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REST EASY EFFICACY STUDY EVALUATION AGAINST Cimex lectularius (performed for RMB Group, LLC) Rest Easy, a new direction in kill and control of bedbugs based on natural essential oils with a long history of effectiveness against a variety of insects, is proven to, on contact, cause rapid extermination of Cimex lectularius. It also shows a highly effective repellency that creates a zone of protection which overcomes strong attractive forces for this pest. As opposed to other technologies, residual efficacy is neither hazardous nor biopersistent. The residual benefit of Rest Easy is due to the slightly volatile essential oils, offering a gradually decreasing kill and repellency effect over a seven to fourteen day period (dependent on actual environmental conditions). There are no immediate or permanent lingering hazards to groups such as pregnant women and children. NOTE: Rest Easy meets all requirements for exemption from EPA registration as per 25(b). Background: Cimex lectularius, the common bedbug, has returned to its former status as a recurrent and prevalent pest. Until the elimination of DDT usage, heavy treatment dosages of that pesticide had mostly eliminated this pest. However, due to the limitations of use for many classical chemical insecticides, bedbugs continued survival outside the U.S., increased travel from those locations to our country, and the opportunistic nature of these insects, they have returned. 1

In spite of the perception that bedbugs are only associated with poor hygiene, infestations have been discovered in better homes and premier hotels. With little chemical threat to them, all they need is to be transported to a new location where humans frequent. The primary concern over bedbugs, outside of simply the perception of poor hygiene, involves their bites (C. lectularius has adapted a preference for humans, but there are more than 92 species known). As opposed to other organisms that focus on areas such as the ankles or under clothing, bedbugs typically feed on bare skin that is exposed while sleeping. The bites can result in itching, irritation, or even allergic-type reactions. However, they are considered to be a low risk for transmission of pathogenic infections. Adult bedbugs are about ¼ inch long, flat, oval, and reddish-brown. Immature nymphs are usually smaller and lighter in color. Eggs are offwhite and require magnification to differentiate from dust particles. The time between laying and hatching of eggs, which are typically resistant to chemical treatments, is 6 17 days. After hatching, bedbugs go through five molting stages, requiring a blood feeding cycle during each stage. Under optimal conditions (70 90 F and a ready human source for feeding), the full growth cycle is completed in four to five weeks. However, under cooler temperatures or without a blood source, bedbugs can survive for many months, simply waiting for more optimal conditions to return. Bedbugs are primarily active at night, with the highest level of activity claimed to be about one hour before sunrise. During the day, they typically congregate close to their feeding sites, even though they have been known to travel up to 100 feet for feeding. Their flat, small shape allows them to hide in cracks and crevices of flooring, baseboards, wood bed frames and headboards, and inside hollow legs. Additionally, they are found between mattresses, in seams and tufts, in boxsprings, behind wall-attached 2

headboards, in chairs and sofas (especially when used for sleeping), along carpet edges, and in draperies. In addition to the organisms themselves, signs of bedbug infestation include dark spotting and staining by their excrement; rusty or reddish spots of blood on sheets, mattresses, and walls; eggs and eggshells; and molted skins of maturing nymphs. Engorgement after a bite typically takes three to ten minutes, with most occurrences being seldom noted. On occasion, movement by the target host causes the bedbug to prematurely release, with a subsequent second bite moving to a nearby location. As this may occur several times, bites often appear somewhat linear, rather than clustered. Treatment options: The first step in any efficient treatment strategy has to involve mechanical, rather than chemical, action. Clutter must be removed, bedding and clothing bagged and laundered at minimum 120 F, and site-specific vacuuming performed (bedbugs tend to be difficult to dislodge and may need physical scraping by the vacuum attachments). Be sure to discard any vacuumed contents in a sealed bag. In spite of the necessity to limit the level of infestation by these mechanical efforts, chemical treatment is still needed to complete the process. In recent years, serious concerns have been recognized for many of the remaining pesticide options. In addition to concerns over potentially allergic reactions, long-term exposure in the close quarters of homes and hotels has highlighted risks of toxicity and cancer threat. 3

The market options currently available for bedbug control basically fall into three groups: Insect Growth Regulators (IGRs) Pyrethrins and related synthetic pyrethroids New technologies Insect growth regulators: Insect growth regulators seem to work fairly safely and do cause insect sterility. However, they are not contact killers and allow organisms to survive and feed. With a potential lifespan of 12 18 months, problems associated with an infestation can remain far too long. Pyrethrins and pyrethroids: Pyrethrum is derived from dried chrysanthemum flowers, and its active ingredients include pyrethrins. Pyrethroids are synthetic pyrethrins designed and formulated to increase their toxicity and residual half-life. These type chemicals have been extensively promoted as the new safe alternative to more classical pesticides. However, their widespread use (over 1,350 products on the market) and high exposure risk, including to children in schools, have led to substantial concerns. Even though natural in origin, pyrethrum and pyrethroids are still toxic chemicals. Despite the fact that most exposures caused only low to moderate illness, an article in the Journal of the American Medical Association (JAMA) showed 4.5% (1998 to 2002) of all acute illnesses due to pesticide exposure in schools were due to pyrethrins. 4

