Page 2 of 27

incidents to children under six years of age to total incidents per pesticide classifications is 

highest for rodenticides than the other pesticide classifications. 

II. BACKGROUND 

In the U.S., rodenticides are registered for use by the Environmental Protection Agency’s (EPA 

or Agency) Office of Pesticide Programs (OPP or Office) for use against pest rodents (e.g., rats, 

mice, gophers, etc.) associated with a variety of use sites (e.g., agricultural fields, restaurants, 

homes, etc.). Rodenticides have been most recently reviewed under OPP’s Reregistration 

program in the 1990s. As a result of these reviews, rodenticide agricultural field uses and 

residential tracking powder products were successfully mitigated via classification as restricted 

use pesticides (RUP; the one exception was manual underground baiting products for use in 

agricultural fields, which did not necessitate an RUP classification). Additionally, rodenticides 

employed to preserve native plant and animal species on islands were determined to be 

appropriately managed by the U.S. Fish and Wildlife Service, rendering mitigation unnecessary. 

However, the path forward to mitigate risk from the remaining rodenticide use pattern 

(rodenticides formulated as baits/pellets used against commensal rodents1

 in residential-type 

settings) met with some resistance, resulting in the Rodenticide Stakeholder Workgroup (RSW), 

a subcommittee under the federally-chartered advisory body, the Pesticide Program Dialogue 

Committee (PPDC). The RSW issued recommendations, and helped inform the Agency’s 2008 

Risk Mitigation Decision for Ten Rodenticides (RMD). Under the terms of the 2008 RMD, 

products marketed to the general non-professional user or homeowner must be modified to adopt 

a variety of mitigation measure to continue to meet the FIFRA standard. These risk mitigation 

measures included requiring rodenticide products used in homes and marketed to general 

residential consumers be sold only with bait stations. Additionally, the RMD required the 

second-generation anticoagulant class of rodenticides to be sold in a way to limit sale to general 

residential consumers. The RMD provided registrants until June 4, 2011 to comply with the 

mitigation measures. However, as of June 4, 2011 not all rodenticide products complied. As a 

consequence, the Agency is preparing to commence cancellation proceedings under FIFRA 

section 6(b). 

Since the 1960s, the Unites States Department of Agriculture (USDA, which regulated pesticides 

until the formation of the EPA) and then the EPA, have worked to regulate these rodenticides by 

mandating they be housed in bait-stations that prevent exposure to non-target organisms. The 

primary reason driving this effort was the number of accidental (unintentional) exposures 

involving these products. Subsequently, at this juncture, the Agency is compiling information to 

support the upcoming NOIC, and this memo in particular focuses on residential rodenticide use 

and their impact on humans. 

Currently, there are 10 active ingredients and two sodium salts that are formulated as baits and 

used in residential-type settings, as well as hold active registrations. Furthermore, they can be 

 

1 Commensal rodents are rodents that live in close association with humans and depend upon them for shelter and/or for some of 

their sustenance. In the continental U.S., the term commensal rodents includes Norway rats (Rattus norvegicus), roof rats (Rattus 

rattus), and house mice (Mus musculus). 
Page 3 of 27

grouped according to three main categories: first-generation anticoagulants, second-generation 

anticoagulants and non-anticoagulants. They are classified as follows: 

 First-generation anticoagulant 

o chlorophacinone (PC code 067707) 

o diphacinone (PC code 067701) 

o diphacinone sodium salt (PC code 067705) 

o warfarin (PC code 086002) 

o warfarin sodium salt (PC code 086003) 

 Second-generation anticoagulant 

o brodifacoum (PC code 112701) 

o bromadiolone (PC code 112001) 

o difenacoum (PC code 119901) 

o difethalione (PC code 128967) 

 Non-anticoagulant 

o bromethalin (PC code 112802) 

o cholecalciferol (PC code 202901) 

o zinc phosphide (PC code 088601) 

Rodenticides are designed to kill mammals, so their effects on humans and non-target mammals 

are qualitatively the same as their effects on target pests, unlike other pesticides such as 

herbicides and certain insecticides where adverse effects on mammals tend to be different in 

nature than their effects on target pests. Rodenticides can be divided into three broad classes in 

terms of their effects: first generation anticoagulants, second generation anti-coagulants, and 

non-anticoagulants. The first- and second generation anti-coagulants interfere with blood 

clotting and death results from hemorrhage. For both first generation and second generation 

anticoagulants, primary manifestations include nosebleeds, bleeding gums, hematuria, melena, 

and extensive ecchymoses (bruises). Patients may also have symptoms of anemia, including 

fatigue and dyspnea on exertion. If the poisoning is severe, the patient may progress to shock 

and death. The first generation anti-coagulants generally require multiple doses to deliver a lethal 

dose while the second generation anticoagulants can deliver a lethal dose to rodents in one 

night’s feeding. The non-anticoagulant rodenticides work in different ways to cause death. 

