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De Omnibus Dubitandum - Lux Veritas

Sunday, May 10, 2009

The Butterfield Bill: Activity as a Substitute for Accomplishment, Part II

By Rich Kozlovich

On April 14th and 15th of this year the EPA hosted something that they called the Bedbug Summit, which “drew almost 300 state and federal regulatory, public health, and housing officials, academics, landlords/property managers, pest professionals, and other key stakeholders”

 On April 19th, 2009 I published a critique of EPA’s “Bedbug Summit”, called Bedbug Summit: Activity As A Substitute For Accomplishment, which clearly outlined what could only be called a great public relations deception and a farce. That is, if your goal is the control of bedbugs. If the goal was to misdirect, deceive and justify the creation of a massive, costly and ineffectual multilayered bureaucracy and promote ineffectual pest control programs such as IPM, then it was a smashing success. Quite frankly, it disturbed me to realize that for some reason I didn’t connect the dots at the time between this and the Butterfield bill. I know…I know…there is no such thing as a conspiracy.

Currently there is a bill introduced by Congressman G.K. Butterfield of North Carolina on May 5th, 2009 that the NPMA officially supports and has asked everyone in the structural pest control industry to openly support. The Butterfield bill is entitled, "Don't Let the Bed Bugs Bite Act of 2009", and based on what is in this bill that title is a misnomer.

NPMA believes that this:

“multi-faceted legislation provides critical resources to state and local officials to combat bed bug outbreaks in lodging facilities, residential housing and other settings. Specifically, the bill:

I. Establishes a state bed bug inspection grant program within the Department of Commerce for states to use to help fund inspections of lodging facilities;

II. Expands an existing grant program managed by the Department of Health and Human Services that already provides funds to states for cockroach and rodent control to be used for bed bug prevention and control;

III. Requires public housing agencies to include in annual plans,required by the Secretary of the Department of Housing and Urban Development, measures necessary for the management of bed bugs, similar to their current responsibility to manage cockroaches; and

IV. Directs the U.S. Centers for Disease Control and Prevention to investigate the public health implications of bed bugs.”

NPMA goes on to say:

“His legislation will grant state and local governments, in concert with the professional pest management industry, the necessary resources to more effectively and aggressively manage bed bug infestations.” 

 Before I go any further I wish to state for the record that I am not attacking any individuals at NPMA, their integrity or their work ethic. I have stated this in the past and I will restate it again….these people work and they work hard and they believe what they are doing is in the long term best interests of the industry. In their defense they believe that this bill is going to pass, whether we are on board or not, and in the long run this will give the pest control industry some positioning on these matters for the economic future of our industry.  It is that judgment and view that I wish to challenge.

Apparently Congressman Butterfield believes the first step in eradicating bedbugs is to create a grant program administered by the Commerce Department to inspect hotels and motels for bedbugs in each state. And that each state’s hotels will have 20 percent of their rooms inspected each and every year. Those inspections will be conducted by “trained inspection personnel” and money will be provided to “train the inspectors” and they shall do the following under this bill

I. inspections are conducted by individuals who meet the minimum competency standard or requirement for inspecting or treating rooms in lodging facilities for bed bugs, as adopted by the State agency charged with regulating pest
II. conduct inspections of lodging facilities for cimex lectularius, including transportation, lodging and meal expenses for inspectors;
III. train inspection personnel;
IV. contract with a commercial applicator, as defined in section 2(e) of the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136(e)), to inspect and treat lodging facilities for cimex lectularius;
V. educate the proprietors and staff of lodging establishments about methods to prevent and eradicate cimex lectularius.

And what will this little program cost. Fifty million dollars a year from 2010 to 2013! First off, Congress didn’t find anything that we didn’t already know. The fact of the matter is that taxpayer money is going to be wasted; and for what will the taxpayer’s money be wasted to the tune of fifty million dollars a year? To inspect rooms for bedbugs! We already have trained inspectors….they are called exterminators and they do it for free. They already know what to tell the owners and maintenance people and they certainly know what bedbugs look like and don’t need any further training. We already have health departments requiring treatment. We already have laws in each state that determines who can make those treatments. So, why is there a need to train “new” inspectors and who will these “new” inspectors be?

