UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

MEMORANDUM 

Date: November 24, 2015 

SUBJECT: Rodenticide: Tier I (Scoping) Review of Human Incidents and Epidemiology 

Assessment 

PC Code: 112701 , 112001 , 112802. 119901 , 128967, 

067701 , 067705, 067707.086002. 086003, 08860 1, 20290 1 

Decision No.: 502964, 502942 

Petition No.: NA 

Risk Assessment Type: NA 

TXR No.: NA 

MRID No.: NA 

DP Barcode: 0426573, 0426554 

Registration No.: NA 

Regulatory Action: NA 

Case No.: NA 

CASNo.:NA 

40 CfR: NA 

FROM: Shanna Recore, Industrial Hygienist 

Elizabeth Evans, Environmental Protection Specialist 

Toxicology and Epidemiology Branch 

Health Effect Division (7509P) 

Ver.Apr.OS 

David J. Miller, Acting Chief ]~1 1ft:\ ~-v?- Toxicology and Epidemiology Branch ,,. j;//J; 

Health Effects Division (7509P) .'I ' . ' /jffel ,,Jl,l/Aw-UJ<S 

THROUGH: 

TO: Matthew Crowley, Risk Assessor 

Risk Assessment Branch JI 

Health Effects Division (7509P) 

and 

Christopher Schlosser, Risk Assessor 

Risk Assessment Branch VI 

Health Effects Division (7509P) 

and 

Caitlyn Newcamp, Chemical Review Manager 

Risk Management & Implementation Branch I 

Pesticide Re-evaluation Division (7508P) 

Page 1 of 15 
Summary and Conclusions 

In order to minimize children and wildlife exposure to rodenticide products the 2008 RMD 

included risk mitigation measures requiring rodenticide products used in homes and marketed to 

general residential consumers be sold only with bait stations. Most rodenticide products 

complied with the mitigation measures required in the RMD as of June 4, 20 11. The phase out 

production of the final 12 non-compliant products began in June 2014 and production of these 

products stopped on December 31, 2014. Distribution to retailers ended March 31, 2015. 

Due to the fact that these safety measures were only recently fully implemented, there is 

insufficient information available, at the time of this report, to determine if the mitigations have 

impacted the frequency of incidents occurring. However; AAPCC data is reviewed arurnally for 

reduction in reported rodenticide incidents as a Strategic Measure. For FY 2014 (using the CY 

2013 AAPCC annual report data), there was a reduction of 17% incidents reported to the 

AAPCC annual reports compared to the number of rodenticide exposures to children ages 1 to 6 

years old in 2011 . The reductions in child exposures are expected to become more prominent 

beginning in the 2016 AAPCC annual report; which will be reflected in the FY 2018 Strategic 

Measure. The target reduction for FY 2018 is to reduce rodentic ide exposure incidents by 75% 

compared to a baseline measure of 11,674 reported incidents in 2008 in children ages l to 6 

years old. 

The Agency will continue to monitor the incident information and provide an updated review of 

incident, considering pre- and post-mitigation incidents separately, when the infonnation 

becomes available. 

Detailed Review 

I. ACTION REQUESTED 

This review is intended to fulfill our requirement to docket summaries of incident data that were 

reported to the Agency, as well as to ensure human incident data and the Agricultural Health 

Study (AHS) are part of the problem formu lation phase of registration review. Repo11s of 

adverse health effects allegedly due to a specific pesticide exposure (i.e., an " incident") are 

largely self-reported and therefore, generally speaking, neither exposure to a pesticide or 

reported symptom (or the corrnection between the two) is validated or otherwise confirmed. 

Typically, causation cannot be determined based on incident data. However, incident 

information can be an important source of feedback to the Agency: incidents of severe outcome, 

or a suggested pattern or trend among less severe incidents, can signal the Agency to further 

investigate a particular chemical or product. Observational epidemiology studies relate the risk 

of disease, e.g., cancer, and exposure to an agent such as a pesticide product in the general 

population or specific sub-groups like pesticide applicators. 