Each of these is discussed below: 

 first generation anti-coagulants disrupt the production in the liver of vitamin K 

dependent blood-clotting factors II (prothrombin), VII, IX, and X. Due to the long halflives of the vitamin K-dependent clotting factors, the anticoagulant effect doesn’t occur 

in the rodent until after several days of ingestion The onset of lengthened prothrombin 

time (PT) from a toxic dose may occur within 24 hours, and reach a maximum in 36-72 

hours at a dose much lower than the dose that can cause hemorrhage (Reigart J.R. et.al, 

1999). The agents also increase permeability of capillaries throughout the body, leading 

to widespread internal hemorrhage. It is noted that chlorophacinone, diphacinone, and 

diphacinone sodium salt block different binding sites than those blocked by warfarin and 

warfarin sodium salt. 
Page 4 of 27

 second generation anticoagulants are more acutely toxic than first generation agents and 

can cause lethal effects to rodents in a single dose. Like the first generation 

anticoagulants these agents block the formation of the active form of vitamin K, which in 

turn inhibits the production of coagulation factors in the liver. These chemicals block the 

same binding site that warfarin and warfarin sodium block; however, second generation 

anticoagulants have much longer half-lives in the body (Batten and Bratt, 1990). Similar 

to the first generation anticoagulants, the toxic effects of these agents usually begin 

several days after ingestion, because of the long half-life of the coagulation factors. 

The non-anticoagulants work in a variety of ways and no single common mechanism exists. 

For example: 

 Bromethalin, causes decreased production of ATP in the cells of the central nervous 

system by uncoupling oxidative phosphorylation in the mitochondria. Low levels of 

ATP reduce the efficiency of the enzyme Na/K ATPase, leading to increased 

intracellular sodium levels. This in turn draws more water into neuronal cells (cerebral 

edema) and increases intracranial pressure which can be lethal. Symptoms and signs 

of cerebral edema include headache, dizziness, nausea, numbness, weakness, loss of 

coordination or balance, altered level of consciousness, respiratory depression, 

seizures, and death. 

 Cholecalciferol increases calcium absorption from food, and mobilizes calcium from 

bone which leads to hypercalcemia (increased calcium levels in blood). 

Hypercalcemia can cause formation of calcium crystals in internal organs such as 

blood vessels, kidneys, stomach wall and lungs (Chavhan S.G.et.al, 2011). Abnormal 

heart conduction and irregular heartbeats can also occur since the heart tissue is 

sensitive to changes in blood calcium levels. Symptoms and signs of cholecalciferol 

poisoning may include fatigue, weakness, nausea, anorexia, headache and irregular 

heartbeats (Goldfrank et.al, 2010). Acute renal tubular injury due to hypercalcemia 

may cause excessive urination, increased water intake, protein in urine and increased 

blood urea levels. Prolonged hypercalcemia may eventually cause kidney failure due 

to formation of kidney stones and calcium deposition in kidney tissues. 

 Zinc phosphide can quickly produce toxic phosphine gas when it comes in contact with 

acids or water. Phosphine is thought to produce toxicity by blocking cytochrome 

oxidase and, inhibiting oxidative phosphorylation which may lead to cell death (Perry 

H.E., 1998). Most of the tissue damage can occur in liver, kidneys and heart. Patients 

may present with symptoms such as, severe gastrointestinal irritation, nausea, vomiting 

(with fishy odor), chills, tightness of chest, difficulty in breathing and cough (from 

pulmonary edema). Development of the liver failure can cause jaundice and excessive 

hemorrhage. Delirium, convulsions and coma may result from renal tubular damage. 

Common cause of death is from ventricular arrhythmias and shock due to myocardial 

damage (Reigart J.R., 1999). 

HED previously reviewed Poison Control Center (PCC) data for residential exposure to 

rodenticides found that anticoagulant rodenticides are responsible for a large number of 

exposures (over 12,000 per year, 1993-96) in children under six years old, accounting for 20% of 
Page 5 of 27

all pesticide exposures. Fortunately, the majority of these exposures, 97%, do not result in 

significant symptoms base on those cases which received follow up to determine medical 

outcome. Compared to other types of pesticides, anticoagulants (including 1st and 2nd

generation) were the least likely to have symptomatic outcomes, accounting for only 2.65% of 

the total symptomatic cases due to all pesticides. Despite the relatively low number of 

symptomatic cases, anticoagulants are much more likely to receive medical treatment accounting 

for 41% of all pesticide-related cases seen in a health care facility and 15% of all hospitalized 

cases (Blondell 03/22/1999). A follow-up analysis analyzed incident reports primarily 

concerning children (Blondell and Spann, 06/03/1999, D256673). They addressed underreporting, finding that a number of surveys indicate that under-reporting of poisoning events to 

the AAPCC is significant; based on these studies, HED estimates that only a quarter of the total 

number of pesticide poisoning incidents are reported to the AAPCC or state counterparts. In 

2006, an updated review of rodenticides primarily concerning children (Hawkins and Allender, 

01/09/2006, D332563) and an addendum (Winfield, 05/08/2008, D332561) made the following 

summary findings: 

 The combination of 9-rodenticides (difenacoum was not included in this analysis) is 

below the composite of all pesticides in the production of symptoms, in the production of 

moderate symptoms and in the production of major symptoms. 

