UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHING TON
, D

. C

. 20460

Office of Chemical Safety & Pollution Prevention 

### SENT VIA E-MAIL March 20, 2012 John Lublinkhof, Ph.D. Director of Regulatory Affairs Bell Laboratories, Inc.

SUBJECT: Outdoor Use Labeling Restrictions for Professional Rodenticide Products

Dear Dr. Lublinkhof:

I greatly appreciate you conununicating Bell Laboratories' questions about the Agency's revision to the restriction of use of rodenticide bait products within 50 feet of buildings for professional and agricultural labels. On March 16,2012, you contacted my office with a concern that the burrow baiting language in the memorandum Commensal Rodenticide Products Outdoor 50 Foot Restriction/or Professional Use Products (Revised to Include Language/or Agricultural Products), dated March 14,2012, could be interpreted to prohibit burrow baiting within 100 feet of "man-made structures constructed in a manner so as to be vulnerable to commensal rodent invasion and/or to harboring or attracting rodents." As you know, it was not the Agency's intent to prohibit burrow baiting in such situations. To reduce any confusion, my staff has made available to the Registration Division a revised version of the label statemen ts in the March 14
, 2012 memorandum
, which are also attached to this letter.

If you have any questions or comments, please contact Rusty Wasem at wasem.russell @ epa.gov or 703

- 305

- 6979.

CC: Meredith Laws
, Registration Division Sincerely,

# Ri**h** dP K' 

## P

# D' "Is--> car. elgwm, lrector Pesticide Re-evaluation Division Office of Pest icide Programs

Bonnie Rabe, ASPCRO Rodenticide Co mmittee John Scott, ASPCRO Rodenticide Committee Bob Rosenberg, NPMA Carl Tanner, Liphatech Bobby Corrigan, RMC Pest Management Consulting Chris Gorecki
, Orkin Registrants of Professional Rodentic ide Products

lof2 

### •

### 2 of 2 New Restrictive Language Changes highlighted in yellow

 “Use Restrictions”

o on all professional labels: “This product can only be used to control No rway 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 attr acting rodent infestations. Examples of such structures include homes and other permanent or temporary residences, food processing facilities, industrial and commercial bu ildings, trash receptacles, agricultural and public buildings , transport vehicles (ships, trains, aircraft), docks and port of terminal buildings and related structur es around and associated with these sites. Fence and perimeter baiting, beyond 100 feet fr om a structure as defined above, is prohibited. This product must not be app lied directly to food or feed crops.”

o on all agricultural labels: “This product can only be used to control No rway rats, roof rats, and house mice in and within 100 feet of agricultural buildings and man-made agricultural structures constructed in a manner so as to be vulnerable to commens al rodent invasions a nd/or to harboring or attracting rodent infestations. Fence and perimeter baiting, beyond 100 feet from an agricultural structure as defined above, is prohibited. This product must not be applied directly to food or feed crops.”

 Label language specific to block, so ft bait, and sachet formulations “Burrow baiting with <insert product name> is prohibited.”

 On all second-generation anticoagulant products labeled for application in rodent burrows: “This product may only be applied to active burro ws to control Norway rats and roof rats within 100 feet of buildings and man-made stru ctures constructed in a manner so as to be vulnerable to commensal rodent invasions and/or to harboring orattracting rodent infestations provided that infe stations of these rodents have been confirmed. Efforts should be made to remove food tras h, garbage, clutter, and debris.” “Bait must be placed no less than 6 inches into active Norway/roof rat burrows. Do not broadcast bait."

 On all first-generation an ticoagulants and non-anticoa gulants professional and agricultural products labeled for application in rodent burrows: "This product may be applied to active rodent burrows to control Norway rats, and roof rats within or beyond 100 feet of buildings and man-made structures, provided that infestations of these rodent s have been confirmed.” “Bait must be placed no less than 6 inches into active Norway/roof rat burrows. Do not broadcast bait." “Because Norway/roof rat infestations may o ccur in areas farther than 100 feet from buildings and man-made structures when th e rodents have ample supplies of food and cover, efforts should be made to remove food trash, garbage, clutter, and debris."