Ohio’s Section 18 Emergency Exemption Testimony

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Ohio House Environment and Brownfield Development Committee

Proponent Testimony on HR 182

Presented by

Andrew Christman, Co-owner, The Ohio Exterminating Co., Inc

And

President - Ohio Pest Management Association (OPMA)

March 24, 2010

Mr. Chairman Mallory and Members of the Committee,

My name is Andrew Christman and I am the 3rd generation owner/operator of The Ohio Exterminating Co., Inc. and I am currently the President of the Ohio Pest Management Association (OPMA). I would first like to thank you for the opportunity to testify today as a proponent for HR 182. Before getting into the importance of this resolution, I thought it might be helpful for me to give you a bit about my background as well as the history of bed bug control in the United States.

I grew up in my families pest control business with my father and grandfather. My Grandfather started his career as a chemist and an accountant and realized the public need for effective pest control products. My grandfather, Lowell Christman developed these products and sold them retail. Shortly after the retail store opened his customers requested that he come to their residents and apply the products for them. In 1936 The Ohio Exterminating Co., Inc. was established as both a pest control product retail outlet and a service company.

My grandfather was instrumental in working on behalf of the pest control industry in Ohio as a key member of the committee that worked with the Ohio Department of Agriculture, the Ohio Legislature and other pesticide use associations in developing and passing the Ohio Pesticide Law. He was also a past president of the Ohio Pest Management Association.

I have been a licensed Commercial Pesticide Applicator certified by the Ohio Department of Agriculture since 1997. I have served my industry in many capacities including various chair positions, board member and executive board positions within the Ohio Pest Management Associations, including my current elected role as President of the Ohio Pest Management Association.

I am a Steering Committee member of the Central Ohio Bed Bug Task Force (COBBTF) and an invited member of the Ohio Department of Health Bed Bug Work Group.

This month I traveled to Washington D.C. on March 1st and 2nd where we had our National Pest Management Association’s annual Legislative Day. We had 17 Pest Management Professionals from Ohio in attendance and we went up to the hill to talk to the Ohio members of Congress about issues critical to our industry, including bedbugs. I personally meet with Sherrod Brown and George Voinovich’s aids.

Based upon my history with the pest management industry and state and federal pesticide laws, I believe some information about bed bugs and some background of the history of bed bug control would be helpful to you.

Bedbugs are small, full grown about 3/16 to ¼ inch long and reddish brown in color. Their nutrition comes from blood meals, normally from humans. They tend to hide very well and come out only to feed once they sense warm temperatures and carbon dioxide (from exhaling). They have piercing mouthparts with which they pierce the human skin then draw the blood through a tube. This feeding behavior or mechanism is in part the reason that the current pesticides are not providing effective control. I will revisit this issue in a moment.

Back to the history of bedbugs. They have been very common throughout the world during all ages of human habitation. However due to long lasting and very effective pesticides developed during the 1940’s and 50’s bedbugs were pretty much controlled throughout the United States and many other countries by the late 1960’s. By the early 1970’s, bedbugs were totally under control and almost totally eliminated from the United States and many other developed nations. As a matter of fact, prior to this new onslaught of infestations, the last time our company did a bedbug service was in the early 1970’s. The effective control first came from products in the class of Chlorinated Hydrocarbon pesticides including trade names such as DDT, Chlordane and Lindane. Eventually, bedbugs developed resistance to these products and the next products that proved effective were the Organophosphate class of pesticides, such as trade names Dursban and Diazinon. With the use of these products, control of bedbugs was fairly simple, very effective and inexpensive.

Through the 80’s and 90’s the pest control landscape changed due to many changes in regulations of pesticide use and pesticide application methods. There were limitations on what pesticide products could be used indoors and the actual allowable application methods were changed (reduced). Then in the early 90’s Congress passed the Food Quality Protection Act (FQPA). One of the primary initiatives of FQPA was to reduce the publics’ overall exposure to pesticides. FQPA established a concept called “the risk cup” or cumulative exposure to specific products. USEPA set forth as part of their cumulative risk assessment to establish “the risk cup” for each individual product. Each product, by class or chemistry, was expected to come within compliance of EPA’s limited “risk cup” or exposure by selecting which uses to withdraw or eliminate from their portfolio.

