people we encounter in our day-to-day operations are sleeping with these bugs every night and are fed on night after night. In a way it is too bad these bugs don’t transmit any disease, since that might heighten concern over this pandemic and prompt some action. My other concern is the amount of product that we must apply and the frequency of application to affect any significant degree of control.

I look forward to the day when we have products for bed bugs that allow us to perform directed applications and products that work effectively as residuals. I hope EPA hears these peoples’ cries — it’s time for an emergency exemption now!

The author is president of Innovative Pest Management, Brookeville, Md. He can be reached at 301/570-3900.