II. BACKGROUND 

Page 2of15 
In the U.S., rodenticides are registered for use by the Environmental Protection Agency's (EPA 

or Agency) Office of Pesticide Programs (OPP or Office) for use agai nst pest rodents (e.g., rats, 

mice, gophers, etc.) associated with a variety of use sites (e.g., agricultural fields, restaurants, 

homes, etc.). Rodenti cides were reviewed under OPP's Reregistration program in the 1990s. As 

a result of these reviews, potential risks from rodenticide agricultural fi eld uses and residential 

tracking powder products were successfully mitigated via classification as restricted use 

pesticides (RUP; the one exception was manual underground baiting products for use in 

agricultural fields, which did not necessitate an RUP classification). Additionally, rodenticides 

employed to preserve native plant and animal species on islands were determined to be 

appropriately managed by the U.S. Fish and Wildlife Service, rendering mitigation unnecessary. 

The path forward to mitigate risk (which included children and wildlife exposure to rodentieide 

products) from the remaining rodenticide use pattern (rodentieides formulated as baits/pellets 

used agai nst commensal rodents 1 in residential-type settings) resulted in the Rodenticide 

Stakeholder Workgroup (RSW), a subcommittee under the federally-chartered advisory body, 

the Pesticide Program Dia logue Committee (PPDC). The RSW issued recommendations, and 

helped inform the Agency's 2008 Risk Mitigation Decision for Ten Rodentic ides (RMD). Under 

the terms of the 2008 RMD, products marketed to the general non-professional user or 

homeowner as well as those applied by professional applicators were to be modified to adopt a 

variety of mitigation measure to continue to meet the FIFRA standard. These risk mitigation 

measures included requiring rodenticide products used in homes or marketed to general 

residentia l consumers be used in bait stations. The RMD also required the second-generation 

anticoagulant class of rodenti cides to be sold in a way to limit sales to general residential 

consumers. The RMD provided registrants until June 4, 20 11 to comply with the mitigation 

measures. However, as of June 4, 20 11 not all rodenticide products compli ed with the RMD 

requirements. On January 29, 2013, the Agency issued a Notice of Intent to Cancel (NOIC) for 

the remaining 12 non-compliant products2 manufactured by Reckitt Benckiser that did not meet 

the Agency's current safety standards. In May 2014, EPA reached an agreement with Reckitt 

Benckiser to begin phase out production of the 12 d-CON non-compliant products in June 2014, 

and stop all production by December 31 , 20 14. In March 31, 20 15, Reckitt ceased distribution of 

existing stocks of these products. 

An analysis of human incidents involving exposure to commensal rodenticides was conducted 

previously in 2011 (S. Recore, I 0/28/20 11 , 0 395567) in support of the Rodenticide Risk 

Mitigation Decision (RMD), and the subsequent Notice of Intent to Cancel (NOIC). It was 

concluded that 

"When looking across human incident data sources, as well as the open literature, 

rodenticides arc found to be involved in numerous incidents, especially involving 

children less than 6 years old. These exposures to children are espec ially evident in the 

anal ysis of the /\APCC data which showed an average of 15,000 exposures per year 

1 Commcnsal rodents arc rodents that live in close association with humans and depend upon them for shelter and/or for some of 

their sustenance. In the continental U.S .. the term commcnsal rodents includes Norway rats (Rau11s 11orvegic11s), roof rats (Rauus 

ra1t11s). and house mice (Mus 11111sc11/11s). 

2 Registration Numbers: 3282-3, 3282-4, 3282-9. 3282-15. 3282-65, 3282-66, 3282-74, 3282-81, 3282-85, 3282-86, 

3282-87, and 3282-88 

Page 3 of 15 
occur to children under 6 years old from 1999 to 2009. While exposures generally result 

in no clinical harm to children, the resulting human exposures to rodenticides have the 

potential to result in severe outcomes and/or medical care." 

"Subsequently, it fo llows that the RMD proposal (containing rodenticides in bait stations 

that are tamper-resistant) may mitigate child incidents involving rodenticides." 

For this evaluation, both the OPP Incident Data System (IDS) and the Centers for Disease 

Control and Prevention/National Institute for Occupational Safety and Health (CDC/NIOSH) 

Sentinel Event Notification System for Occupational Risk-Pesticides (SENSOR) databases were 

consulted for pesticide incident data for the commensal rodenticides. These rodenticides are not 

included in the AHS, and therefore this study does not provide information for this report. They 

can be grouped according to three main categories: first-generation anticoagulants3, secondgeneration anticoagulants4 and non-anticoagulants.

