Page 2 of 2 The use profile proposed is the use of the Pr emium Roach Spray product, 0.15% pyrethrin, as a bed bug treatment. The product is currently regist ered for use to control a broad spectrum of pests including fleas, ants, cockroaches, crockets, earwigs, firebrats, silve rfish, spiders, pillbugs, sowbugs, and many other crawling ins ects. It is registered for i ndoor broadcast, spot, or crack and crevice treatment by professional pest contro l 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, f ood manufacturing, processing and servicing establishments, and on vessels, rail cars, aircraft (cargo ar ea only), buses, trucks, and trailers.

The specific instructions for the label amendmen t for use as a bed bug treatment are present on the label. The product can be applied to areas wh ere there is bed bug harbor age. Application is intended as a spot, crack and crevice or broadcas t 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 applie d as a surface application to carpe ting, drapes, and flooring at the rate of 16 ounces of product pe r 500 square feet. Pr emium 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 ornamental s, and direct application to household pets. Pyrethrins are av ailable in liquid, powder, dust a nd granular formulations. They are applied by commercial and residential appl icators by a wide spectrum of application equipment methods. These uses have been previ ously 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 abatem ent, 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 th e 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 incident al oral and inhalation exposures assessed for indoor foggers (total re lease 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 asse ssment (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.