 The ratio of children seen in a Health Care Facility as a result of a potential exposure to 

the 9-rodenticides group is almost 26% higher than the composite of all pesticides. 

 No apparent annual trend is noticed in the 5 year-span for the 9-rodenticides group. 

 Brodifacoum contributes almost 80% of the total exposure cases of the group; this may 

be due to market share. 

III.DISCUSSION AND ANALYSIS 

The Agency generally relies on toxicity studies conducted on animals and exposure information 

relevant to the pesticide’s use pattern when registering a pesticide. After a pesticide is 

registered; however, human observational data about the effects and exposure of registered 

pesticides may be collected and analyzed. For this memorandum and review, human 

observational data, or incidents, from the following sources were analyzed: 

 summary data from the American Association of Poison Control Centers (AAPCC) 

 human incident (poisoning) data from OPP’s Incident Data System (IDS) database, 

 NIOSH Sentinel Event Notification System for Occupational Risks (SENSOR), 

 the Agency-sponsored National Pesticide Information Center (NPIC), 

 California’s Pesticide Incident Surveillance Program (PISP), and 

 open literature. 

Specifically, this review considers these different sources of human observational information at 

the request of the Environmental Protection Agency’s Office of Pesticide Programs’ Pesticide 

Re-evaluation Division in anticipation of one or more Notices of Intent to Cancel (NOIC). 
Page 6 of 27

A. Human Incident Data 

Incident information can provide important feedback to the Agency, assisting in 

determining actual real-world exposures and risks posed by pesticides/pesticide products. 

Incident data are collected systematically, but differently, across the different databases used by 

the Agency with respect to such issues as coverage, certainty/confidence, fields/parameters 

reported, and usability. The aforementioned five pesticide incident data sources (IDS, 

NIOSH/SENSOR, NPIC, California PISP, and AAPCC) were used in this report since they 

provide useful content and historical perspective. Various other comparable sources of data are 

available (e.g. the Bureau of Labor Statistics, emergency room outpatient surveillance, etc.) but 

are believed to be of limited additional utility and were not investigated. By looking across the 

five data sources which were used, the Agency is confident that we are able to consider adequate 

and appropriate information to discern trends and patterns in incident poisonings associated with 

the following rodenticides used for commensal rodent control in bait form: brodifacoum (PC 

Code 112701), bromadiolone (PC Code 112001), bromethalin (PC Code 112802), 

chlorophacinone (PC Code 067707), cholecalciferol (PC Code 802901), difenacoum (PC Code 

119901), difethialone (PC Code 128967), diphacinone (PC Code067701), diphacinone sodium 

salt (PC Code 067705), warfarin (PC Code086002), warfarin sodium salt (PC Code 086003), 

and zinc phosphide (PC Code 088601). 

1. American Association of Poison Control Centers (AAPCC) 

The American Association of Poison Control Centers (AAPCC) is a non-profit, national 

organization founded in 1958 that represents the poison control centers of the United States and 

the interests of poison prevention and treatment of poisoning. All of the calls to a poison control 

center are managed by a medical professional trained to answer questions about poisons. 

Additionally, AAPCC reports provide clearly summarized information on pesticide incidents 

within the context of other poisoning events. 

http://www.aapcc.org/dnn/NPDSPoisonData/NPDSAnnualReports.aspx

AAPCC produces an annual summary report giving statistics and information on all the 

poisonings reported to PCCs in a calendar year. The AAPCC annual summary data break down 

the incident data in terms of rodenticides2

. The Agency examined the rodenticide data from 

1999 to 2009, and found that an average of 17,000 exposures were reported each year and 

approximately 5000 of these were treated in a health care facility each year. Approximately 85% 

(~15,000 per year) of these 17,000 exposures occurred to children under 6 years old over the 11 

year period analyzed (Figure 1). 

 

 

2 Note that in AAPCC rodenticides include the following categories/pesticides: ANTU, bromethalin, cholecalciferol, cyanide, 

long-acting anticoagulant(2nd generation anticoagulants), other, PNU, sodium monofluroacetate, strychnine, unknown, warfarintype anticoagulant (1st generation anticoagulants), and zinc phosphide.
Page 7 of 27

Figure 1: AAPCC Rodenticide Incidents over Time (1999-2009) 

The Agency further examined the AAPCC rodenticide incidents with known exposure outcomes. 

Known exposures are categorized as follows: 

 Death, 

 Major - symptoms are life-threatening or result in residual disability or disfigurement 

(coma, cardiovascular instability, repeated seizures), 

 Moderate – symptoms are more pronounced, prolonged, or more of a systemic nature 

than minor symptoms with no residual disability. Usually some form or treatment is 

indicated (high fever, disorientation), 

 Minor – symptoms are minimal with no residual disability (skin irritation, drowsiness, 

mild gastrointestinal symptoms), or 

 None – patient developed no symptoms as a result of exposure. 

