MR. ROCH LONGUEPE, 6220 Allan Street, Halifax, Nova Scotia, Canada, B3L 1G6 Email: federation@campus.ie , longueepee@campus.

ie Telephone: (902) 425-4768 Toll Free: 1-877-271-2388 NOVA SCOTIA DEPARTMENT OF ENVIRONMENT AND LABOUR Environment Monitoring and Compliance Division PO Box 697, Halifax, Nova Scotia, B3J 2T8 Attention: MR. GERARD MACLELLAN, Executive Director, RE: Parasitic infestations (Bed Bug, Cimex lectularius) DELIVERED IN PERSON Tuesday, March 22, 2005.

Mr. MacLellan, Thank you for your letter of response dated Thursday, March 17, 2005. There are a few concerns I wish to highlight for your consideration. In your letter you write Staff have been in contact with the Medical Officer of health (sic) and isolated cases are not considered a public health Hazard. (Sic) I note that in my letter to Causeway Bay Management that I made no mention of other parasitic infestations, except on that property. However, the words of your letter do allude to other occurrences. These cases are not isolated. How can your department and/or affiliates consider these occurrences are isolated? How many cases, how often, constitute isolated? This parasite is not caused by filth or unkempt places. Rather it has to be introduced by a physical carrier. It is mainly clothing and baggage of travelers and visitors, secondhand beds, bedding materials, furniture, and laundry that spread these parasites.

The property where I first learned of this parasitic infestation namely 2327 Brunswick Street, is residence to an estimated 1,500 people. There are three buildings joined by an underground connection to parking garages for each of the buildings. Tenants performing laundry tasks, garbage removal, and parking frequent these underground connecting tunnels. To date, there have been parasitic occurrences discovered in at least two of the three buildings. Tenants have frequent discussions of the infestation. How many times have pest control personnel been called to respond to Bed Bug, Cimex lectularius infestations? How many times have afflicted tenants quietly relocated, ashamed, and afraid of adverse publicity? Additionally, there are also reports that units have been treated three or more times for extermination purposes. I note that the property belonging to Causeway Bay Management has a long history of problems. The majority of residents in these buildings are students who are studying here from outside of Canada. A number of these students have arrived from countries where this parasite is most common. In the United States of America, New York City is now experiencing an outbreak. The plague is spreading fast. Kansas is reporting outbreaks, as are such widespread states as Massachusetts, Maryland and Texas. In fact, at last count, only Alaska, Idaho, North and South Dakota, Montana, Maine, Vermont and New Hampshire were exempt. As well as North America, the invasion has struck Australia and Western Europe, to cities where they were exterminated fifty or more years ago. Infestations are doubling annually. In some urban centers, including London, the rate of increase may be as much as ten-fold. To aggravate the matter, I have discovered the parasite (Bed Bug, Cimex lectularius) in my own place of residence. I enclose the report of Mr. Andrew Hebda entomologist, and Curator of Zoology with the Nova Scotia Museum who analyzed the parasite, letter dated Thursday, March 17, 2005. I further note Mr. Hebdas attestation of occurrences of this parasitic infestation. Mr. Hebda writes, Although we have not received many specimens in the last year, I note that there are reports of its occurrence at several locations within the Municipality during the last several months. I also have evidence now that the provincial and municipal authorities have known of the problem in Halifax Regional Municipality for two years. Provincial legislation clearly mandates the regulatory body for parasitic infestations is a shared role between the provincial Department of Health, the Department of Environment and Labour and the Municipal government in which the occurrence is reported to be. Bed Bug, Cimex lectularius is a bloodsucking nocturnal parasite of man. This parasite is extremely resilient. The parasite can survive under water. Adults are easier to kill, while the nymphs (eggs or hatchlings) can survive up to one and a half years in extreme climates, without feeding.

Bed Bug, Cimex lectularius, usually deposits their eggs in clusters. They are fastened with cement to cracks and crevices or rough surfaces near adult harborages. The eggs hatch in 4-12 days. There are 5 nymphal stages, and it usually takes 35-48 days for nymphs to mature. Female bed bugs deposit 3 to 8 eggs at a time. A total of 200-500 eggs can be produced per female. The eggs hatch in 4-12 days. Adult bed bugs can survive for 6-7 months without a blood meal and have been known to live in abandoned houses for 1 year. Description and Habits

Bed bugs are small, brownish, flattened insects that feed solely on the blood of animals. The common bed bug, Cimex lectularius, is the species most adapted to living with humans. It has done so since ancient times.