5 They are classified as fo llows: 

• First-generation anticoagulant 

o chlorophacinone (PC code 067707) 

o diphacinone (PC code 06770 I) 

o diphacinone sodium salt (PC code 067705) 

o warfarin (PC code 086002) 

o warfarin sodium salt (PC code 086003) 

• Second-generation anticoagulant 

o brodifacoum (PC code 11 2701) 

o bromadiolone (PC code 11200 I) 

o difenacoum (PC code 11 990 I) 

o difethialone (PC code 128967) 

• Non-anticoagulant 

o bromethalin (PC code 11 2802) 

o cholecalciferol (PC code 20290 I) 

o z inc phosphide (PC code 08860 I) 

The purpose of the database search is to identify potential patterns in the frequency and severity 

of the health effects attributed to commensal rodenticide exposure. 

III. RESUL TS!DISCUSSION 

a. IDS (Incident Data System) 

3 First-generation anti-coagulants rodenticides disrupt the production in the liver of vitamin K dependent bloodclotting factors II (prothrornbin), VII, IX, and X. 

•

1 The second-generation anticoagulants rodenticides. like the first generation anticoagulants, block the formation of 

the active form of vitamin K, which in tum inhibits the production of coagulation fac tors in the liver. These are more 

acutely toxic than first generation agents and can cause lethal effects to rodents in a single dose. 

5The non-anticoagulants rodcnticides work in a variety of ways and no single common mechanism exists. 

Page 4 of 15 
OPP's IDS includes reports of alleged human health incidents from various sources, including 

mandatory federal Insecticide, Fungicide and Rodenticide Act (flFRA) Section 6(a)(2) reports 

from registrants, other federal and state health and environmental agencies, and individual 

consumers. Since 1992, OPP has compiled these reports in IDS. IDS contains reports from 

across the U.S. and most incidents have all relevant product information recorded. Reports 

submined to the IDS represent anecdotal reports or allegations only, unless otherwise stated in 

the report. 

IDS records incidents in one of nvo modules: Main IDS and Aggregate IDS: 

o Main IDS contains incidents resulting in higher severity outcomes and provides 

more detail with regard to case specifics. This system stores incident data for 

death, major and moderate incidents, and it includes information about the 

location, date and nature of the incident. Main IDS incidents involving only one 

active ingredient (as opposed to pesticide products with multiple active 

ingredients) are considered to provide more certain infonnation about the 

potentia l effects of exposure from the pesticide. 

o Aggregate IDS contains incidents resulting in less severe human incidents (minor, 

unknown, or no effects outcomes). These are reported by registrants only as 

counts in what are aggregate summaries. 

FIRST-GENERATION ANTICOAGULANTS 

Chlorophac inonc: 

For the Main IDS, from January 1, 20 l 0 to May 27, 20 I 5, there was 1 incident reported for 

chlorophacinone in the database. This incident involved an adult female suicide attempt and was 

classi fted as moderate severity. 

In Aggregate IDS, from January 1, 2010 to May 27, 2015, there was l incident reported 

involving chlorophacinone. This incident was classified as having no or unknown effects. 

Overall, there are few incidents reported to IDS involving chlorophaci none. 

Diphacinone and salts: 

For the Main IDS, from January 1, 2010 to May 27, 2015, there were 27 incidents reported for 

the single chemical diphacinone or its salts in the database. One of these incidents was classified 

as major severity and 26 of these incidents were classified as moderate severity. There were four 

additional incidents reported involving more than one chemical (including diphacinone or its 

salts). Two of these incidents were classified as moderate severity. One incident was a death that 

was the result of a suicide and the other incident was classified as major severity that was the 

result of a sui cide attempt. 

In Aggregate IDS, from January 1, 20 10 to May 27, 20 15, there were 94 incidents reported 

involving diphacinone and salts. These incidents were classified as minor severity. 

Page S of IS 
Warfarin and its Na Salts: 

For the Main IDS, from January I, 20 I 0 to May 27, 20 15, there were no incidents reported for 

the single chemical warfarin and its sodium salts in the database. There was one incident 

reported involving more than one chemical (including warfarin and its sodium salts) and was 

classified as moderate severity. 

In Aggregate IDS, from January 1, 20 I 0 to May 27, 20 15, there was l incident reported 

involving warfarin and its sodium salts. This incident was classified as minor severity. Overall, 

there are few incidents reported to IDS involving warfarin and its sodium salts. 