Approximately 78,000 of the rodenticide related calls received over the 11 year period had a 

known outcome. The Agency found that 92% of these calls reported no symptoms as a result of 

0

5000

10000

15000

20000

25000

Treated in HCF

Number of incidents or outcomes

with known exposures (includes

none, minor, moderate, major, and

death)

exposures to kids <6

sum of single substance exposure
Page 8 of 27

the rodenticide exposure (figure 2) 3. Further, when compared to other types of pesticides, 

rodenticides were the least likely to have symptomatic outcomes, accounting for only 2% of the 

total symptomatic cases due to all pesticides from 1999-2009. 

Figure 2: AAPCC Incidents Followed to Known Health Outcomes from 1999 to 2009 

Preponderance of exposure to children 

The AAPCC incidents from 1999-2009, were further analyzed with respect to child exposure. 

The Agency found that insecticides are responsible for more total incidents and incidents to 

children less than six years of age than other pesticide classes. However, the ratio of incidents to 

children under six years of age to total incidents per pesticide classifications is highest for 

rodenticides than the other pesticide classes (Table 1, Figure 3). Approximately 16% of all 

reported exposures to pesticides are due to rodenticide exposures and 26% of all reported 

pesticide-related exposures to children under 6 are due to rodenticide exposures. In addition, 

approximately 25% of all pesticide-related cases seen in a health care facility were related to 

rodenticide exposures. 

 

3

 These calls include all age groups and are inclusive of attempted suicides and malicious intent cases. 

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Sum of  Death 43554141314

Sum of Major 55 66 41 64 39 43 49 22 22 28 22

Sum of Moderate 117 154 131 176 176 166 158 105 123 65 74

Sum of Minor 317 316 333 425 400 352 341 237 252 262 236

Sum of None 7773 6776 6309 6751 6348 6078 5721 4761 4460 4207 4233

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

Incident Count
Page 9 of 27

Table 1. Ratio of Exposures to Children <6 years old to Sum of Single Exposures per Pesticide Category in 

AAPCC from 1999-2009 

Pesticide Category % Exposures 

to Children 

Exposures to 

Children <6 

years old 

Total 

Exposures 

disinfectants 55% 122,868 224,578 

fungicides 25% 3,593 14,308 

herbicides 26% 26,774 101,832 

insecticides 41% 192,745 474,149 

organophosphates 29% 24,877 84,931 

other pesticides 65% 98,309 150,196 

rodenticides 85% 166,250 195,263 

Figure 3: Ratio of Exposed Children Less Than 6 Years Old to Sum of Single Exposures per Pesticide 

Category (1999-2009). 

More detailed analysis of AAPCC raw data from 1999 to 2005 of the children’s exposures, 

demonstrates that an average of 3686 (or 26%) children less than 6 years old exposed to 

rodenticides were treated/evaluated and released at a health care facility or admitted to a noncritical care unit per year as a result rodenticide exposure. The analysis also demonstrates that an 

average of 128 cases per year (or 1%) of the exposures to children result in a medical outcome 

classified by the AAPCC as minor, moderate or major (Table 2). In addition, of all pesticiderelated cases involving children less than 6 years old, approximately 39% of those seen in a 

health care facility are related to rodenticide exposure and 13% of hospitalization cases are 

related to rodenticide exposure. Further, no deaths to children are reported. 

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Ratio of Children <6 Years Old to Total Single

Substance Exposures

Year

disinfectants

fungicides

herbicides

Insecticides ‐ other

organophosphates

pesticides ‐ other

rodenticides
Page 10 of 27

Table 2: 1999-2005 Pesticide vs. Rodenticide Comparison of Cases to Children <6 Years Old. 

Exposure Outcome

Rodenticides All Pesticides 

(% of Total) (% of Total) 

None 35% 29% 

Minor 1% 11% 

Moderate 0.1% 1% 

Major 0.02% 0.07% 

All Symptomatic 1% 12% 

Healthcare 

Any Level of Care 26% 14% 

Admitted to ICU 0.1% 0.2% 

Nevertheless, severe outcomes from human exposures to rodenticides do occur. From 1999-

2005, 894 cases were reported having minor, moderate, or major effects. For cases reporting 

moderate or major effects, the most common effect reported was hematological, 37% and 55% 

respectively (Table 3). These symptoms are likely a result from anticoagulant rodenticides’ 

abilities to interfere with blood clotting and are likely the result of rodenticide exposure. 

