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 an ima organization with more than two million members and supporters, welcomes Environmental Protection Agency’s (EPA) June 7 anno uncement that it is moving to ban the sale to resid ential

co nsumers of the most toxic mouse and rat poisons, br odifacoum, bromadiolone, difethialone and difenacou m. However, we call upon EPA to extend its ban to unnecessary in addition to presenting ri sks for exposure to children, pets and wildlife.

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

also includes the first- generation anticoagulants, warfarin, chlorophacinon e and diphacinone. A for consultation under the Endangered Species Act d escribes chlorophacinone, and diphacinone as blood thinners that predispose poisoned animals to widespread inte rnal hemorrhaging. “Death occurs to poisoned animal s 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 als o rupture, leading to fluid loss directly through b ody areas

where no vents would otherwise exist.” 1
toxicant that causes respiratory distress; cholecal ciferol, which causes hypercalcemia in the blood an d other body tissues; and zinc phosphide, which causes liberatio n 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 nat ural habitats are lost to development, and we owe i t to these gentle, social animals to do a ll 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 po tential 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 Reque st for Endangered Species Act Section 7 consultatio n on 31 pesticides for all uses, on all listed species. U.S . Environmental Protection Agency, Office of Pestic ides and Toxic Substances . Washington, DC 290 pp.

Treatment of Animals (PETA), the world’s largest an ima l rights than two million members and supporters, welcomes the U.S. Environmental Protection Agency’s (EPA) June 7 anno uncement that it is moving to ban the sale to resid ential nsumers of the most toxic mouse and rat poisons, br odifacoum, bromadiolone, difethialone and difenacou m. However, we call upon EPA to extend its ban to all mouse and rat poisons, as they are all inherently c ruel and sks for exposure to children, pets and wildlife.

generation” anticoagulants, the 2008 risk mitigatio n decision referenced by EPA generation anticoagulants, warfarin, chlorophacinon e and diphacinone. A for consultation under the Endangered Species Act d escribes chlorophacinone, and diphacinone as blood thinners that predispose poisoned animals to widespread inte rnal hemorrhaging. “Death occurs to poisoned animal s 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 als o rupture, leading to fluid loss directly through b ody areas

1 In addition, the risk mitigation decision includes bromethalin, a nerve toxicant that causes respiratory distress; cholecal ciferol, which causes hypercalcemia in the blood an d other body tissues; and zinc phosphide, which causes liberatio n of phosphine ga s 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 nat ural habitats are lost to development, and we owe i t 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 po tential 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 Reque st for Endangered Species Act Section 7 consultatio n on 31 pesticides for all uses, on all listed species. U.S . Environmental Protection Agency, Office of Pestic ides and Toxic Environmental Protection Agency’s (EPA) June 7 anno uncement that it is moving to ban the sale to resid ential nsumers of the most toxic mouse and rat poisons, br odifacoum, bromadiolone, difethialone and difenacou m. mouse and rat poisons, as they are all inherently c ruel and

generation” anticoagulants, the 2008 risk mitigatio n decision referenced by EPA generation anticoagulants, warfarin, chlorophacinon e and diphacinone. A 1991 EPA request for consultation under the Endangered Species Act d escribes chlorophacinone, and diphacinone as blood thinners that predispose poisoned animals to widespread inte rnal hemorrhaging. “Death occurs to poisoned animal s 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 als o rupture, leading to fluid loss directly through b ody areas In addition, the risk mitigation decision includes bromethalin, a nerve toxicant that causes respiratory distress; cholecal ciferol, which causes hypercalcemia in the blood an d 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 nat ural habitats are lost to development, and we owe i t 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 po tential food sources and nesting sites. PETA offers additional http://www.peta.org/issues/wildlife/house -mice.aspx.

Environmental Protection Agency. 1991. Formal Reque st for Endangered Species Act Section 7 consultatio n on 31 pesticides for all uses, on all listed species. U.S . Environmental Protection Agency, Office of Pestic ides and Toxic