SECOND-GENERA Tl ON ANTICOAGULANT 

Brodifacoum 

For the Main IDS, from January l, 2010 to May 27, 2015, there were 46 incidents reported for 

the single chemical brodifacoum in the database. For1y one of these incidents were classified as 

a moderate severity and five of these incidents were classified as major severity. Incident 

description for the incidents classified as major severity are provided in Appendix 1. There were 

three additional incidents reported involving more than one chemical besides brodifacoum. 

In Aggregate IDS, from January 1, 2010 to May 27, 20 15, there 25 1 incidents reported involving 

brodifacoum. One incident was classified as having no or unknown effects and 250 incidents 

were classified as minor severity. 

Bromadiolone 

For the Main IDS, from January 1, 2010 to May 27, 2015, there were 12 incidents reported for 

the single chemical bromadiolone in the database. Eleven of these incidents were classified as 

moderate severity and one of these incidents was c lassified as major severity. An incident 

description for the incident classified as major severity is provided in Appendix 1. There was 

one additional incident reported involving more than one chemical besides bromadiolone. 

In Aggregate IDS, from January 1, 2010 to May 27, 20 I 5, there 171 incidents reported involving 

brornadiolone. Fifty two incidents were classified as having no or unknown effects and 11 9 

i~1cid nt s were classified as minor severity. 

Difenacoum 

For the Main IDS, from January 1, 20 l 0 to May 27, 20 15, there were no incidents reported 

involving difenacoum. 

In Aggregate IDS, from January 1, 2010 to May 27, 20 15, there was one incident reported 

involving difenacoum. The incident was classified as having no or unknown effects. Overall, 

there are few incidents reported to IDS involving difenacoum. 

Page 6 of 15 
Di fethialone 

For the Main IDS, from January I, 2010 to May 27, 2015, there was one incident reported for the 

single chemical difethialone in the database. This incident was classified as moderate severity. 

There were no additional incident reported involving more than one chemical besides 

difethialone. 

In Aggregate IDS, from January 1, 2010 to May 27, 20 15, there were 21 incidents reported 

involving difethialone. Nine incidents were classified as having no or unknown effects and 12 

incidents were classified as minor severity. Overall, there are few incidents reported to IDS 

involving difethialone. 

NON-ANTICOAGULANTS 

Bromethalin 

For the Main IDS, from January I, 2010 to May 27, 2015, there were 16 incidents reported for 

the single chemical bromethalin in the database. There was one death reported to IDS 

associated with bromethalin, but upon further review, it does not appear to be related to 

bromethalin exposure. An approximately 35 year old man was found dead in bed who may have 

had a history of depression. When found, he was "foaming at the mouth with an orange colored 

sputum." A box of bromethalin was found in a cabinet in his room, but there was no evidence he 

consumed it. The medical examiner ruled this as a suspected heart attack. One incident was 

classified as major severity, 13 incidents were classified as moderate severity and one incident 

had no or unknown effects. There was one additional incident reported involving more than one 

chemical besides bromethalin. 

In Aggregate IDS, from January 1, 20 10 to May 27, 2015, there were 160 incidents reported 

involving bromethalin. Two incidents were classified as having no or unknown effects and 158 

incidents were classified as minor severity. Overall, there are few incidents reported to IDS 

involving bromethalin. 

Cholecalciferol 

For the Main IDS, from January l , 20 l 0 to May 27, 2015, there were no incidents reported 

involving choleealcifcrol. 

In Aggregate IDS, from January I, 2010 to May 27, 20 15, there was one incident reported 

involving cholecalciferol. The incident was classified as minor severity. Overall, there are few 

incidents reported to IDS involving cholecalciferol. 

Zinc Phosphide 

For the Main IDS, from January l , 2010 to May 27, 2015, there were 7 incidents reported for the 

single chemical zinc phosphide in the database. These incidents were classified as moderate 

Page 7 of 15 
severity. There were two additional incidents reported involving more than one chemical besides 

zinc phosphide. 

