The Ohio Department of Agriculture has asked the EPA for a public health exemption which would allow it to use the carbamate insecticide propoxur to treat bed bugs (with a 14-day retreatment period). (We mentioned this back in November. And New York vs. Bed Bugs discusses how Section 18 exemption requests work here.)
Propoxur is no miracle cure for bed bugs, but it is potentially a good tool for fighting bed bugs, especially strains resistant to pyrethroids. It would be a big help.
The Environmental Protection Agency is now accepting comments on the request (deadline 1/21/2010).
The following is an excerpt from the EPA’s notice [EPA–HQ–OPP–2009–0856; FRL–8802–9]
Propoxur; Receipt of Application for Emergency Exemption; Solicitation of Public Comment
Under section 18 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (7 U.S.C. 136p), at the discretion of the Administrator, a Federal or State agency may be exempted from any provision of FIFRA if the Administrator determines that emergency conditions exist which require the exemption. The Ohio Department of Agriculture (DOA) has requested the Administrator to issue a public health exemption for the use of propoxur on indoor residential single or multiple unit dwellings, apartments, hotels, motels, office buildings, modes of transportation, and commercial industrial buildings to control bed bugs. Information in accordance with 40 CFR part 166 was submitted as part of this request.
As part of this request, the applicant asserts that an emergency exemption is warranted because of the prevalence of control failures with other existing labeled insecticides, in part due to pyrethroid resistance in the bed bug population. Bed bugs are parasitic, blood-sucking insects that prefer humans as a host and tend to inhabit human dwellings. For several decades, pyrethroids have been used to manage the bed bug population in the United States. Since the late 1990s, bed bugs have begun making a comeback, largely due to their development of extremely high levels of resistance to pyrethroid insecticides. Thus, these parasitic insects have been growing rapidly and have re-emerged as a major pest in many towns and cities in Ohio. The ODA states that currently available insecticides are inadequate for the control of bed bugs and resulted in a crisis that poses grave economic concerns, quality of life issues, and potential health risks to the residents of the state. The ODA claims propoxur is one of the few insecticidal ingredients showing excellent activity against bed bugs and would provide an effective
insecticide in a different chemical class for bed bug control.
The Applicant proposes to make applications year-round with a 14–day retreatment restriction. Three propoxur products will be used (all containing 1% propoxur):
• Prenbay 1% Oil Solution (EPA Reg.
No. 655–546) manufactured by Prentiss
• Invader HPX (EPA Reg. No. 9444–
186) manufactured by FMC Corp.
• Prescription Treatment Brand 250
Propoxur (EPA Reg. No. 499–501)
manufactured by Whitmire Micro-gen
Research Lab. Inc.
These products would be applied as a crack and crevice or spot treatment to indoor residential single or multiple unit dwellings, apartments, hotels, motels, office buildings, modes of transportation, and commercial industrial buildings. Application of the products would be applied in quantities sufficient to manage the bed bug infestation in Ohio.
This notice does not constitute a decision by EPA on the application itself. The regulations governing section 18 of FIFRA require publication of a notice of receipt of an application for a public health exemption proposing a use of a pesticide which was voluntarily
canceled under section 6(f) of FIFRA, and which poses a risk similar to the risk which was voluntarily canceled under section 6(f) of FIFRA.
The notice provides an opportunity for public comment on the application.
The Agency, will review and consider all comments received during the comment period in determining whether to issue the public health
exemption requested by the ODA.
You can download supporting materials here (PDF), including a letter from Dr. Susan Jones, Ohio State University entomologist, and draft labels for the products.
And you can submit your comments before 1/21/10, identified by docket identification (ID) number EPA-HQ-OPP-2009-0856, at the Federal eRulemaking Portal.