I don’t believe for a minute that pest controllers will be used for these inspections, except possibly at the beginning, no matter what it says about standards. This grant money is going to be used up by State Health departments, State Universities, State Agricultural departments or whoever is in charge of pesticide regulations in the state in question and they will set the standard to accommodate themselves. 

And because grant money will be available, they won’t have to take the inexpensive way out and use PCO standards. This money will go to state agencies, and I believe to the Health Departments, which will make them secondary de facto regulators of the pest control industry in their states.

This is nothing more than window dressing, creating a gigantic multilayered bureaucracy with the U.S. Department of Commerce, the Center for Disease Control and state agencies all over the country. Bureaucratic activity as a substitute for accomplishment, and when was the last time you saw a bureaucracy disappear?

Nowhere does it discuss the real issue: The EPA’s responsibility for this mess and the introduction of chemistry that works. This bill will spend fifty million each year and accomplish nothing, even if hotels are treated more often. Bedbugs will still be infesting homes, other businesses, buses, trains, cabs, schools…etc., etc., etc., ad nauseam, and where are the requirements for tools that will bring about proper control?

I. Inspections will not eliminate bedbugs.
II. It may fix the blame, but it won’t fix bedbugs.
III. Furthermore, I believe this will lay the ground work for more unnecessary regulations, unnecessary documented training sessions and added licensure.
IV. If that happens, and based on past history, I believe eventually that's where the grant money will go and the requirements will increase.
This isn’t leadership, nor will it manage bed bugs aggressively, effectively or otherwise. We need chemistry that works. This is a singular problem with a twofold solution.

First and foremost, we have to define the real problem. We need to outline the cause. Both of those are easy. We know the EPA is a fault for this plague, we need place the blame right at their feet. We need chemistry that works, either by returning old chemistry, changing labels of chemistry that is currently available or give us new chemistry that works. (NPMA is currently working with EPA on this matter)

Everything else is a waste of money, energy, time and only gives the impression of accomplishment where very little actually exists. There is nothing in this bill that provides for anything that isn’t already being done…. except for getting the fifty million dollars.

To perceive is “to become aware of, know, or identify by means of the senses, to discern, envision or understand. “ My "perceptions" of what is wrong with this bill were easily identified because they should have been obvious to the most casual observer.

So then, what are the “positive aspects” of this Bill?

I. Fifty million dollars is going to be spent every year, and who knows how much more in the future, and yet bedbugs will not be curtailed because of it.
Grant chasers will by positively impacted. That doesn’t seem very positive to me
except for those getting the money. Those with bedbugs will still have them.
II. A great deal of bureaucratic welfare is going to be created and still bedbugs are not going to be curtailed. That doesn’t sound positive to me except for the bureaucrats.
III. Legislators will give the impression that they are doing something worthwhile to stop this plague caused by the EPA. That doesn’t sound positive to me except for the legislators who will give the impression that they are actually doing something.
IV. The real cause of the problem isn’t identified. That doesn’t sound positive to me, except for the EPA who is responsible.
V. No new directives are part of this bill that requires EPA or anyone else to approve chemistry that works. That doesn’t sound positive to me, except for the pest controllers who will be getting large sums of money to control this plague with inadequate tools, and even if the tools needed to eradicate bedbugs are returned, this bureaucratic layer cake will never disappear.

What about the “general public”? How will they benefit? And please don’t tell me how better communications will make a difference in their lives. That isn’t even a logical fallacy.  That would be a blatant falsehood. The claim that this “proposed legislation …will be beneficial for all parties, including pest management professionals, regulatory agencies and the general public” is a fallacy of composition.

There is only one party that we should be focusing on. Not pest controllers, not regulators, and especially not regulators. The public!

It's the public and the public only who should be our one and only concern. In no way will this bill alleviate the public’s suffering. That, and only that, should be our concern. Everything else is horsepucky!

I would like to share a quote with everyone from Thomas Sowell.

“Life is all about tides. There are those who catch the tide and those who
row against the tide. Those rowing against the tide will always go in that
direction no matter which way the tide is moving. The rest have no direction and
will simply follow the tide. Those who row against the tide are in better shape
than those who go with the tide. Not only physically, but intellectually,
emotionally and psychologically! When the tide changes direction, and it will,
guess who will be in the lead? “

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