Table 3. AAPCC Reported Exposure Symptoms for Symptomatic Children Less Than 6 Exposed to 

Rodenticide from 1999- 2005 

 Level of 

Effect 

 

Total 

Exposures 

Reported Exposure Symptoms* 

Neurological Ocular Renal Respiratory Misc. Cardio Dermal GI Hematological 

Minor 

effect 727 15 (2%) 17 (2%) 0 20 (3%) 180 (25%) 0 18 (2%) 

277 

(38%) 36(5%) 

Moderate 

effect 147 7 (5%) 1 (1%) 4 (3%) 2 (1%) 22 (15%) 0 8 (5%) 

34 

(23%) 55 (37%) 

Major 

effect 20 1 (5%) 0 0 2 (10%) 5 (25%) 0 2 (10%) 

4 

(20%) 11 (55%) 

* The categories are not mutually exclusive (i.e. a person could report both a neurological and renal symptom) 

2. OPP Incident Data System (IDS) 

The OPP IDS includes reports of alleged human health incidents from various sources, including 

mandatory Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Section 6 (a) (2) reports 

from registrants and reports from other federal and state health and environmental agencies and 

individual consumers. Since 1992, OPP has compiled these reports in IDS. IDS contain reports 

from across the U.S. and most incidents contained in the system have all relevant product 

information recorded. Case reports or “narratives” are provided for each incident, with varying 

levels of detail; however, there is no effort at validating or assessing how likely it is that the 

reported exposure is causally related to the reported outcome. Because IDS has such extensive 

coverage, it is useful for providing temporal trend information and determining whether risk 

mitigation has helped reduce potential pesticide exposure and decreased the number of potential 

incidents reported to IDS. 

For this evaluation, the OPP IDS was utilized for pesticide incident data on the following 

rodenticide active ingredients: brodifacoum (PC Code 112701), bromadiolone (PC Code 
Page 11 of 27

112001), bromethalin (PC Code 112802), chlorophacinone (PC Code 067707), cholecalciferol 

(PC Code 802901), difenacoum (PC Code 119901), difethialone (PC Code 128967), diphacinone 

(PC Code 067701), diphacinone sodium salt (PC Code 067705), warfarin (PC Code 086002), 

warfarin sodium salt (PC Code 086003), and zinc phosphide (PC Code 088601). This database 

search was done to identify the frequency and severity of the health effects as well as potential 

patterns and trends attributed to exposures from rodenticides formulated as baits used for control 

of commensal rodents. Reports submitted to the IDS represent anecdotal reports or allegations 

only, and are not necessarily confirmed, validated, or investigated by medical professionals 

unless otherwise stated in the report. 

IDS consists of two separate modules: Main IDS and Aggregate IDS. Because of the reporting 

requirements, IDS records incidents resulting in higher severity outcomes in the Main IDS 

module. However, there are some less severe incidents (i.e., HD and HE) that have been 

submitted to OPP as reports, and therefore, these are captured in Main IDS. 

The higher severity outcomes include: 

 H-A (death): If the person died; 

 H-B (major): If the person alleged or exhibited symptoms which may have been lifethreatening, or resulted in adverse reproductive effects or in residual disability; and 

 H-C (moderate): If the person alleged or exhibited symptoms more pronounced, more 

prolonged or of a more systemic nature than minor symptoms, usually some form of 

treatment of the person would have been indicated, symptoms were not life threatening 

and the person has returned to his/her pre-exposure state of health with no additional 

residual disability. 

This system stores incident data for death (HA) and major (HB) and moderate (HC) incidents, 

and it includes more details about the location, date and nature of the incident. Main IDS 

incidents involving only one pesticide are considered to provide more certain information about 

the potential effects of exposure from the pesticide, and therefore these incidents are reviewed 

individually in this assessment. When an incident involves more than one pesticide, it is difficult 

to determine which effects are attributed to the pesticide being considered. 

IDS records the less severe human incidents that are reported by registrants as counts in the 

Aggregate IDS module. The less severe human incidents include: 

 H-D (minor): If the person alleged or exhibited some symptoms, but they were minimally 

traumatic, the symptoms resolved rapidly and usually involve skin, eye or respiratory 

irritation; and 

 H-E/H (unknown or no effects): If symptoms are unknown, unspecified or are alleged to 

be of a delayed or chronic nature that may appear in the future. 

In Aggregate IDS, queried from January 1, 1999, to December 31, 2009, there are 1218 incident 

involving rodenticides (1126 HDs and 92 HEs)4

. Because it falls within the categories reported 

as counts (which includes minor, unknown or no effects), there is no unique report that provides 

details about the incident and single chemical incidents are not distinguished from multiple 

 

4 There were no incidents reported for the active ingredient warfarin sodium salt in Aggregate IDS. Note: there was only one 

warfarin sodium salt product registered during the period of 1995-2009.
Page 12 of 27

chemical incidents; however, a high frequency of incidents indicates there is a high potential for 

exposure and vice versa. 

For the Main IDS, queried from January 1, 1999 to December 31, 2009, there are 321 cases 

reported that involve the rodenticide active ingredients listed above. Of these 321 cases, there 

are 304 cases reported that involve exposure to a single rodenticide chemical in the database. 

