Rodenticide Mitigation Dec

What Retailers Should Know

October 19, 2010

Rusty Wasem Laura ParsonsNeil Anderson

- Pesticide Re-evaluation Division
Outline

• EPA & Pesticides – Statutory 

Requirements

• Rodenticides• Recap of Decision• What Decision Means for Retaile• EPA Communication Efforts
EPA & Pesticides Statuto

Requirements

• Federal Insecticide Fungicides & Roden

(FIFRA)

• Food Quality Protection Act (FQPA)• All products that make pesticidal claims 

registered with EPA.

• Product labeling and use instructions.• Pesticide producers (“registrants”) mus

variety of data to obtain a registration foproduct.

– Public health pesticides (like rodenticides) m

supported with efficacy data.

• Statutorily required periodic reviews of 
Rodenticides

•

1st Generation Anticoagulants:

warfarin, chlorophacinone, diphacinone– Lethal dose in multiple feedings, le

persistent than 2nd Generation.

– Pest dies 5-7 days after lethal dose

•

2nd Generation Anticoagulants:

brodifacoum, bromadiolone, difenacoum, dif– Lethal dose in 1 feeding, more pers– Pest dies 5-7 days after lethal dose

• Non-Anticoagulants

bromethalin, cholecalciferol, zinc phosphide
Timeline for Implementati

• Sept. 1997 Original decision - more review needed

• May/June 2008 Publish decision – no comment period

• Dec. 2009 – Rodenticide producers submit compliant prod

• 2.5 Years After Decision Published (~Dec. 4, 2010)

• Deadline for EPA to issue decisions on registration applica

amendments

• 3 Years After Decision Published (~June 4, 2011)

• Last day for voluntarily complying registrants to release in

commerce a product not complying with the risk mitigation 

• Products requesting voluntarily cancellation have until this 

release into commerce

• Existing stocks of non-compliant products released for shi

the registrant on or before this date can be sold until stock

exhausted
Risk Mitigation – Children & 

• Risks Identified:

– accidental child exposure.

Since 1993, 12k-15k cases per year reportedRarely is a harmful amount of bait consumed.

– accidental pet exposure.

Often result in pet death.

• Mitigation Required:

– homeowner/retail rodenticide products m

sold with a bait station and may not contathan 1 lb of bait.

– testing required to demonstrate tamper 

resistance of bait station.

– prohibit certain forms (pellets, meal, treat

grain) of bait that can easily be removed fstation.
Risk Mitigation - Ecologi

• Risk Identified: 

– direct and secondary poisonings of non-target spe

– well documented 2nd gen. anticoagulant presence 

raptors, foxes, wild cats, deer.

• Mitigation Required:

– reduce availability of 2nd gen. anticoagulants to ho

– prohibit sale of 2nd gen. products in retail stores.

– packaging size requirements for 2nd gen. products

• 8 lbs for agriculture products / 16 lbs for professiona

– outdoor (non-field) use must be within 50 ft. of build
What Decision Means fo

Retailers? 

• All changes will be made by the 

rodenticide producer/registrant

• Non-conforming products releas

retailers on or before June 4, 20be sold until exhaustion.

• Products released to distributor

retailers post June 4, 2011 must mitigation measures.
Compliant Products

• New Registrations – to date (10/18

we have registered 23 mitigation compliant homeowner/retail prod

• Registration decisions on other 

compliant products are currently pending. 
Communication Efforts by 

• Webpage Updates

– Rodenticides Homepage– http://www.epa.gov/oppsrrd1/rereg

odenticides/

– Rodenticides Docket – EPA-HQ-OPP-2006-0955– http://www.regulations.gov/search

e.html#docketDetail?R=EPA-HQ-OP0955

• Direct Contact
Contact Info

• Rusty Wasem Chemical Review Manager Rodentici

– wasem.russell@epa.gov– (703) 305-6979

• Laura ParsonsTeam Leader Rodenticides

– parsons.laura@epa.gov– (703) 305-5776

• Neil AndersonBranch Chief, Risk Management & 

Implementation Branch I anderson.neil@epa.gov

– (703) 308-8187
Photo Credits

• Photos on slides 1, 2, 4, 7, 9 fro

Wikipedia.

• Photo on slide 6 Environment 

Canada webpage.
Bait Stations

• Tiered bait station requirements for all “resid

consumer” products

• Tier I – Tamper-Resistance and Weather-Res

– These bait stations are resistant to weather and to 

by children and dogs. To be used indoors and outd

(within 50 feet of buildings).

• Tier II – Tamper-Resistant (but not weather re

– These bait station are resistant to tampering by ch

dogs. To be used indoors only.

• Tier III – Tamper-Resistant for Children Only

– These bait stations are resistant to tampering by c

be used indoors only.

• Tier IV – Tamper-Resistance Unknown

– These bait stations may not claim to be tamper res

be used indoors only and only in areas inaccessibl

children and pets.