|Manufacturers who claim to control insects |
affecting human health, like this head louse,
must be properly registered and have data
that shows efficacy against the target pest.
As a result of false claims and illegal marketing of untested products for bed bugs and head lice, yesterday the Federal Trade Commission issued a judgment and settlement with a Texas-based manufacturer of cedar oil based insecticides. This action was a follow-up to charges filed last fall against another manufacturer of an unproven bed bug treatment containing cedar, cinnamon, lemon grass, peppermint and clove oils.
So what's so bad about making dubious insect control claims for a supposedly "safe" product like cedar oil? After all, the U.S. EPA has frequently let the market determine which products really are effective against many pests. And if the product really is "safe", what's the harm of promoting it and letting consumers figure out whether it works or not? We know that cedar oil does have effectiveness against some pests, like many other essential oils.
Historically regulators have drawn a line in the sand, and rightly so, for products that claim to control bed bugs, mosquitoes, head lice or other pests affecting human health. If you think you are protecting your or your children's health by using a product, the federal government has long taken the stance that you have a right to be reasonably sure that the product should work as advertised.
While the FTC cautions consumers about advertisements that offer quick solutions to bed bug infestations, this is a problem that affects professionals as well. Even professionals are prone to be duped by false or overblown marketing claims. Consider this: if it were easy to control bed bugs with a do-it-yourself product why would people continue to need your professional services? And look around. Are your competitors finding bed bug control easy? There is still no "silver bullet" for bed bugs.
What's missing from many marketing claims is scientific research involving replication and untreated controls. And it makes sense that a company selling a product for such uses should be able to produce research results that justify their sales claims. So if you're considering investing in a new bed bug insecticide for your home or business, here are some questions to ask:
- Is the product registered with the U.S. EPA as a bed bug (or head louse or mosquito, etc.) insecticide?
- If a manufacturer claims their product to be exempt from EPA registration, is the company also making claims that their product protects humans from pests that can harm human health? If so, they may not be qualified to be exempted from label requirements. For the rules concerning exempt pesticides, and a list of active ingredients that really are exempt under the 25(b) provision of FIFRA, go to http://www.epa.gov/oppbppd1/biopesticides/regtools/25b_list.htm
- What is the toxicology profile of the product? Just because a product is natural doesn't mean it's safe. Ask to see the Safety Data Sheet and find out whether the product has been tested by the EPA.
- Can the manufacture produce data from an unbiased testing laboratory to show the efficacy of their product? Do the data include comparisons with untreated controls, and were tests replicated and shown to be statistically significant?
- Does this data show that both susceptible and pesticide-resistant strains are killed? This is especially important for bed bugs. I've seen some products tested only against bed bug strains that are known to be highly susceptible to most insecticides (e.g., the bed bug 'Harlan strain'). Such products may not perform as well against tough field strains that your technicians are most likely to encounter.
- Does the product have to be sprayed directly on the pest, or is there data to show that exposure to dried residues will also kill the pest? If residual testing was conducted, how long was the pest exposed to the residue? Is this exposure time realistic for the bed bug populations you are treating?
- Does the data show that the product kills eggs as well as nymphs and adults? Again, this is especially important for bed bugs.
- How well does the product perform compared to other standard pesticides being used for the pest?
And if your customer asks you about why they need your services when they can buy "Kilz Em Safe" online or at the local garden store, it might pay to point them to the FTC's warning against products that promise a quick solution. Remind them that when they hire you, they're paying for more than insecticide. Every good pesticide applicator knows that it's not just a natural insecticide that will get the job done safely. It's the knowledge of where and how to safely apply a good insecticide that's important.