Adult bed bug feeding on a human. (M. Potter, Univ. of Kentucky)

Characteristically these areas are marked by dark spotting and staining, which is the dried excrement of the bugs. Also present will be eggs and eggshells, molted skins of maturing nymphs, and the bugs themselves.
Dark spots of bed bug excrement on a mattress. (M. Potter, Univ. of Kentucky)

Bed bugs can live in almost any crevice or protected location. The most common place to find them is the bed. Bed bugs often hide within seams, tufts, and crevices of the mattress, box spring, bed frame and headboard.
Bed bugs often congregate along seams of mattresses and box springs. Blackish spots are excrement. (M. Potter, Univ. of Kentucky)

Nightstands and dressers should be emptied and examined inside and out, then tipped over to inspect the woodwork underneath. Oftentimes the bugs will be hiding in cracks, corners, and recesses.
Bed bugs hidden beside a recessed screw under a nightstand. (M. Potter, Univ. of Kentucky)

Upholstered chairs and sofas should be checked, especially seams, tufts, skirts, and crevices beneath cushions. Sofas can be major bed bug hotspots when used for sleeping.

Bed bugs often reside along baseboards. Photo shows eggs, nymphs, and adults beneath carpet edge. (M. Potter, Univ. of Kentucky)

Inspections and treatments must be very thorough. (M. Potter, Univ. of Kentucky)

Given these factors, the cases are not isolated. Wayne Chapdelaine, an inspector with the Halifax Regional Fire and Emergency Service, conducted the investigation of the infestation at 810 - 2327 Brunswick Street. Mr. Chapdelaine has refused to make the results of his investigation available to either myself, or the individual for whom the complaint was written. It would be hard for anyone to confirm that these cases are in fact isolated, when your department and Mr. Chapdelaines office are not making the results of his investigation known to us. Given the fact that these occurrences are not isolated, I am concerned that genuine, effective measures are not being taken by the provincial and municipal departments responsible for the regulation of the infestation to contend with the problem. 5

I am also aware that many residents within the city are experiencing the problem of Bed Bug, Cimex lectularius infestations are being improperly directed and dealt with by the provincial and municipal departments responsible for the regulation of the problem. Nor have residents of Halifax Regional Municipality been properly informed of the existence of the problem. Nova Scotia Provincial legislation recognizes the Precautionary Principle. The precautionary principle denotes a duty to prevent harm, when it is within our power to do so. This principle has been codified in several international treaties to which Canada is a signatory. Domestic law makes reference to this principle. Governments have a sworn duty to inform. It is troubling that the government bodies responsible for the regulation of this problem are failing to advise all residents of the potential risks. Subsequently, your respective departments are rendering its residents defenseless to properly contend with the problem. I might add that to date, that no protocol has been initiated by any of these government bodies responsible for the regulation of this problem. On the second part of your statement here you state that these cases are not considered a public health Hazard. Once again, I cannot concur. If you're being bitten by loathsome, disease carrying bugs, that is a health issue. I had Mr. Andrew Hebda, entomologist, and Curator of Zoology with the Nova Scotia Museum; analyze some of the parasites from the property of 810 - 2327 Brunswick Street. In his report, Mr. Hebda stated, "There were specimens found in all stages of development," Mr. Hebda wrote. "Most of the specimens you brought in had fed, so there are implications relating to health." My research has led me to some troubling facts. There are facts, which are not commonly discussed among much of the literature available on the subject. Bed Bug, Cimex lectularius, has been shown to harbor the causative organisms of plague, relapsing fever, tularemia, Q fever, and hepatitis B. Other agents found include hepatitis B. The transmission of hepatitis is possible by contamination from crushing the bug, contamination from infected feces, or from regurgitation during the bite. Transmission of trypanosomes has been demonstrated for bats. [trypanosomes - Any of various parasitic
flagellate protozoans of the genus Trypanosoma, transmitted to the vertebrate bloodstream, lymph, and spinal fluid by certain insects and often causing diseases such as sleeping sickness and nagana.]

In extreme cases where there are heavy infestations, Bed Bug, Cimex lectularius, is known to cause anemia. Iron deficiency anemia is a low red blood cell count or hemoglobin level caused by too little iron in the body. Hemoglobin is a molecule in the red blood cells that carries oxygen to cells throughout the body.

