Faced with the reality that Ohio’s bed bug problems were reaching epidemic proportions, on Oct. 21, Matt Beal, assistant chief at the Ohio Department of Agriculture (ODA), submitted to EPA a request for a "Section 18 Exemption for the use of three formulations of propoxur for the control of bed bugs in residential single or multiple unit dwellings, apartments, hotels, motels, office buildings, modes of transportation and commercial industrial buildings in Ohio."
Beal told PCT the decision was made based on several factors, including infestation reports from throughout the state from Ohio State University Entomology Professor Dr. Susan Jones; reports that the Ohio Department of Agriculture has received; and bed bug research from University of Kentucky Entomology Professor Dr. Michael Potter, which included, among other findings, research on bed bug pesticide resistance.
"I felt that we, as the regulatory governing body, had to do whatever was necessary to help the citizens of Ohio," Beal said.
WHY PROPOXUR? Beal said Ohio decided to ask for the propoxur exemption based on Potter’s research and the fact that propoxur is labeled for use indoors for not only residential sites but for warehouses. "What we are asking is for EPA to evaluate this particular active ingredient and provide an exemption for indoor residential use until something new is developed," Beal said.
The three propoxur products are:
Prenbay 1% Oil Solution – manufactured by Prentiss
Invader HPX Residual with Propoxur – manufactured by FMC
Prescription Treatment Brand 250 Propoxur – manufactured by BASF
Under Section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), EPA is authorized to allow an unregistered use of a pesticide for a limited time if the Agency determines that an emergency condition exists. It’s not uncommon for EPA to grant a Section 18 to a state agency to address an agriculture-related issue. For example, a Section 18 exemption was granted to solve a European corn borer problem in Wyoming. Ohio’s request is unique in that it marks the first time a Section 18 has been requested for indoor use of a pesticide.
Accompanying Beal’s request were support letters from Jones and Potter and manufacturers Prentiss, FMC and BASF.
IN DIRE NEED. Ohio’s decision to file the Section 18 Exemption has national implications. ODA has been coordinating its efforts with other state pesticide regulatory agencies through the Association of Structural Pest Control Regulatory Officials (ASPCRO). After several conference calls, it was decided that Ohio would submit the initial request for a propoxur Section 18. If it is approved, a number of other states will submit "follow-on" applications.
Like many states, Ohio is struggling to find answers for a bed bug problem that by all indications is "getting out of hand."
"The problems are multiplying. I’m being overwhelmed with the number of phone calls I’m receiving and the number of talks I’ve given on this topic," said Ohio State’s Jones. "The Central Ohio Bed Bug Task Force has been compiling data that has been showing tremendous increases in bed bug infestations (in the Columbus area) and in Cincinnati the problem is just off the scale."
Andrew Christman, vice president of the Ohio Exterminating Co., says his business, which services a 90-mile-radius around Columbus, has seen the number bed bug service calls explode. "Five years ago, we received two calls. This year we are on pace to receive 2,000 to 2,500 calls. It is just consuming our time," he said.
Similarly, Scott Steckel, vice president of operations of Varment Guard Environmental Services, reports that the Columbus-based company’s bed bug services went from nine in 2005, to 83 in 2007, to 667 in 2009.
How bad has the problem become in Cincinnati? In 2005, Cincinnati-based Sherzinger Pest Control performed a total of 84 services, but by 2008 that number had grown to 1,892. General Manager Hank Alt-haus said that through December the company had performed 2,968 total services.
Pest management professionals interviewed by PCT, including Christman and Steckel, noted that it’s not that the products currently available are not working; rather, the problem is that they don’t have a long-lasting residual.
But concerns about bed bug problems spreading and product performance are only two reasons Ohio asked for the exemption. A problem that concerns Jones and others is related to product failure: citizens frustrated with failed treatments attempting to treat for bed bugs themselves using unregistered and/or potentially harmful chemicals.
All of these were reasons why Beal, working with groups such as the Ohio Pest Management Association (OPMA), the National Pest Management Association (NPMA), ASPCRO, university researchers and others, decided to ask for the exemption.
WAIT AND SEE. Due to the unique circumstances (i.e., indoor use) surrounding Ohio’s Section 18 exemption request for propoxur, Beal is patient with the process, understanding that EPA is doing its due diligence so that they are "absolutely certain they are making the right decision."
That EPA is even considering the exemption is a testament to some of the collaborative efforts among industry and academia. For example, in the fall of 2008, EPA had discussions with several members of the structural pest control research community — including Potter and University of Florida Professor Dr. Phil Koehler — about the need to take a look at older chemistries (e.g., organophospates, carbamates). Then, following April’s National Bed Bug Summit, after a variety of groups were clamoring for such products, EPA conceded that this might be the right course of action. Following the Summit, NPMA worked with ASPCRO to identify whether there was a need for a Section 18 and to assemble a consortium of states that were interested in participating. Also, state and federal lawmakers are now involved. For example, in early December, a pair of Cincinnati-area state legislators introduced legislation in the Ohio General Assembly urging EPA to grant Ohio’s Section 18 exemption.
While these developments offer reasons for optimism, there are concerns that EPA will not approve Ohio’s request. Though it is not a regular product registration, a Section 18 must still meet the health standards set by FIFRA. In submitting the application, Ohio proposed a number of risk mitigation steps to increase the likelihood the product would meet the standard. Preliminary indications are that the residential risks may still be unacceptable, according to NPMA Senior Vice President Bob Rosenberg.
It’s also important to note that should the exemption be granted, the addition of propoxur to a PMP’s bed bug control toolbox will not solve the national bud bug problem. The propoxur formulations — which include a pair of aerosols and a ready-to-use oil formulation — have their limitations. "We’re not out of the woods yet," said Potter, who noted that the propoxur products will "provide some additional tools that companies can utilize to wage war."
The author is Internet editor and managing editor of PCT magazine.