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Specifically brought to our attention were the following: 

 There are many structures other than buildings that are vulnerable to commensal rodent 

infestations. 

Beginning in early 2011, it was brought to the Agency’s attention that the restriction that 

commensal use rodenticides be used within “50 feet of buildings” would leave professional pest 

applicators poorly equipped to deal with commensal rodent infestations in many important sites. 

At certain sites such as food processing and storage facilities, it is important to make rodenticide 

bait placements farther than 50 feet to create a protective perimeter against commensal rodents or to 

protect non-building structures that store food farther than 50 feet from buildings. Ports, which may 

contain many storage and transport units but lack buildings, were also given as another example of 

areas that require rodenticides to protect sensitive resources more than 50 feet from buildings. 

Because of this, the Agency will change the term “building” to “man-made structures constructed in 

a manner so as to be vulnerable to commensal rodent invasions and/or to harboring or attracting 

rodent infestations.” 

 The importance of placing dumpsters and other garbage receptacles farther than 50 feet from 

buildings and the utility of using rodenticides around dumpsters. 

IPM guidance informs building and pest managers to locate dumpsters and other waste receptacles 

as far from the resource they are trying to protect from rodents as possible. The Agency has been 

made aware of several municipal guidance publications that suggest commercial waste enclosures 

be sited more than 100 feet from buildings (Santa Barbara Handout). Also, placing dumpsters 

farther than 50 feet from buildings (especially those involved in food production or processing) can 

aid in the management of flies and other similar pests. (UGA Extension and Illinois Dept of 

Health) 

 Outdoor food storage facilities that are farther than 50 feet from buildings. 

The California League of Food Processors submitted comments informing the Agency that some of 

their members store finished tomato paste in sealed containers outdoors, more than 50 feet from 

buildings. The tomato paste is stored farther than 50 feet to accommodate facility vehicle traffic. 

According to their comments, the 50-foot restriction would lead to difficulty controlling rodent 

populations around the stored food product therefore making compliance with food safety standards 

very difficult. (See June 7, 2011 Letter Neenan to Keigwin). 

 In urban areas, rat infestations often occur farther than 50 feet from buildings. 

The New York City Department of Health and Mental Hygiene (DOHMH) cited several examples 

in urban areas where standard rodent control practices and IPM methodology require rodent control 

farther than 50 feet from buildings. These examples include trash receptacles, parks and green 

space as well as urban sewage catch basins which are located farther than 50 feet from buildings. 

(See letter Mario Merlino, New York City Department of Health and Mental Hygiene to US EPA, 

June 9, 2011) 
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After carefully analyzing these comments, and in consideration of the Agency’s efforts to reduce 

wildlife exposures, PRD has determined that it would be appropriate to revise the labels for 

professional use commensal rodenticide products to provide applicators with some additional 

flexibility to meet critical pest control needs. This additional flexibility (i.e., extending the 

distances from man-made structures) is balanced with specific label requirements for integrated pest 

management practices, specific placement instructions, and prohibitions on certain use practices. 

 Burrow baiting with place packs and blocks is risky and should be reconsidered 

The Ad Hoc Rodenticide RMD Stakeholder Workgroup also brought to the Agency’s attention the 

issue of burrow baiting applications made with place packs and blocks. According to the 

Workgroup, it supports the Agency prohibiting burrow applications with rodenticide place packs 

and blocks because doing so “addresses and corrects the most environmentally insensitive and risky 

practice of stuffing packets and blocks down rat holes (as often they come right back up and thus 

present direct exposure to pets, children, wildlife mammals and birds, environmental wash off, 

etc.).” The Agency agrees with the Workgroup and will implement this restriction. (See 

presentation Ad Hoc Rodenticide RMD Stakeholder Workgroup, August 30, 2011) 

New Restrictive Language

The new label perimeter restriction for professional use commensal rodenticide products is as 

follows: 

 “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” 
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 Label language specific to block, soft bait, and sachet formulations 

“Burrow baiting with <insert product name> is prohibited.” 

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

products labeled for application in rodent burrows: 

“This product may only be applied to active rodent burrows to control Norway rats, and roof 

rats beyond 100 feet, provided that infestations of the Norway rat or roof rat have been 

confirmed. Bait must be placed no less than 6 inches into active Norway/roof rat burrows. 

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 conducive food trash, garbage, clutter, and debris. Do not 

broadcast bait.” 

This label language will only apply to commensal use rodenticide products that are marketed to 

occupational (agricultural and PCO) users and sold in quantities of four pounds or greater 

(depending on the active ingredient). All homeowner products will continue to be subject to the 50 

foot restriction per the RMD. 

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

703-305-6979. 

Guidance Consulted for Integrate Pest Management Practices for Dumpster and Refuse 

The City of Santa Barbara Department of Public Works. Space Allocation Guide for Trash and 

Recycling For New Commercial: Construction and Remodel. 

http://www.santabarbaraca.gov/Documents/Forms_and_Handouts/Public_Works/03_Guides

/Trash_and_Recycling_Space_Allocation_Guide.pdf

The District of Columbia Health Regulation and Licensing Administration, Bureau of Community 

Hygiene. Using Dumpsters to Prevent Rodent Problems. 

http://hrla.doh.dc.gov/hrla/cwp/view,a,1384,q,572974.asp

Extension. Structural and Public Health Pests: Flies (House Flies, Filth Flies). 

http://www.extension.org/pages/23627/structural-and-public-health-pests:-flies-house-fliesfilth-flies

Illinois Department of Public Health. Prevention & Control: The House Fly and Other Filth Flies. 

http://www.idph.state.il.us/envhealth/pcfilthflies.htm