In Aggregate IDS, from January 1, 2010 to May 27, 2015, there were 20 incidents repor1ed 

involving zinc phosphide. One incidents were classified as having no or unknown effects and 19 

incidents were classified as minor severity. Overall, there are few incidents reported to IDS 

involving zinc phosphide. 

b. SENSOR-Pesticides 

The SENSOR-Pesticides database covers 12 states from 1998-2011 , although reporting varies 

from state to state. Cases of pesticide-related illnesses are ascertained from a variety of sources, 

including: repor1s from local Poison Control Centers, state Department of Labor workers' 

compensation claims when reported by physicians, reports from State Departments of 

Agriculture, and physician reports to state Departments of Health. Although both occupational 

and non-occupational incidents are included in the database, SENSOR-Pesticides focuses on 

occupational pesticide incidents, and is of particular value in providing that infonnation. The 

state coordinator at each of the 12 respective state Departments of Health conducts case followup activities such as obtaining medical records to verify symptoms and severity. Using 

standardized protocol and case definitions derived from poison center reporting, the state 

SENSOR-Pesticide coordinator enters the incident information into the state-based system which 

is sent to NIOSH annually to be aggregated. 

In 2009, SENSOR-Pesticides began requiring prevention coding for cases that had an 

identifiable contributing factors, such as: earl y re-entry, PPE not worn, spill/splash, equipment 

failure, improper storage, drift, etc. The new prevention codes will allow for more focused 

incident review and analysis by contributing factor within the database. 

FIRST-GENERATION ANTICOAGULANTS 

Chlorophacinone: 

A query of SENSOR-Pesticides from 1998-2011 , identifies 12 cases involving chlorophacinone. 

Of these, nine cases involve a single ai which will be reviewed for this memorandum. One case 

was moderate severity and eight cases were low severity. Eight of the nine cases involved 

inhalation of the product "dust. " 

The moderate severity case occurred after an insulation worker was working in a school attic. 

The insulation work was generating dust in the attic. That evening the case experienced 

shakiness, fever and vomiting but felt better afler a few hours. The case experienced 

respiratory, neurological, gastrointestinal, renal, and cardiovascular symptoms following 

exposure. "Rat pellets" were found throughout the attic and the school, but the workers were not 

notified of this. 

Page 8of15 
Eight cases experienced respiratory symptoms after exposure, and eight cases experienced 

neurological symptoms after exposure. Five cases experienced gastrointestinal symptoms. Eight 

cases were occupational and one case was a homeowner. The homeowner case occurred when 

the user opened a can of gopher bait and accidentally inhaled it, experienced shortness of breath 

and coughing and called Poison Control. 

Oiphacinone and salts: 

A query of SENSOR-Pesticides from 1998-2011, identifies 11 cases involving diphacinone. 

Seven of these cases involved a single active ingredient and were reviewed for this 

memorandum. These cases included one fatal case, one moderate severity case and five low 

severity cases. One low severity case was intentional ingestion for self-harm. The remaining six 

cases were unintentional. Four cases reported gastrointestinal symptoms. Three cases were 

handling the product at the time of exposure. Two cases were exposed while cleaning up 

product spills. One case was exposed via intentional ingestion, and the fatal case was exposed 

from dust applied to the air vent at his place of work and is reviewed in detail below. 

The fatality occurred in Florida in 2002. This fatal case was a 35-year old man who was exposed 

to Ditrac Powder, EPA Reg. # 12455-56, a Restricted Use Product that was appli ed by a certified 

pesticide applicator. This exposure occurred as the man opened a tire shop that, unbeknownst to 

him, had its a ir conditioning vents recently treated with Ditrac powder and the dust from vents 

blew into his face. He immediately became ill and was hospitalized for an infiltrate in the right 

lower lung. Later, this case had to be re-admit1ed to the hospital because of an acute episode of 

an upper gastrointestinal bleed. Doctors treaced for circulatory shock but eventually neither 

medications nor surgical interventions could be utilized to control bleeding and the patient died 

one month after the inhalation exposure. The autopsy report confim1ed severe gastrointestinal 

bleeding. Review of the tire shop demonstrated that no application, storage, or equipment 

violations had occurred. 

Warfarin and its Na Salts: 

A query of SENSOR-Pesticides from 1998-2011 , identifies 35 cases involving warfarin and its 

sodium salt. Thirty four of these cases involved a single active ingredient and were reviewed for 

this memorandum. Of these 34 cases, five cases were high severity, 14 cases were moderate 

severity and 15 cases were low severity. Eight cases were work-related, 26 cases were not workrelated, and 22 cases were exposed in a private residence. Of the five high severity cases, three 

cases were intentional self-harm ingestions. Of the two unintentional high severity cases, both 

were ingestions; one involved a 4 year old ingestion of product and one involved an 82 year old 

ingestion of product. 

