[Technically Speaking] The Perfect Storm

In 1998, I encountered my first bed bug infestation in the Washington, D.C., area and the timing of this seemed of no consequence until the U.S. Environmental Protection Agency (EPA) decided to hold a bed bug summit last month. This reminded me of the question always asked in seminars, meetings and summits, “Why now?” Many answers have been postulated, among them travel, immigration, change in pest management practices, change in pesticides, etc., but the one reason never proffered was EPA.
How ironic that EPA — the agency that created the perfect storm and that severely limited our ability to address the resurgence of bed bugs — would hold a summit 11 years down the road on the premise that EPA will facilitate the solution to this problem. It is sad to think that EPA was forewarned of this potential problem in the early 1990s.

NECESSARY PRODUCTS ELIMINATED. The early 1990s was a time when there was a major push by EPA and our environmental friends to eliminate two major classes of insecticides, organophosphates and carbamates. Contrary to what one attendee at the summit representing CedarCide claimed, “The EPA doesn’t want you to know about this product because they have a long-standing relationship with the chemical companies that provide them with both power and revenue,” EPA has never been in bed with pesticide manufacturers. To the contrary, they have been in bed with environmental groups determined to eliminate pesticides. The consequence of this is that our ability to address the expanding bed bug problem is severely hampered by the limited groups of products available.

When the elimination of these pesticide classes were being considered concerns were raised by various groups over potential public health threats and the loss of two very important classes of insecticides. The most important impact of this loss is our ability to manage resistance in mosquitoes, flies and other disease vectors, such as the resurgent bed bug.

At that time the stakeholders expressing these concerns were assured by EPA that there was no need to worry — if a public health threat occurred it could be addressed on an as-needed basis with a Pesticide Emergency Exemption — Section 18 of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) — an exemption predicated on EPA determining that an emergency exists. To my knowledge there has been no attempt on the part of EPA or any state to look at these older classes of insecticides and consider a Section 18 Exemption to address widespread bed bug resistance.

After 11 years of attempting to deal with the bed bug issue, we still have people both in the industry and government who believe we can eradicate bed bugs by legislation, regulation and designer technologies. Legislation and regulations don’t get rid of bed bugs and they do little to force people to correct the problem.
Dogs and detection devices can be used to find bed bugs but the accounts being serviced by the average pest management professional only require decent eyesight or a conversation with a tenant who has infected bed bug bites or a baby or child who has bites all over its body. There are many designer technologies that incorporate heat, cold, steam and/or crushing them with your fingernail on the wall to effectively kill bed bugs — the intent obviously to show we can do it with IPM and minimal to no use of pesticides.

NO MONEY AVAILABLE. One of the basic tenants of IPM is it must be economical. The unfortunate aspect of these devices and techniques is that while effective in killing bed bugs they aren’t economical for pest management professionals and the large majority of their customers. In our geographic area it isn’t uncommon for 50 percent or more of the units in an apartment complex to be infested with bed bugs and considering these complexes have 250 to 1,000 units each, this is a monumental problem and expense for management.
Unfortunately, at this time for most property managers (except those catering to the affluent), the most economical approach to managing bed bug problems is repeated pesticide applications. There is no doubt that we have products that kill bed bugs but they fit three patterns:

Pyrethroids provide quick knockdown depending on population resistance profiles.

Organic dusts that kill bed bugs simply can’t be applied every place a bed bug takes up harborage.

Different mode of action (other than pyrethroids) residuals that at best require 14 days continuous contact for death.

The resurgence of bed bugs and our inability to effectively and economically manage them points out the lack of thinking and planning on the part of EPA and other regulatory organizations. The consequence of their actions has created a situation far worse than the continued availability of organophosphates and carbamates would have. Companies are pumping gallons of insecticides into apartments, treating bedding with insecticides, and tenants and homeowners are making their own applications. The bottom line is people are being overexposed to pesticides in an effort to address the bed bug problem.

Even if a Section 18 could restore classes of insecticides that would be far more effective in killing bed bugs it is unlikely that manufacturers would jump on this because their products have been so maligned and the manufacturing process has been shelved. The other problem would be the bureaucratic  hurdles that would have to be cleared for this to occur:

• Assessment of the validity of the emergency claim and economic loss.
• Human dietary risk assessment.
• Occupational risk assessment.
• Ecological/environmental risk assessment.
• Assessment of the progress toward registration for the use for specific or public health exemption requests.

Perhaps it’s time EPA officials who make these uninformed decisions get out in the field and see the consequences of their “perfect storm” — apartments with thousands of bed bugs, children bitten up and insufficient resources to pay for the designer IPM technologies that only the affluent can afford.

The author is president of Innovative Pest Management, Brookeville, Md., and can be contacted at rkramer@giemedia.com.