June 21, 2011 

Steven Bradbury, Director 

Office of Pesticide Programs 

Environmental Protection Agency 

Ariel Rios Building, 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

Via Facsimile: (703) 308-7026

Dear Dr. Bradbury: 

People for the Ethical Treatment of Animals (PETA), the world’s largest anima

organization with more than two million members and supporters, welcomes

Environmental Protection Agency’s (EPA) June 7 announcement that it is moving to ban the sale to residential 

consumers of the most toxic mouse and rat poisons, brodifacoum, bromadiolone, difethialone and difenacoum. 

However, we call upon EPA to extend its ban to 

unnecessary in addition to presenting risks for exposure to children, pets and wildlife.

While the ban targets “second-generation” anticoagulants, the 2008 risk mitigation decision referenced by EPA 

also includes the first-generation anticoagulants, warfarin, chlorophacinone and diphacinone. A 

for consultation under the Endangered Species Act describes chlorophacinone, and diphacinone as blood thinners 

that predispose poisoned animals to widespread internal hemorrhaging. “Death occurs to poisoned animals over a 

period of days to weeks through loss of bodily fluids, mainly blood, through various orifices. In the final days or 

hours, the poisoned animal's skin membranes may also rupture, leading to fluid loss directly through body areas 

where no vents would otherwise exist.”1

toxicant that causes respiratory distress; cholecalciferol, which causes hypercalcemia in the blood and other body 

tissues; and zinc phosphide, which causes liberation of phosphine ga

Mice and rats are complex, unique individuals with the capacity to experience a wide range of emotions. They are 

often forced into human environments when their natural habitats are lost to development, and we owe it to these 

gentle, social animals to do all that we can to peacefully coexist with them. 

horrific suffering by exposure to these poisons is completely unnecessary. 

importance of non-lethal measures to deter mice and rats from 

sealing holes inside and outside and cleaning up potential food sources and nesting sites. PETA offers additional 

tips for living in harmony with house mice and rats

I can be reached at 757-622-7382, ext. 8001 or via email at JosephM@peta.org.

Sincerely, 

Joseph Manuppello 

Research Associate 

Regulatory Testing Division 

 

1 Environmental Protection Agency. 1991. Formal Request for Endangered Species Act Section 7 consultation on 31 

pesticides for all uses, on all listed species. U.S. Environmental Protection Agency, Office of Pesticides and Toxic 

Substances . Washington, DC 290 pp. 

Treatment of Animals (PETA), the world’s largest animal rights 

than two million members and supporters, welcomes the U.S. 

Environmental Protection Agency’s (EPA) June 7 announcement that it is moving to ban the sale to residential 

nsumers of the most toxic mouse and rat poisons, brodifacoum, bromadiolone, difethialone and difenacoum. 

However, we call upon EPA to extend its ban to all mouse and rat poisons, as they are all inherently cruel and 

sks for exposure to children, pets and wildlife.

generation” anticoagulants, the 2008 risk mitigation decision referenced by EPA 

generation anticoagulants, warfarin, chlorophacinone and diphacinone. A 

for consultation under the Endangered Species Act describes chlorophacinone, and diphacinone as blood thinners 

that predispose poisoned animals to widespread internal hemorrhaging. “Death occurs to poisoned animals over a 

weeks through loss of bodily fluids, mainly blood, through various orifices. In the final days or 

hours, the poisoned animal's skin membranes may also rupture, leading to fluid loss directly through body areas 

1

In addition, the risk mitigation decision includes bromethalin, a nerve 

toxicant that causes respiratory distress; cholecalciferol, which causes hypercalcemia in the blood and other body 

tissues; and zinc phosphide, which causes liberation of phosphine gas in the stomach. 

Mice and rats are complex, unique individuals with the capacity to experience a wide range of emotions. They are 

often forced into human environments when their natural habitats are lost to development, and we owe it to these 

ll that we can to peacefully coexist with them. The willful infliction of unimaginably 

horrific suffering by exposure to these poisons is completely unnecessary. To its credit, EPA stresses the 

lethal measures to deter mice and rats from entering our homes in the first place such as 

sealing holes inside and outside and cleaning up potential food sources and nesting sites. PETA offers additional 

tips for living in harmony with house mice and rats http://www.peta.org/issues/wildlife/house

7382, ext. 8001 or via email at JosephM@peta.org.

Environmental Protection Agency. 1991. Formal Request for Endangered Species Act Section 7 consultation on 31 

pesticides for all uses, on all listed species. U.S. Environmental Protection Agency, Office of Pesticides and Toxic 

Environmental Protection Agency’s (EPA) June 7 announcement that it is moving to ban the sale to residential 

nsumers of the most toxic mouse and rat poisons, brodifacoum, bromadiolone, difethialone and difenacoum. 

mouse and rat poisons, as they are all inherently cruel and 

generation” anticoagulants, the 2008 risk mitigation decision referenced by EPA 

generation anticoagulants, warfarin, chlorophacinone and diphacinone. A 1991 EPA request 

for consultation under the Endangered Species Act describes chlorophacinone, and diphacinone as blood thinners 

that predispose poisoned animals to widespread internal hemorrhaging. “Death occurs to poisoned animals over a 

weeks through loss of bodily fluids, mainly blood, through various orifices. In the final days or 

hours, the poisoned animal's skin membranes may also rupture, leading to fluid loss directly through body areas 

In addition, the risk mitigation decision includes bromethalin, a nerve 

toxicant that causes respiratory distress; cholecalciferol, which causes hypercalcemia in the blood and other body 

Mice and rats are complex, unique individuals with the capacity to experience a wide range of emotions. They are 

often forced into human environments when their natural habitats are lost to development, and we owe it to these 

The willful infliction of unimaginably 

To its credit, EPA stresses the 

entering our homes in the first place such as 

sealing holes inside and outside and cleaning up potential food sources and nesting sites. PETA offers additional 

http://www.peta.org/issues/wildlife/house-mice.aspx. 

Environmental Protection Agency. 1991. Formal Request for Endangered Species Act Section 7 consultation on 31 

pesticides for all uses, on all listed species. U.S. Environmental Protection Agency, Office of Pesticides and Toxic