SECOND-GENERATION ANTICOAGULANT 

Brodifacoum 

Page 9 of 15 
A query of SENSOR-Pesticides from 1998-2011, identifies a total of 52 cases involving 

brodifacoum. Forty six of these cases involved a single active ingredient. fifteen of these cases 

were intentional ingestions for self-harm. The remaining 31 unintentional cases were reviewed 

for this memorandum. Nine cases were moderate severity and 22 were low severity. Nineteen 

cases were ingestions, including 13 cases involving children under six years old. Since 2009 (the 

year in which the SENSOR prevention code was required) all child cases are coded for 

" improper storage of pesticide." Of the nine moderate severity cases, seven were ingestions and 

two were via inhalation. 

Nine cases (including three occupational and six residential cases) were made ill from inhalation 

of the product under various case-specific scenarios including: five cases that had accidental 

contact with product or residue and four cases were made ill while applying the product. The 

remaining three cases were exposed via the dermal or ocular routes. Fifteen cases reported 

gastrointestinal symptoms including abdomina l pain, vomiting and diarrhea; followed by ten 

cases reporting respiratory symptoms including cough and upper respiratory pain and e ight cases 

reported neurological symptoms. Four cases reported cardiovascular symptoms including heart 

palpitations and chest pain (Table 1 ). 

Table 1. SENSOR-Pesticides 1998-2011 

Brodifacoum Case Health Effects 

N=3 1 

Body System Count of Cases 

Gastrointestinal 15 

Respiratory 10 

Neurological 8 

Ocular 5 

Cardiovascular 4 

Dermal 4 

Bromadiolone 

A query of SENSOR-Pesticides from 1998-201 1, identifies a total of 15 cases involving 

bromadiolone. Of these, ten cases involve a single active ingredient and were reviewed for this 

memorandum. One case was high severity, two cases were moderate severity and seven cases 

were low severity. Four cases were intentional ingestion for self-harm. These four intentional 

cases include the high severity case and both moderate severity cases as well as one low severity 

case. 

Of the remaining six unintentional cases, all are low severity. One case opened a bag of 

rodenticide and powder blew into his face and eye. Another case was working at a cash register 

and she inhaled product from the opened bag of rodenticide. Another case got a piece of the 

product in his eye. One case was exposed when he entered a building that was being treated. 

One case was sickened after bait was applied in his home. The final case did not have case 

narrative information. Three of these six reported ocular symptoms including eye pain and 

conjunctivitis, three reported respiratory symptoms including upper respiratory pain, two 

reported neurological symptoms and one reported gastrointestinal symptoms. 

Page 10 of 15 
Difenacoum 

A query of SENSOR-Pesticides from 1998-20 11 , identified no cases involving difenacoum. 

Di fethialone 

A query of SENSOR-Pesticides from 1998-201 I, identifies a total of four cases involving 

difethia lone, all of which are single ai cases involving only difethialone. All four cases were 

exposed via ingestion. One case was high severity, two cases were moderate severity and one 

case was low severity. 

Three cases, inc luding the high severity case, one moderate severity and the low severity case, 

were intentional ingestions for self-harm. The remaining case was an infant (9 months old) who 

accidentally ingested "a significant amount of 0-con Rat & Mouse Bait Blocks" and experienced 

nausea and vomiting (c lassified as moderate severity). 

NON-ANTICOAGULANTS 

Bromethalin 

A query of SENSOR-Pesticides from 1998-20 11 , identifies a total of eight cases involving 

bromethalin; seven cases involved only bromethalin. All cases were residentia l. Three cases 

involved ingestion of product, including one infant case and two adult cases. Of these adult 

ingestion cases, one was an intentional self-harm attempt and the other was a suspicious possible 

self-harm attempt. The suspicious ingestion case was moderate severity. All other cases (n=6) 

were low severity. 

Two cases involved product spills. One case involved a warehouse worker who applied product 

and did not wash hands afterwards and was exposed while drinking water and touching her face. 

Three cases reported dermal symptoms including edema and rash), three cases reported 

neurological symptoms inc luding slurred speech, two cases reported ocular symptoms, two cases 

reported gastrointestinal symptoms, and one case reported respiratory symptoms. 

