Charge to the Panel for the March 6-7, 2012 Session of the FIFRA Scientific Advisory 

Panel (SAP) Entitled “Methods for Efficacy Testing for Bed Bug Pesticide Products” 

1

 EPA registered pesticide products are an important part of bed bug management 

programs. In the past five years pesticide users have reported control failures, which they claim 

is due to the lack of bed bug susceptibility to pesticide products that have been applied. 

Subsequently, resistance to pyrethroid insecticides was documented although it has not been 

directly correlated to field application failures. In response, EPA has evaluated the database for 

registered products and concluded that there is a need to standardize approaches to bed bug 

product testing methods to ensure the quality and validity of the efficacy data for these types of 

products. In order to accomplish this, the Agency has developed a draft product performance 

guideline for bed bug pesticide products. The Agency is seeking advice and recommendations 

from the Scientific Advisory Panel (SAP) on scientific issues associated with the proposed Draft 

Product Performance Guidelines “Laboratory Methods for Efficacy Testing of Bed Bug Pesticide 

Products.” 

1) Laboratory test methods. The draft guidelines describe laboratory test methods for 

evaluating the efficacy of a variety of bed bug pesticide products. Please discuss: 

(a) Whether, given the objectives and the types of products being evaluated, the test 

methods are appropriate to evaluate the efficacy of bed bug products with regard to kill 

and knockdown; repellency; pesticide resistance; and discriminating dose. 

(b) Whether there are additional or alternative laboratory test methods beyond those 

discussed in the draft guidelines for testing the efficacy of bed bug pesticide products. 

2) Standardized test system elements and conditions (Section (h) pp. 10). The draft 

guidelines describe standard elements and conditions that are recommended for each type of 

efficacy evaluation. Please discuss: 

(a) The appropriateness of suggested environmental conditions (such as temperature and 

humidity). 

 (b) The proposed test organism. In particular, please discuss: 

(i) Whether the testing should be done only with one species, the common bed 

bug, Cimex lectularius. Whether it is appropriate to use unfed adult bed bugs with 

a sex ratio of 1:1 to test adulticide products. 

(ii) The advantages and disadvantages of including a susceptible strain in every 

test and whether the Harlan strain is the preferred susceptible strain. 

(iii) The advantages and disadvantages of including a resistant strain in every test 

and how an investigator should select a resistant strain or strains. 

(iv) The adequacy of the use of field collected bed bug strains from urban areas in 

three regions of the U.S. to represent the variability in susceptibility of bed bug 
Charge to the Panel for the March 6-7, 2012 Session of the FIFRA Scientific Advisory 

Panel (SAP) Entitled “Methods for Efficacy Testing for Bed Bug Pesticide Products” 

2

populations for conducting efficacy evaluations. 

(v) The recommended approach for grouping and evaluating the data from the 

tested bed bug strains to assess efficacy of bed bug products. 

(c) The advantages and disadvantages of including a positive control in every test. 

3) Specific guidance for laboratory studies for resistant ratio determination, 

characterization of bed bug strain susceptibility, and discriminating dose selection (Section 

(i) pp.11). The draft guidelines propose a method to collect the data necessary to calculate a 

resistance ratio. Resistance ratios should be calculated for bed bug populations collected from 

the field in three regions in the U.S. The lethal dose values to be used in these calculations are to 

be derived from probit analysis. For pyrethroid insecticides, deltamethrin is proposed as the 

laboratory standard. From the collected data and resistance ratio values, the procedure 

recommends an approach to select a discriminating dose for a product. Please discuss: 

(a) Which insecticides should be chosen as standards for other insecticidal modes of 

action. 

(b) Whether it is useful to compare the resistance ratios of bed bug field populations to 

the resistance ratio for a corresponding dose of deltamethrin when evaluating pyrethroid 

insecticides. 

(c) Whether a resistance ratio of 100x is adequate to screen field strains for resistance 

against insecticides and if not, what other approaches are recommended for detecting 

resistance in bed bug populations. 

(d) What type(s) of data analysis and statistical testing would be most appropriate for 

these data sets. 

(e) The discriminating dose selection for products, including whether the LD90 value of 

the least susceptible field population is the best value to use as the basis for 

discriminating dose selection. 

4) Exposure times to product treatments [Sections (j) (pp. 13) and (l) (pp.17)]. For residual 

surface and impregnated material testing, the draft guideline proposes two possible approaches to 

exposing bed bugs to pesticide product applications in the laboratory: 1) single dose with a fixed 

exposure time of 24 hours followed by mortality assessments through 96 hours unless all bed 

bugs die or control mortality exceeds 10%; and 2) single dose with an exposure time that is 

continuous until all bed bugs die or control mortality exceeds 10%. The single dose is generally 

the lowest label recommended dose for the product. Please discuss: 

(a) Whether the exposure times provide sufficient data to measure the efficacy of a bed 

bug pesticide or whether other exposure times or testing scenarios should be used. 
Charge to the Panel for the March 6-7, 2012 Session of the FIFRA Scientific Advisory 

Panel (SAP) Entitled “Methods for Efficacy Testing for Bed Bug Pesticide Products” 

3

(b) Whether percent mortality values or lethal time values should be used as endpoints to 

assess the success of product applications and the advantages and disadvantages of each 

one. 

