UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, 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 statements 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 

car. D' "Is--> elgwm, lrector 

Pesticide Re-evaluation Division 

Office of Pesticide Programs 

Bonnie Rabe, ASPCRO Rodenticide Committee 

John Scott, ASPCRO Rodenticide Committee 

Bob Rosenberg, NPMA 

Carl Tanner, Liphatech 

Bobby Corrigan, RMC Pest Management Consulting 

Chris Gorecki, Orkin 

Registrants of Professional Rodenticide 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 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 processing facilities, industrial and commercial buildings, 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. 

Fence and perimeter baiting, beyond 100 feet from a structure as defined above, is 

prohibited. This product must not be applied directly to food or feed crops.” 

o on all agricultural labels: 

“This product can only be used to control Norway 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 commensal rodent invasions and/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, soft 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 burrows to control Norway rats and roof rats 

within 100 feet of buildings and man-made structures constructed in a manner so as to be 

vulnerable to commensal rodent invasions and/or to harboring or attracting rodent 

infestations provided that infestations of these rodents have been confirmed. Efforts 

should be made to remove food trash, 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 anticoagulants and non-anticoagulants 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 rodents 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 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 food trash, garbage, clutter, and debris."