What happened was that pesticide manufactures had some very difficult decisions to make, and they eventually made their decisions based on economics. Manufacturers chose to preserve the products that contributed to the larger uses of their customers, which complimented their bottom line. So, at that time we lost the indoor uses of the Dursban and Diazinon products that had provided effective control of bedbugs and many other insects.

We currently have very effective products for the control of insects such as ants, termites, cockroaches, spiders and centipedes etc…. while these current products are effective for those insects, they have not been effective against bedbugs. The reasons, as I mentioned earlier, in part are due to the feeding habit of the bedbug (siphoning human blood through a tube like mouth piece) and an exoskeleton that is very thick and difficult for pesticides to absorb through and penetrate.

The mode of action of a pesticide is also important. A pesticide is either (1.) ingested by the insect by eating it (2.) by grooming itself and ingesting it or (3.) dermal penetrating or soaking through its cuticle – its skin. Well, this is exactly where the problem of control comes up. Bedbugs suck blood, so they don’t have a way to (1.) Ingest a pesticide (2.) they do not groom them selves very often and don’t have the opportunity for ingesting the pesticide and lastly (3.) their exoskeleton (cuticle or skin) is thicker than most insects and the class of products that we have available does not dermally penetrate the skin.

A product like Propoxur, which is what Ohio’s Section 18 Emergency Exemption request is asking for, is an effective product against bedbugs and is one that kills on contact and has a residual effect to keep killing via dermal penetration after the application has been made.

Now that you know a little more about bed bugs and the products used to control bed bugs, you need to know that HR 182 merits your support.

HR 182 urges the USEPA to grant an emergency exemption for the use of Propoxur to control bed bugs. We need this product to solve the bedbug infestations that the citizens of Ohio are plagued with. The majority of Ohioans dealing with this problem cannot afford proper and safe treatments and this is affecting their quality of life. The cost of treatments can range anywhere from $250.00 - $1,000.00+ per service and often times can take 3-4 services. Additionally, the cost of subsidized housing is growing and I predict in the near future the financial burden of bed bug treatments alone will be an out of control. No one has projected these bedbug control costs into their budgets, nor can they continue to afford them.

A huge area of concern is that many people are taking matters into their own hands. I often witness residents using non-labeled pesticides that are not effective and very costly while vastly exposing themselves and their families to potential hazards by the misuse of these pesticides.

It is noteworthy that an emergency exemption is not easy to obtain and it is rarely granted. In fact, when we first raised the issue with our peers at the national level and in other states we were told it couldn’t be done. We are extremely grateful to Representative Mallory in the House (and State Senator Kearny) for taking the time to understand this difficult issue. In fact, Ohio has become a leader in this discussion and again, we are very appreciative for Rep. Mallory and Senator Kearney for their help.

Additionally, the Ohio Department of Agriculture has been incredibly diligent in working with USEPA on this issue. Director Boggs at the Ohio Department of Agriculture formally filed the Section 18 request. The Section 18 request is asking for the use of Propoxur to be a “restricted use” product. This is important, as a restricted use product requires only trained and licensed pest management professionals can purchase and apply this product.

Pest Management Professionals are licensed through the State of Ohio by the Ohio Department of Agriculture. One must take and pass an examination to obtain their Commercial Pesticide Applicators license. One must also obtain the proper insurance and maintain continuing education credits to keep their licenses. Bed bug biology, behavior and control are the number one topics at our continuing education seminars today.

We (OPMA) are very fortunate to have such an experienced and hard working staff at ODA. While we are still a long way from having a product in hand, we wanted to thank Director Boggs, Matt Beal, Mike Eckhart and their staff for tirelessly pursuing this complicated but important issue on behalf of our industry and the citizens of Ohio.

In conclusion, Mr. Chairman and members of the committee, I urge your support of HR 182 and thank you for the opportunity to sit in front of you today.

I am more then happy to field any questions you may have at this time.

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For more information on this subject please go to My Bed Bug Series.