5) Specific guidance for laboratory studies for forced exposure (no-choice) residual surface 

treatment tests (Section (j) pp.13). The methods described for testing residual surface 

treatments recommend five types of surfaces: unpainted plywood; linoleum tile; concrete board; 

cotton sheet; and medium pile carpet. Please discuss: 

(a) Whether the experimental unit described in the draft guidelines will provide sufficient 

data to show how effectively and how quickly a bed bug product knocks down and kills 

bed bugs, when applied as a residual treatment to surfaces. 

(b) Whether there is a single surface type that could be used as a standard or 

representative surface for testing product residual activity in lieu of testing multiple 

surfaces as recommended in the draft guidelines. 

(c) Whether there are modifications or additional tests that could be recommended to 

improve residual surface treatment testing. 

(d) What type(s) of data analysis and statistical testing would be most appropriate for 

these data sets. 

6) Specific guidance for laboratory studies to determine if bed bugs are repelled by, or 

attracted to, pesticide product residues (Section (k) pp. 15). For pesticide product treatments 

to be efficacious, bed bugs must contact pesticide residues. Testing methods should determine 

whether or not pesticide residues alter bed bug behavior, either by repellence from or attraction 

to pesticide treated areas. Please discuss: 

(a) Whether the experimental unit described in the draft guidelines will provide sufficient 

 data to measure the duration and extent to which a pesticide product’s residues repel bed 

 bugs. 

(b) Whether conditioning of experimental bed bug harborages is necessary. 

(c) Whether individual responses and/or group responses should be used to determine 

whether bed bugs are repelled by pesticide product residues in harborages. 

(d) What type(s) of data analysis and statistical testing would be most appropriate for 

these data sets. 

7) Specific guidance for laboratory studies for testing pesticide impregnated material 

products (Section (l) pp. 17). The draft guideline proposes no-choice and choice tests for 
Charge to the Panel for the March 6-7, 2012 Session of the FIFRA Scientific Advisory 

Panel (SAP) Entitled “Methods for Efficacy Testing for Bed Bug Pesticide Products” 

4

treated materials. Both are to be conducted in the presence of a non-human host or artificial 

membrane system to provide a source of blood. The proposed tests evaluate mortality, blood 

feeding inhibition, and preference for treated versus untreated surfaces. Please discuss: 

(a) Whether the experimental unit is adequate for evaluating mortality and blood feeding 

inhibition following exposure to impregnated materials. 

(b) Whether the use of an artificial membrane system to simulate an animal host and 

provide blood for questing bed bugs is adequate, or whether an animal host is necessary. 

(c) Whether the assessment period is adequate. 

(d) Modifications or additional tests that would improve pesticide impregnated product 

testing. 

(e) Adequacy of the experimental unit to provide an experimental design and adequate 

data to evaluate repellency. 

 (f) What type(s) of data analysis and statistical testing would be most appropriate for 

 these data sets. 

8) Specific guidance for laboratory studies of indoor fogger products (Section (m) pp.19). 

The methods described for indoor fogger testing recommend use of an experimental unit that 

includes a 216 cubic feet or larger Peet-Grady chamber. The test container for bed bugs has 20 

holes (1/16" diameter) in it to simulate a crack and crevice treatment and a bed bug refuge. 

Please discuss: 

(a) Whether the experimental unit is adequate for testing indoor foggers and misters. 

(b) Modifications or additional tests that could be recommended to improve indoor 

fogger testing. 

 (c) What type(s) of data analysis and statistical testing would be most appropriate for 

 these data sets. 

 9) Specific guidance for laboratory studies for testing ovicidal products (Section (o) pp. 22). 

Efficacious ovicidal products are likely to improve the effectiveness of bed bug management 

programs. The draft guidelines describe methods for evaluating product efficacy against eggs 

from direct application and contact with residual surface applications. Please discuss: 

(a) Adequacy of the experimental unit for testing ovicidal products. 

(b) Modifications or additional tests that could be recommended to improve ovicidal 

product testing. 
Charge to the Panel for the March 6-7, 2012 Session of the FIFRA Scientific Advisory 

Panel (SAP) Entitled “Methods for Efficacy Testing for Bed Bug Pesticide Products” 

5

 (c) What type(s) of data analysis and statistical testing would be most appropriate for 

 these data sets. 

10) Please provide comments on the overall clarity, accuracy and completeness of the draft 

guidelines: “Laboratory Testing Methods for Bed Bug Pesticide Products”. Please provide 

any additional comments that highlight any areas of the draft guidelines that may need to be 

clarified and note any relevant topics that may be missing. Please include references to any 

published literature that could help improve the completeness and clarity of the draft guidelines.