Iron deficiency anemia doesn't cause symptoms right away. The symptoms, which develop slowly over time, may include the following: dizziness or lightheadedness, fatigue and weakness, headache, irritability, less endurance in exercise, pale skin and eyes, called pallor, pica, a condition in which the person craves nonfood items such as ice, rapid heartbeat, shortness of breath, especially with exercise. Almost all problems caused by iron deficiency anemia can be reversed with treatment. However, if the anemia is severe and other health problems exist, it can lead to: confusion, congestive heart failure, a condition in which a weakened heart is unable to pump blood effectively throughout the body, a heart attack, low blood oxygen, and stroke. Those most susceptible are young children and elderly persons. In some cases hospitalization is required for treatment. Many elderly persons frequently use prescription drugs, usually painkillers for various ailments. An infestation of Bed Bug, Cimex lectularius, would most likely go undetected by many elderly persons due to the numbing effects of their medically prescribed painkillers. Most people, especially young children, would be unable to recognize this parasite. There are five nymphal stages. Only the most mature stages can be detected easily, and only by a trained eye. Before exposure to these infestations, I could not recognize these five nymphal stages. Mr. Munson could not. Could you? Bites from Bed Bug, Cimex lectularius are commonly known to also cause allergic reactions, such as skin reactions, which, depending on the individual, this may last for two months. The parasite has been implicated as carrier of disease for almost a century. Additionally, there is scientific evidence, to suggest it is a vector of disease. The parasite has been proven to be a carrier of smallpox, a disease, which causes high fever, leaves permanent marks on the skin and spreads very fast. It can be fatal. Timely treatment and precautionary measures are vital for controlling this malady. In 1905 Dr. Charles A. R. Campbell at his clinic in San Antonio, Texas clearly demonstrated that the common bedbug is a smallpox carrier. While Dr. Charles A. R. Campbell completed his findings several decades ago, they have not been disproved. Perhaps in part, due to the fact that in 1980, the World health Organization officially declared smallpox eradicated, there appeared no need to disprove Dr. Campbells findings. With the recent September 11, 2001 terrorist attacks on the United States, that reality has changed. In response to a bio terrorism threat, Health Canada's Center for Emergency Preparedness and Response has purchased more vaccines in the event of a bioterrorism attack.

(Please refer to the following website: http://www.vaccinationnews.com/DailyNews/June2002/CanadaBuySmallVaxAll.htm) If there were at least one case of small pox, the World Health Organization would have to declare an international state of emergency. They would not dismiss it as an isolated case. Over the last five years, there have even been reports that the smallpox virus has resurfaced in other countries. In 2000, eight children were hospitalized with a form of smallpox after playing with discarded vaccine vials they found in a Vladivostok garbage bin, in Russia. In June 2002 there was a Smallpox scare in SWABI, Pakistan. Should an outbreak of this parasite (Bed Bug, Cimex lectularius) happen in conjunction with a smallpox threat, the ability to control the problem might be seriously hindered. While the smallpox virus is extremely contagious in and of itself, if the (Bed Bug, Cimex lectularius parasite were to bite a person infected with the smallpox virus, it would be difficult to track the parasite for containment. The 9/11 attacks on the United States should be a painful reminder of what happens in cases of Government unpreparedness. These are health concerns. While they may appear not to be an imminent threat at present, they are clearly valid. I have scientific and medical evidence to support these findings. I draw your attention once again to the precautionary principle. Nova Scotia Provincial legislation recognizes the Precautionary Principle. The precautionary principle denotes a duty to prevent harm, when it is within our power to do so. The precautionary principle calls on all parties to act in a shared role of responsibility. In Mr. Munsons case, for example, he has lost all of his property due to the degree of infestation and the high risk of further spread of the parasite. Additionally, Mr. Munson has endured adverse effects to his health and incurred expense for relocation and ongoing legal expenses. Furthermore, the parasites are now in my place of residence. I too must contend now with the expense and adverse effects of this parasite. The damages to health and property as noted above are very real. Those damages will be have to be resolved with civil remedies involving property owners, tenants and government. I am concerned that failure to properly contain the parasitic problem may only serve to fuel significant future expenditures for civil disputes between property owners, tenants and government. Thus, it would appear to be in everyones best interest to take more aggressive steps to eradicate the problem this parasite presents.

