Bed Bug Consulting, LLC
(December 6, 2021)
An effort is underway in New York State to restrict, and in certain cases ban, “bug bombs,” led by State Senator Zellnor Myrie (D-NYC). Total release foggers, more aptly referred to as bug bombs (because in some cases, they literally blow up), are dangerous indoor devices that release an aerosolized plume of toxic pesticides and unknown inert (or other) ingredients in an overpowered, ineffectual attempt to manage common pest problems. As Senator Myrie notes in his legislative justification for the bill, “This is an environmental justice issue disproportionately affecting lower-income individuals, as bug bombs are a relatively inexpensive pest management solution. As a result, individuals living in older, larger multi-dwellings, who also suffer from adverse health outcomes like asthma at higher rates, are disproportionately exposed to the harmful effects of bug bombs.”
Senator Myrie’s legislation, S.7516, will allow only certified pesticide applicators to purchase and use the dangerous devices, and would completely ban their use in multi-unit dwellings. “Foggers should not be used in multi-dwelling buildings, but existing New York state law does not prohibit this use,” Senator Myrie continues in his legislative justification. “Restricting the sale of pesticide foggers to consumers, restricting their use in multi-dwelling buildings, or restricting the use to licensed pesticide applicators will reduce their use by ensuring they are applied only by personnel trained to understand and follow the restrictions and warnings on the product label and will result in better targeting when they are used.”
While eliminating consumer use by restricting the devices to certified pesticide applicators would be an important step forward, there is considerable evidence to justify an all-out ban that extends beyond multi-family units. Problems with these devices stretch far back. In spite of over 450 bug bomb related illnesses between 2001-2006 in the United States, EPA rejected a petition from the NYC Department of Health (DoH) in 2009, claiming that incidents were “overwhelmingly minor in nature,” resulting from “a few basic errors” and concluded that “label improvements can mitigate these risks.” EPA subsequently introduced new labels, this time with comic-book style pictures indicating the steps required to use the products.
Almost a decade later, in 2018, CDC officials published a new report on the revised labels, determining that EPA’s actions represented a public health failure. Between 2007 and 2015, CDC cataloged 3,222 illnesses caused by bug bomb use. This nearly 8-fold increase in reported incidents reveals that EPA’s new labels caused more problems and confusion than the previous labels already determined to be deficient. The main cause of poisoning was a failure to leave the premises. The CDC report also notes, “Some users ventilated treated premises for the recommended length of time or longer, but still became ill, suggesting that ventilation might be inadequate or the recommended period might be insufficient to fully eliminate TRF [total release fogger] residuals before occupancy.”
In addition to the inherent dangers of using these products is the fact that they do not work at all, according to a 2019 study. “In a cost-benefit analysis, you’re getting all costs and no benefits,” said Zachary DeVries, PhD, co-author of the study. “Bug bombs are not killing cockroaches; they’re putting pesticides in places where the cockroaches aren’t; they’re not putting pesticides in places where cockroaches are and they’re increasing pesticide levels in the home.
Many common household pests, like cockroaches and bed bugs, have displayed widespread resistance to the insecticides primarily used in bug bombs—synthetic pyrethroids—the primary failure with bug bombs is that the pesticide does not get into the cracks and crevices where the insects hide. As a result, pesticide levels in one’s home can increase 600-fold – creating a long-term problem, with synthetic pyrethroids persisting on indoor surfaces for over a year.
The U.S. Centers for Disease Control and Prevention (CDC) finds that EPA label restrictions on total release foggers, otherwise known as “bug bombs,” are a public health failure. Bug bombs pose a significant risk of acute illness to individuals even when they attempt to follow new label instructions. Beyond Pesticides has long called for bug bombs to be banned, as myriad nontoxic alternative strategies are available to successfully manage household pests.
Bug bombs are small cans primarily comprised of an insecticide, often a synthetic pyrethroid, a synergist such as piperonyl butoxide (PBO), and an aerosol propellant. In addition to the explosion/fire risk if the aerosol product is used in an unattended home near a pilot light or other spark-producing appliance, both synthetic pyrethroids and PBO pose acute and chronic human health risks. PBO is added to pesticide formulations to increase the toxicity of synthetic pyrethroids, and has been linked to childhood cough. Peer-reviewed research associates synthetic pyrethroids with behavioral disorders, ADHD, and delayed cognitive and motor development, and premature puberty in boys. Not only can bug bombs acutely poison, but once applied these chemicals can persist in the home for over a year, putting individuals and families at risk of chronic exposure and subsequent health issues.
CDC’s 2018 report, Acute Illnesses and Injuries Related to Total Release Foggers, updates a previous study released in 2008 with new data reveals that EPA’s attempt to reduce bug bomb illness and injury through label changes was unsuccessful. Looking at records from 2007-2015, a total of 3,222 unique cases of illness and injury were reported. The report indicates, “No statistically significant reduction in overall incidence of TRF [total release fogger]-associated injuries and illnesses was observed in the first 3 years after the label revisions took effect.” Incidents ranged from failing to leave an area after releasing the bug bomb, reentering the premises too early, use of too many products for the space provided, and even explosions related to the ignition of aerosols released from the product.