Additionally, especially with efforts to provide longer-lasting effects, chronic exposure issues have been raised. As a part of the routine EPA Reregistration and Eligibility Decision on pyrethrins in 2006, and due to both acute and chronic health concerns, the EPA now requires all reregistrations of such products to remove day-care centers, nursing homes, schools, and hospitals from labels. With respect to short-term, acute issues, various pyrethrin chemistries have tested to be: Gastrointestinal toxicants Liver toxicants Kidney toxicants Neurotoxicants Due to limited information collected so far, the true levels of acute toxicity concern for humans are still to be determined. With respect to chronic health issues, the EPA review identified that there is suggestive evidence of carcinogenicity, along with probable evidence of endocrine disruption. The actual risk for human cancer is still to be evaluated, while a determination for risk of endocrine (hormonal) disruption has been completed. No decision has yet been made as to required changes in warnings or use instructions for pyrethrin products. Of further concern, almost all pyrethrin products use piperonyl butoxide (PBO) as a synergist, helping reduce the effect of defensive responses by target organisms. PBO is identified as an experimental carcinogen and equivocal tumorigenic agent. Outside of the health concerns, PBO is also a serious environmental risk, being listed as a SARA 313 chemical requiring reporting for the Superfund toxic chemical release inventory. 5

New technologies: With the continued concerns over classical insecticides, the lack of effective control by growth inhibitors, and the new issues arising with the pyrethrins and pyrethroids, many new technologies are being brought to the market. Unfortunately, a substantial number of these have proven suspect or ineffective. Some products claim unbelievable control, using buzzwords and testimonials, while having a pitiful record of answering efficacy complaints. Others seem to be good cleaning products, but don t seem to have any effect on these resilient insects. However, one new technology, Rest Easy, offers high efficiency based on some age-old ingredients. In addition to an impressive target kill, Rest Easy creates a new defense strategy for control. Whereas other chemicals MUST be persistent in their toxicity to have any effect, Rest Easy offers a repellent effect that establishes a safety zone around treated areas. Instead of leaving toxic traces that might simply be evaded, the volatile fragrance helps keep these bugs from skirting treated areas and attacking their prey. Utilizing ingredients exclusively from the EPA s 25(b) list of Minimum Risk Pesticides, Rest Easy was developed to capitalize on nature s own defense systems. Starting in 1996, the EPA recognized a series of ingredients as so low risk as to be unnecessary for registration under FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act). Please note that some states require registration under their own regulations to ensure that these products meet labeling and ingredient requirements. Ingredients in Rest Easy were specifically chosen to provide a synergistic blend of high efficiency, while maintaining the highest possible level of human and pet safety. The following is an evaluation of this product s efficacy against C. lectularius, the common bedbug. 6

TEST 1 REST EASY BEDBUG EVALUATION DIRECT SPRAY Treatment Number 30 minutes 60 minutes 240 minutes Kill Control (no treatment) 20 20 20 20 0% Direct spray Rest Easy 20 0 N/A N/A 100% TEST 2 REST EASY BEDBUG EVALUATION - REPELLANCY Treatment Number Crawling to heat (10 min) Repellancy Control (heat only) 10 8 No Rest Easy sprayed, dried 30 min, heat 10 1 Yes 7

TEST 3 REST EASY BEDBUG EVALUATION - PERSISTENCE Treatment Number 30 minutes 60 minutes 240 minutes Kill Control (no treatment) 10 10 10 10 0% Rest Easy spray then wipe 10 10 10 10 0% Pyrethrin spray then wipe 10 0 N/A N/A 100% Porous wood control (no treatment) 10 10 10 10 0% Porous wood with Rest Easy spray 10 5 5 5 50% TEST 4 REST EASY BEDBUG EVALUATION RESIDUAL EFFECT Treatment Number Crawling to heat (10 min) Repellancy Rest Easy (after 30 minutes) 10 1 Yes Rest Easy (after one day) 10 2 Yes Rest Easy (after two days) 10 3 Yes Rest Easy (after five days) 10 2 Yes Rest Easy (after seven days) 10 3 Yes Rest Easy (after ten days) 10 6? Rest Easy (after fourteen days) 10 8 No 7

Results: Test 1: Rest Easy killed 100% of direct contact test organisms within 30 minutes (about 90% within the first five seconds). Test 2: Rest Easy provided effective repellancy even after drying of a treated material. Test 3: Rest Easy did not leave any persistent toxicity when wiped from a surface. Rest Easy provided 50% residual kill on a porous wood surface. Test 4: Rest Easy showed a gradual reduction in efficacy over a fourteen day period, with primary benefits up to between seven and ten days. Interpretation of results: Rest Easy is a highly effective direct contact killer of bedbugs. As expected, Rest Easy operates without and avoids long-term, toxic residuals, such as encountered with the chemical pesticide pyrethrins (which left a toxic film, even after wiping). However, after providing an effective kill of contacted bugs (such as from spraying between mattresses, behind headboards, and in cracks), the residual presence of Rest Easy adds beneficial repellency that helps create a zone of protection, rather than just pinpoint toxicity. 8