You further write, for the present time, the dispute will need to be settled by the two parties and may require some input from the Nova Scotia Tenancy Board. I reject that view. I have clearly validated that your department and those who share in that role of regulating this problem are liable. For your information, I hold Power of Attorney for Mr. Munson. I enclose a copy of that Power of Attorney for your file. It has been established, that prior to the parasitic outbreak at Mr. Munsons former place of residence, that your department, and those who share in that role of regulation, knew of the parasitic problem in other locations on the property, as well as other locations within the Municipality. What steps your departments and those who share in that role of regulating this problem took, is yet to be decided. Your departments, and those who share in that role of regulating this problem, have not provided any reasonable proof to validate your assertions. In respect to the Nova Scotia Tenancy Board, it is not the appropriate body to be hearing this case. The Nova Scotia Tenancy Board possesses neither the breadth of experience, nor the authority to contend with the conflicting matters in this case. Neither does the Small Claims Court Division. Mr. Munsons damages exceed the compensation levels allotted at these two levels of adjudication. This case belongs more appropriately in the Nova Scotia Provincial Court Level. It is in the publics best interest that this case be tried at the proper level of court and be placed on official record.
In the interim, I call on your departments and those who share in that role of regulating this

problem, to establish protocols to begin combating the problem that has now spread to four areas within the Municipality. I recommend the following:
1. Establish and agree on up to date, accurate educational material on the subject of this parasite in order that such material can be circulated to the general public, landlordtenant locations, and moreover, afflicted parties. Educational material should include: Contact information for personnel, which can be contacted in the event of discovery of the parasite or an infestation. Information on what steps afflicted parties can take for themselves in the event of discovering the parasite or infestation thereof. Up to date, accurate educational material on the subject of this parasite, which will include balanced appraisals of the adverse effects to health and property of afflicted parties. An up to date list of reputable pest control services along with all relevant contact information Educational material on what chemicals can be used in extermination processes with a necessary legal disclaimer, notifying residents that extermination processes should be left to professionally trained and reputable pest control personnel.

This material should also include what afflicted parties are required to do in preparation for the extermination process. Additionally that afflicted parties should be relocated for a time period to allow required time for the process of extermination and containment. 2. Establish a non-partisan group comprised of delegates from each of the levels of government who have a shared role to contend with the regulation of this and similar problems. This should include clear, established roles for each government party and levels involved in the process. 3. Establish a monitoring program, which will maintain a watchful eye on the spread of the parasite respecting any unsafe levels, locally, nationally and internationally. 4. Find an effective chemical, which will exterminate the parasite more effectively. At this point it seems evident this may be one of the challenges in the role of containment. One example of what does exterminate these parasites is a commonly used flea shampoo. 5. Establish an annual report on the sightings of this and other parasites, and in the event of outbreaks, monthly reports, which will be made available to the general public free of charge. It is important to note that discretion should be exercised on specific locations so as not to hinder the relocation of afflicted parties. 6. Establish a quarantine program to assist afflicted parties in exterminating parasitic infestations to ensure afflicted parties do not inadvertently spread the parasitic problem to new locations. This should also include maintaining a list of infected locations on file. 7. Require all Landlord and property management owners where parasitic discoveries are found to inform all tenants or residents on tenancy properties, about the parasite problem. Additionally, all Landlord and property management owners where parasitic discoveries are found provide all tenants thereof with all relevant educational material on the subject. This information must be provided all tenants on the property, whether their units are infested or not. 8. Require all Landlord and property management owners where parasites are found to incur the cost of relocation of tenants for extermination processes. 9. Require that where there are repeated infestations that the given property be evacuated until health authorities have deemed no further risk for occupancy. 10. Where parasite infestations are found, Landlords or property management shall not be entitled to rent or lease to any new parties until health authorities have deemed that there is no further risk to future occupancy. 11. Establish Health personnel to officially declare infestation a health risk in order that tenants and landlords be empowered to justify damages resulting from infestation through insurance policies, etc. And those parties are placed on notice to take immediate action. 12. Seek the general publics input on the problem, i.e. concerns, recommendations for extermination, etc.

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13. Establish clear legislation, which will incorporate all of the above noted recommendations. I trust that your departments and those who share in that role of regulating this problem will act accordingly to combat this parasitic infestation before the outbreak reaches epidemic levels.

With every best wish,

________________________

Roch Longuepe
The contents of this letter may be subject to solicitor/client confidentiality intended only for the use of the person(s), firm, or agency named above. If you are not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication and any attachments is strictly prohibited. If you have received this communication in error, kindly notify the above via email or phone.

cc:

Honorable Kerry Morash Honourable Angus MacIsaac Honorable Mayor Peter Kelly Dawn Sloane, Councilor, HRM Sheila Fougere, Councilor, HRM Janice Gammie Danny Graham, MLA Howard Epstien, MLA Maureen Macdonald, MLA Jerry Pye, MLA

Dr. Jeff Scott, Provincial M.O. of Health Dr. Robert Strang, M. O. of Health Mr. Robert J. Munson

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