Please submit response to:

Derrick Lastinger, Program Director

Structural Pest Section

Georgia Department of Agriculture

19 Martin Luther King, Jr. Drive SW

Atlanta, GA 30334-4201

January 27, 2012

Richard Keigwin, Director

Pesticide Re-Evaluation Division

Office of Pesticide Programs

US EPA Headquarters 

Ariel Rios Building 

1200 Pennsylvania Avenue, N. W. 

Mail Code: 7508P 

Washington, DC 20460

Dear Mr. Keigwin, 

We write today on behalf of the Association of Structural Pest Control Regulatory Officials (ASPCRO) to confirm our 

understanding regarding revisions to the label language for professional and agricultural rodenticide labels and 

clarify the upcoming revisions to rodenticide labels and to more clearly define the term “man-made structure.”

Throughout the last several months ASPCRO and US EPA staff have discussed problems with the language on 

current rodenticide labels that reads: “Do not apply further than 50 feet from buildings.” As we’ve mentioned 

previously, many sites where rodent control is essential do not contain a ‘building’, as traditionally defined, close to 

the area of treatment or contain any building at all.

While ASPCRO members appreciate EPA’s commitment to the protection of secondary and non-target wildlife and 

the definitiveness and enforceability of a specific distance as opposed to the ambiguous phrase “in and around,” we 

believe the label must provide additional flexibility to certified applicators and persons working under their direct 

supervision, so effective rodent management strategies can continue to be utilized. To that end, extending the 

distance to 100 feet and replacing the term “building” with “man-made structure” still adequately safeguards the 

ecosystem while also allowing for uses of rodenticides that are necessary to protect food, property and public health 

from destructive and potentially dangerous rodent infestations.

While ASPCRO firmly believes the term “man-made structure” is a better alternative to the more inflexible 

“building,” we also think it is vital to provide guidance to the regulatory community – especially state lead agencies -

as well industry stakeholders. Per our discussions, we understand these products can only be used to control 

Norway rats, roof rats, and house mice in and within 100 feet of man-made structures constructed in a manner so as 

to be vulnerable to commensal rodent invasions and/or to harboring or attracting rodent infestations. Examples of 

such structures include homes and other permanent or temporary residences, food plants, industrial and 

commercial buildings, dumpsters and permanent trash receptacles, agricultural and public buildings, transport 

vehicles (ships, trains, aircraft), docks and port of terminal buildings and related structures around and associated 

with these sites.

The term “man-made structures” specifically excludes a fence line of any material, meaning that it would be a label 

violation to place rodenticide next to such objects, if they are not within 100 feet of a “man-made structure.” 
To address the use restrictions in outdoor, non-crop areas including areas more than 100 feet from man-made 

structures, first generation anticoagulants and non-anticoagulant products may be applied to rodent burrows to 

control Norway rats, roof rats and house mice, provided that infestations of the commensal rodents (Norway rat, 

roof rat or house mice) have been confirmed. Bait must be placed deeply in active Norway/roof rat burrows using 

only loose pellets or meal formulation. Because commensal rodent infestations may occur in areas farther than 100

feet from man-made structures when the rodents have ample supplies of food and cover, efforts should be made to 

remove conducive food, trash, garbage, clutter, and debris. 

ASPCRO believes the descriptions above accurately reflect our discussions and the intent of the upcoming revision 

to the rodenticide labels. We have attached an Appendix which summarizes our understanding of the pending label 

revisions. We respectfully request feedback on this matter in order to confirm ASPCRO’s assumption. 

ASPCRO feels another key component to the success and implementation of the risk mitigation measures is support 

of product stewardship efforts. Agricultural, industrial, institutional, and urban stakeholders with a need for 

adequate rodent management will require access to educational support about effective rodent management. We 

feel a cooperative effort by ASPCRO Rodenticide Committee, US EPA and key industry stakeholders in this process 

will provide a means for supporting development of the necessary components including best management 

practices, outreach materials, and resources. 

In closing, ASPCRO extends its deepest appreciation to you, Neil, Rusty, John, and Laura for working with ASPCRO 

over the last several months on this very important issue. As always, we appreciate your time and attention, and 

support of state lead agencies.

Sincerely, 

Derrick Lastinger

President, ASPCRO

Program Director, Georgia Department of Agriculture

Vice-President, ASPCRO

Co-Chair, ASPCRO Rodenticide Committee

Program Manager, Colorado Department of Agriculture

Bonnie M. Rabe

Co-Chair, ASPCRO Rodenticide Committee

Division Director, New Mexico Department of Agriculture

cc: Chuck Andrews, AAPCO President; Steve Dwinell SFIREG Chair; Bob Rosenberg, NPMA 
ASPCRO Letter to EPA

Rodenticide Labels

Appendix A

 On all professional and agricultural labels

This product can only be used to control Norway rats, Roof rats, and house mice in and within 100 

feet of man-made structures constructed in a manner so as to be vulnerable to commensal rodent 

invasions and/or to harboring or attracting rodent infestations. Examples of such structures 

include homes and other permanent or temporary residences, food plants, industrial and 

commercial buildings, dumpsters and permanent trash receptacles, agricultural and public 

buildings, transport vehicles (ships, trains, aircraft), docks and port of terminal buildings and 

related structures around and associated with these sites.

 On all first-generation anticoagulants and non-anticoagulants professional and agricultural labels 

This product may be applied to rodent burrows to control Norway rats, roof rats and house mice, 

provided that infestations of the commensal rodents (Norway rat, roof rat or house mice) have 

been confirmed. Bait must be placed 6 inches or more in active Norway/roof rat burrows using 

only loose pellets or meal formulation. Because commensal rodent infestations may occur in 

areas farther than 100 feet from buildings and man-made structures when the rodents have 

ample supplies of food and cover, efforts should be made to remove conducive food trash, 

garbage, clutter, and debris