Cholecalciferol 

A query of SENSOR-Pesticides from 1998-20 11 , identified no cases involving cholecalciferol. 

Zinc Phosphide 

A query of SENSOR-Pesticides from 1998-2011 , identifies a total of 25 cases involving z inc 

phosphide; 23 of which involved only zinc phosphide and were reviewed for this memorandum. 

These 23 single ai cases stem from 15 events. One case was high severity, two cases were 

moderate severity and twenty cases were low severity. The high severity cases involved an 

intentional ingestion for self-harm. 

Regarding the 20 low severity cases: in 11 cases veterinarians (n=4) or pet owners (n=7) exposed 

while treating dogs that had ingested product (primaril y phosphine gas pellets or "peanuts"). 

Page J l of 15 
Four cases were exposed following extenninator applications. Two cases were applying product 

and exposed. One case was a child who "got into rat poison powder in a dish on the floor." Two 

cases did not have case descriptions. All of these cases were low severity and symptoms were 

commonly dizziness, headache, and shortness of breath, nausea, and chest tightness. 

Regarding the moderate severity cases, one involved a man in a grocery store who was 

accidentally exposed to rodenticide fumes. This case experienced chest tightness, difficulty 

swallowing and nasal irritation. The second moderate severity case apparently involved the 

accidental ingestion of product Moletox 2. This case experienced chest pain, lacrimation, 

coughing, and loss of appetite. 

c. American Association of Poison Control Centers (AAPCC) 

The American Association of Poison Control Centers (AAPCC) is a non-profit, national 

organization founded in 1958 that represents the poison control centers of the United States and 

the interests of poison prevention and treatment of poisoning. All of the calls to a poison control 

center are managed by a medical professional trained to answer questions about poisons. The 

American Association of Poison Control Centers (AAPCC) produces an annual summary report 

giving statistics and information on all the poisonings reported to PCCs in a calendar year. 

Although AAPCC data was reviewed by HED for the 20 I I human incidents report (0395567) 

analyzing exposure to commensal rodenticides, it is not being reviewed for this incident analysis. 

At the time of this report there is insufficient information available to determine if the 

mitigations have impacted the frequency of incidents occurring. The most current AAPCC 

annua l report available is for year 2013 and the phase out of the remaining non-compliant 

products began in June 2014 and was complete as of March 31, 2015. 

However, AAPCC data is reviewed annually for reduction in reported rodenticide incidents as an 

EPA Strategic Measure. For FY 2014 (using the 2013 AAPCC annual report data), there was a 

reduction of 17% incidents reported to the AAPCC annual reports compared to the number of 

rodenticide exposures to children ages l to 6 years old in 2011. The reductions in child 

exposures are expected to become more prominent beginning in the 2016 AAPCC annual report; 

which will be reflected in the FY 2018 Strategic Measure. The target reduction for FY 2018 is to 

reduced rodenticide exposure incidents by 75% from the baseline of 11 ,674 reported incidents in 

children ages I to 6 years old. 

d. Agricultural Health Study (AHS) 

The AHS is a high quality, prospective epidemiology study evaluating the link between pesticide 

use and various health outcomes including cancer. The AHS includes private and commercial 

pesticide applicators and their spouses. If there are Al-IS findings relevant to a particular 

pesticide going through registration review, the Agency will ensure they are considered in the 

problem formulation/scoping phase of the process and, if appropriate, fully reviewed in the risk 

assessment phase of the process. The AHS includes infonnation on use of 80 different pesticide 

active ingredients commonly used in agriculture. The commensal rodenticides are not included 

in the AHS, and therefore this study does not provide information for this report. 

Page 12 of 15 
IV. CONCLUSION 

In order to minimize children and wildlife exposure to rodenticide products the 2008 RMD 

included risk mitigation measures requiring rodenticide products used in homes and marketed to 

general residential consumers be sold only with bait stations. Most rodenticide products 

complied with the mitigation measures required in the RMD as of June 4, 2011. The phase out 

production of the final 12 non-compliant products began in June 20 14 and production of these 

products stopped on December 31, 2014. Distribution to retailers ended March 31, 2015. 

