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The use profile proposed is the use of the Premium Roach Spray product, 0.15% pyrethrin, as a 

bed bug treatment. The product is currently registered for use to control a broad spectrum of 

pests including fleas, ants, cockroaches, crockets, earwigs, firebrats, silverfish, spiders, pillbugs, 

sowbugs, and many other crawling insects. It is registered for indoor broadcast, spot, or crack 

and crevice treatment by professional pest control operators (PCOs) and residential consumer 

users. The product is registered for use inside non-food handling buildings such as apartment 

buildings, homes, hospitals, non-food areas of hotels, industrial buildings, laboratories, 

mausoleums, motels, nursing homes, private residences, schools, stores, utilities warehouses, 

non-food areas of restaurants, food manufacturing, processing and servicing establishments, and 

on vessels, rail cars, aircraft (cargo area only), buses, trucks, and trailers. 

The specific instructions for the label amendment for use as a bed bug treatment are present on 

the label. The product can be applied to areas where there is bed bug harborage. Application is 

intended as a spot, crack and crevice or broadcast surface application. The proposed label states 

the product is to be applied behind dressers, cove base, under carpets and furniture, inside and on 

box springs, under beds, behind mirrors and pictures and other locations where bed bugs harbor. 

The product is also to be applied as a surface application to carpeting, drapes, and flooring at the 

rate of 16 ounces of product per 500 square feet. Premium Roach Spray can also be applied 

directly to mattresses, with applications focused on seams and folds. The proposed label 

specifies that the user should allow mattresses to dry thoroughly before the bedding is replaced. 

The active ingredient, pyrethrin, is also registered for residential uses as a pest control in homes 

and outdoor domestic structures, on gardens, lawns, and ornamentals, and direct application to 

household pets. Pyrethrins are available in liquid, powder, dust and granular formulations. They 

are applied by commercial and residential applicators by a wide spectrum of application 

equipment methods. These uses have been previously assessed in the Health Effects Division 

(HED) human health risk assessment for the registration eligibility decision (RED) (D326648, 

3/16/06). Residential scenarios assessed include mosquito abatement, turf treatment, indoor 

fogger use, pet treatment, space sprays, and metered release. Occupational risks for pest control 

operators were also assessed for indoor surface spray treatments. 

The anticipated application rate and exposure for the pyrethrin use as a bed bug treatment is not 

expected to be greater than the occupational and residential uses previously assessed for indoor 

insecticide treatments in the HED risk assessment for the RED. Exposure and risks from the 

proposed bed bug use is expected to be the same or less than the incidental oral and inhalation 

exposures assessed for indoor foggers (total release foggers), indoor space sprays, mosquito 

misting systems and metered release uses. 

As residential exposures are not expected to be greater for the bed bug use than the residential 

exposures used in the previous aggregate assessment (D326648), and no new dietary assessment 

is required as there are no proposed changes to agricultural uses or crop tolerances based on the 

bed bug use, a new aggregate assessment is not required. Given these considerations, HED has 

no objection to granting the proposed use.