There were no incidents reported for the new active ingredient difenacoum. These incidents 

were mostly (267 incidents) categorized as HCs (Human Moderates); however, there are six 

incidents categorized as HA (deaths) and 22 incidents categorized as HBs (Human Majors), five 

incidents categorized as HD (minor) and five incidents categorized as HE/H (unknown or no 

effects) (Figure 4). The HAs and HBs appear to be occurring to adults mostly due to ingestion, 

either because of suicide attempts (13 incidents or 46%) or suspected malicious intent (i.e., 

intentional poisonings) (6 incidents or 21%). Other deaths (HAs) and majors (HBs) are due do 

unintentionally ingestions (1 incident), unknown suspected exposures (2 incidents), applicator 

exposure (3 incidents), post application exposure to tracking powder (2 incident), and intentional 

ingestion (1 incident). 

Figure 4: Main IDS Incidents for Rodenticides over Time by Severity 

Figure 5 shows the incident counts for both Main and Aggregate IDS reported for the commensal 

rodenticides by classification (i.e., non-anticoagulant, 1st generation anticoagulant, or 2nd

generation anticoagulant) from 1999 to 2009. Over that 11 year period, non-anticoagulant and 

0

5

10

15

20

25

30

35

40

Incident Count

Year

Sum of H

Sum of HA

Sum of HB

Sum of HC

Sum of HD

Sum of HE
Page 13 of 27

1st generation anticoagulant rodenticide incidents appear to be steady over time, while 2nd

generation anticoagulant rodenticide incidents appear to have been increasing coming to a peak 

in 2008, and decreasing in 2009. 

Figure 5: Main and Aggregate IDS Incidents for Rodenticides over Time by Classification 

Of the rodenticide active ingredients queried in Main and Aggregate IDS, brodifacoum accounts 

for the most incidents (41%), followed by bromadiolone and bromethalin which account for 22% 

and 12%, respectively (Table 4). The deaths (HAs) and majors (HBs) appear to be occurring to 

adults mostly due to ingestion, either because of suicide attempts (15 incidents or 52%) or 

suspected malicious intent (6 incidents or 21%). 

 

0

20

40

60

80

100

120

140

160

180

200

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Incident Count

Year

1st Generation

2nd Generation

Non‐Anticoagulants
Page 14 of 27

Table 4: Rodenticides Ranked by Total Exposure Count from Main and Aggregate IDS 

Rodenticide % of incidents in IDS # of incidents in IDS # of HAs (Deaths) 

and HBs (Majors) 

Brodifacoum 41% 434 2 HAs(both malicious 

intent), 15 HBs (10 

were suicide attempts 

and 1 malicious intent)

Bromadiolone 22% 230 - 

Bromethalin 12% 129 3 HBs (1 case 

malicious intent, 1 

case suicide attempt) 

Diphacinone 12% 124 2 HAs (1 malicious 

intent) 

Zinc phosphide 6% 65 1 HA, 3HBs (2 cases 

were suicide attempts) 

Warfarin 

3% 28 1 HA (suicide), 1 HB 

(malicious intent) 

Difethialone 2% 25 - 

Diphacinone, sodium salt 1% 10 - 

cholecalciferol 1% 10 - 

chlorophacinone 0.3% 3 - 

Warfarin, sodium salt 0.1% 1 1 HB (suicide attempt) 

Difenacoum 0.1% 1 - 

- has no HA (deaths) or HBs (majors) associated with this chemical in IDS. 

Of the rodenticide active ingredients queried in Main and Aggregate IDS, the products associated 

with the most incidents were D-CON MOUSE PRUFE II (Reg. No. 003282-00065) (320 

incidents or 20%), followed by D-CON READY MIXED GENERATION II (Reg. No 003282-

00081) (116 incidents or 7%), and CONTRAC ALL-WEATHER BLOX (Reg. No. 012455-

00079-003240) (98 incidents or 6%). The deaths (HAs) and majors (HBs) appear to be 

occurring to adults mostly due to ingestion, either due to suicide attempts (13 incidents or 46%) 

or suspected malicious intent (i.e., intentional poisonings) (6 incidents or 21%) (Table 5). 

Table 5: Rodenticide Products Ranked by Total Exposure Count from Main and Aggregate IDS 

Registration 

Number 

Sum of 

Exposure 

Count 

# of HAs (Deaths) 

Product Name and HBs (Majors) Active 

Ingredient 

Rodenticide 

Type 

003282-

00065* D-CON MOUSE PRUFE II Brodifacoum 2nd Generation 320 

1 HA (malicious 

intent), and 6 HBs 

(5 cases suicide 

attempts) 

003282-

00081* 

D-CON READY MIXED 

GENERATION II Brodifacoum 2nd Generation 116 1HB (malicious intent) 