Due to the fact that these safety measures were only recently fully implemented, there is 

insufficient information available, at the time of this report, to determine if the mitigations have 

impacted the frequency of incidents occurring. However; AAPCC data is reviewed annually for 

reduction in reported rodenticide incidents as a Strategic Measure. For FY 2014 (using the 2013 

AAPCC annual report data), there was a reduction of 17% incidents reported to the AAPCC 

annual reports compared to the number of rodenticide exposures to children ages I to 6 years old 

in 2011. The reductions in child exposures are expected to become more prominent beginning in 

the 2016 AAPCC annual report; which \viii be renected in the FY 2018 Strategic Measure. The 

target reduction for FY 20 18 is to reduce rodenticide exposure incidents by 75% compared to a 

baseline measure of I 1,674 reported incidents in 2008 in children ages 1 to 6 years old. 

The Agency will continue to monitor the incident information and provide an updated review of 

incident, considering pre- and post-mitigation incidents separately, when the information 

becomes available. 

Page 13 of 15 
Appendix A. 

Commensal - - - - - - - - --- Rodenticide - - - - - - --- - Death - and Ma - - ior S - ·!Y Incident R d to IDS fo 2010 to Mav 27. 2015 . Incident 

Package Jncidcnt Reg Ingredient Exposure 

Report Date Location Number Product Name Name Severity Incident Description 

021982 - 003282- D-CON MOUSE 

00005 5/ 10/2010 CA 00065 PRUFE II Brodifacoum Major A 23 year old male suicide artempt 

025040 - D-CON 

00011 1/4/2013 CA BROD IF ACOUM Brodifacoum Major A 45 year old male suicide anempt. 

027024 - 003282- D-CON MOUSE 

00003 811 /2014 LA 00065 PRUFE II Brodifacoum Major An adult female suicide anempt. 

027333 - LOS ANGELES, 003282- D-CON MOUSE 

00012 31212012 CA 00065 PRUFE II Brodifacoum Major A 62 year old male suicide attempt 

A 53 year old male was drunk and 

taken to the ER. The police 

suspected that he ate some of the 

product just because it was around 

his home. He was taken to one 

hospital and upon ER admission 

where his blood pressure was 87/50 

and his heart rate was I 08. He was 

then transported to another hospital 

and he was placed in the cardiac 

027563 - 003282- D-CON BAIT unit. He was discharged 4 days 

0000 1 217/20 15 FRITCH, TX 00066 PELLETS Brodifacoum Major later. 

Seven children, ages 10 through 12, 

were hospitalized after coming into 

contact with rat poison they mistook 

for candy. A student found the rat 

poison on top of a high filing 

cabinet in the classroom and shared 

it with classmates. One of the 

students who was exposed 

contacted her father who called 

022579 - 911.The chemical in the rat poison 

00010 1/ 13/20 11 CA BROMADIOLONE Bromadiolone Major was bromadiolone, a blood thinner. 

Page 14of 15 
Incident 

Package Incident Reg Ingredient Exposure 

Report Date Location Number Product Name Name Severity Incident Description 

An approximately 35 year old man 

was found dead in bed who may 

have had a history of depression. 

When found, he was "foaming at 

the mouth with an orange colored 

sputum." A box ofbromethalin was 

found in a cabinet in his room, but 

012455- there was no evidence he consumed 

025024 - 00120- TOMCAT MOUSE it. The medical examiner ruled this 

0000 1 3120120 13 ELSA, TX 003240 KILLER I Bromethalin Death as a suspected heart attack. 

A 56 year old male opened the 

product. The air that came out of 

the bag and hit his face. For 

approximately one hour after he 

opened the bag he continued to taste 

the product. Two days after his 

exposure he began to experience 

TOMCAT MOUSE edema/swelling, numbness, 

KILLER I abdominal distension, taste 

012455- (REFILLABLE alteration, fever/hyperthermia, 

026696 - STATEN 00120- RESIST ANT BAIT confusion, ocular irritation and 

00001 5114/20 14 ISLAND, NY 003240 STATION) Bromethalin Major redness, and insomnia. 

An adult male may have inhaled 

some of the product that had been 

on the roadside during the winter 

and spring. He suspects that dust 

wafted into the road grader cab that 

he was operating while he was 

RAMIK MINI BARS doing his road work. He developed 

022153 - CARROLLTON, 061282- ALL WEATHER RAT diabetes with pancreatic and liver 

00001 511 /2010 MO 00026 & MOUSE KILLER Diphacinone Major shutdown. 

Page 15 of15