012455-

00079-

003240 

CONTRAC ALLWEATHER BLOX Bromadiolone 2nd Generation 98 - 

000270-

00373 

BROMADIOLONE BAIT 

BAR Bromadiolone 2nd Generation 71 - 
Page 15 of 27

Registration 

Number 

Sum of 

Exposure 

Count 

# of HAs (Deaths) 

Product Name and HBs (Majors) Active 

Ingredient 

Rodenticide 

Type 

012455-

00069-

003240 

CONTRAC RODENTICIDE Bromadiolone 2nd Generation 60 - 

003282-

00066* 

D-CON PELLETS 

GENERATION II Brodifacoum 2nd Generation 56 1 HB (suicide attempt) 

003282-

00074* D-CON BAIT PELLETS II Brodifacoum 2nd Generation 55 1 HB (suicide attempt) 

012455-

00086-

003240 

CONTRAC RODENTICIDE 

PLACE PAC Bromadiolone 2nd Generation 49 - 

067517-

00066-

000478 

ASSAULT ALL WEATHER 

BAIT Bromethalin NonAnticoagulant 46 - 

000270-

00372 

BROMADIOLONE BAIT 

PELLETS Bromadiolone 2nd Generation 35 - 

008845-

00127* 

HOT SHOT SUDDEN 

DEATH BRAND MOUSE 

AND RAT KILLER 

Bromethalin NonAnticoagulant 34 1 HB 

061282-

00046 RAMIK GREEN Diphacinone 1st Generation 29 1 HA (malicious 

intent) 

000100-

01056 

HAVOC RODENTICIDE 

BAIT PACK PELLETS 

WITH BITREX 

Brodifacoum 2nd Generation 22 - 

008845-

00125* 

HOT SHOT SUDDEN 

DEATH BRAND MOUSE 

KILLER 

Bromethalin NonAnticoagulant 22 - 

012455-

00016 ZP TRACKING POWDER Zinc phosphide NonAnticoagulant 22 1 HB 

067517-

00071-

000478 

ASSAULT MOUSE/RAT 

PELLETS Bromethalin NonAnticoagulant 17 1 HB (malicious 

intent) 

012455-

00076 

CONTRAC RODENTICIDE 

READY TO USE PLACE 

PAC 

Bromadiolone 2nd Generation 16 - 

012455-

00075 

CONTRAC RAT AND 

MOUSE BAIT READY TO 

USE PLACE PACS 

Bromadiolone 2nd Generation 15 - 
Page 16 of 27

Registration 

Number 

Sum of 

Exposure 

Count 

# of HAs (Deaths) 

Product Name and HBs (Majors) Active 

Ingredient 

Rodenticide 

Type 

012455-

00056 

DITRAC TRACKING 

POWDER Diphacinone 1st Generation 14 

1 HA (suspected 

exposure to 

product) 

003282-

00009* 

D-CON MOUSE PRUFE 

KILLS MICE Warfarin 1st Generation 13 - 

012455-

00079 

CONTRAC ALLWEATHER BLOX Bromadiolone 2nd Generation 11 - 

012455-

00018-

003240 

ZP POCKET GOPHER 

BAIT Zinc phosphide NonAnticoagulant 11 - 

000100-

01056-

061282 

HAVOC RODENTICIDE 

BAIT PACK PELLETS 

WITH BITREX 

Brodifacoum 2nd Generation 10 - 

061282-

00023 

RAMIK GREEN MINI 

BAIT PACKS Diphacinone 1st Generation 10 - 

- has no HA (deaths) or HBs (majors) associated with it in IDS. 

*products that are on the cancellation list 

3. National Pesticide Information Center (NPIC) 

NPIC is a cooperative effort between Oregon State University and EPA which is funded by EPA 

to serve as a source of objective, science-based pesticide information and respond to inquiries 

from the public and to incidents. NPIC functions nationally during weekday business hours 

through a toll-free telephone number in addition to the internet (www.npic.orst.edu) and email. 

Similar to Poison Control Centers, NPIC’s primary purpose is not to collect incident data, but 

rather to provide information to inquirers on a wide range of pesticide topics, and direct callers 

for pesticide incident investigation and emergency treatment. NPIC receives approximately 

25,000 calls per year, with about 4000 of these being incidents. NPIC collects the information 

about the incidents and records that information in a database. NPIC is a source of national 

incident information, but generally receives fewer reports than IDS. Regardless, NPIC can 

provide an additional source of incident information. 

Unlike IDS, incidents reported to NPIC are assigned a certainty classification, which helps 

ascertain whether the exposure and reported outcome are related. However, NPIC has only 

recently begun recording a severity classification (i.e., whether the outcome was severe or 

minor). Of all the rodenticide human incidents, only 27 included severity classifications 

(“minor,” “moderate,” and “asymptomatic”) and therefore the rodenticides are not sorted 

according to fatality count or hazard factor as done for IDS. Table 6 depicts the breakdown of 

reported rodenticide human incidents by Certainty Index classification for the time period 1999-

2010. Although a majority of the incidents were considered “unclassifiable,” they were 
Page 17 of 27

considered in this review. This is consistent with the review of IDS incidents, which are not 

classified according to their certainty. 

Table 6: NPIC – Rodenticide Human Exposures Incidents, by Certainty Index 

Certainty Index Exposure Count 

Probable 1 

Possible 9 

Unlikely 31 

Unclassifiable 165 

For NPIC from 2005 to 2010, there were 1527 total calls regarding rodenticides received by 

NPIC in the database. Of these total calls, 204 were incidents, 2 were suspected incidents and 

1321 (or 87%) were information calls. Of the rodenticides queried in the NPIC database, zinc 

phosphide accounts for the most calls, 50%, and most incidents, 39% (Table 7). There were no 

calls in the NPIC database regarding diphacinone sodium salt or warfarin sodium salt. The 

Agency examined the calls to NPIC regarding rodenticides and found that they have declined 

from 2005 to 2010 by about 60% (Table 8). The rodenticide related incidents reported to NPIC 

were due primarily to misuse that included, but were not limited to, the following scenarios: 

child accidental contact; child ingestion or suspected ingestion; adult accidental ingestion; adult 

contact; malicious intent; suicide attempts; and inquiries about the safety of eating food from a 

garden after a rodenticide had been used in or near the garden.5

 

Table 7: Rodenticides Ranked by Calls to NPIC from 2005-2010 

Rodenticide Incident Suspected 

Incident Information Grand Total 

% of calls 

to PCC 

ZINC PHOSPHIDE 80 1 689 770 50 

BROMADIOLONE 27 - 223 250 16 

DIPHACINONE 21 1 124 146 10 

BROMETHALIN 14 - 100 114 7 

CHLOROPHACINONE 21 - 50 71 5 

WARFARIN 28 - 35 63 4 

BRODIFACOUM 9 - 52 61 4 

DIFETHIALONE 4 - 40 44 3 

CHOLECALCIFEROL - - 6 6 0.4 

DIFENACOUM - - 2 2 0.1 

 

 

5

 The inquiries regarding safety of eating food from a garden after a rodenticide had been used in or near the garden 

were classified by NPIC as incidents; however, the narrative suggests that these may also be interpreted as 

informational calls. Use in this manner is a misuse. 
Page 18 of 27

Table 8: Rodenticide Calls to NPIC by Year from 2005 to 2010 

Year Incident Suspected Incident Information Grand Total 

2005 38 1 318 357 

2006 55 - 306 361 

2007 31 - 246 277 

2008 41 1 191 233 

2009 - - 153 153 

2010 39 - 107 146 

Grand Total 204 2 1321 1527 

4. NIOSH Sentinel Event Notification System for Occupational Risks (SENSOR) 

The NIOSH SENSOR database covers 12 states from 1998-2006, although reporting varies from 

state to state. Pesticide-related incidents are collected from Department of Labor workers’ 

compensation claims when reported by physicians, reports from State Departments of 

Agriculture, from poison control centers and from State Departments of Health based on reports 

by physicians suspecting pesticide exposure, so each call in the SENSOR database is likely to 

correspond to an exposure incident. Although both occupational and non-occupational incidents 

are included in the database, the data in SENSOR are predominately occupational incidents, and 

is of particular value in providing that information. A state SENSOR contact specialist performs 

follow-up with workers and obtains medical records to verify symptoms, circumstances 

surrounding the exposure, severity, and outcome. Using standardized protocol and case 

definitions, SENSOR coordinators at State Departments of Health enter the incident interview 

description provided by the medical report, physician and patient into the SENSOR data system, 

accessible to participating states and EPA. In-depth investigations for case confirmation are 

performed giving the Agency high confidence in the information provided. The ability to detect 

trends over time for SENSOR data is limited due to a generally small number of incidents and 

varying degrees with which the states track incidents. 

http://www.cdc.gov/niosh/topics/pesticides/overview.html

There were 50 rodenticide incidents reported to NIOSH SENSOR from 1998-2006. Of these, 

there was one death (no details available), two were classified high severity, 12 were classified 

as moderate severity and 28 were classified as low severity and there were 7 with unknown 

severity. Of these 50 incidents, 17 incidents included narratives containing details about those 

incidents. Six incidents were unintentional occupational exposures in the workplace, six 

incidents were suicide attempts by adults, two incidents were accidental ingestion by children 

and three incidents were suspected ingestions by children found near rodenticide baits. Of the 

rodenticides queried in the SENSOR database, brodifacoum accounts for the most incidents, 

28% (Table 9). 

 
Page 19 of 27

Table 9: Rodenticide Ranked Calls to SENSOR from 1998-2006 

Rodenticide % of calls to SENSOR # of calls to SENSOR 

Brodifacoum 28% 14 

Warfarin 26% 13 

Chlorphacinone 16% 8 

Zinc Phosphide 12% 6 

Diphacinone, Sodium Salt 8% 4 

Bromadiolone 6% 3 

Diphacinone 2% 1 

Warfarin, Sodium Salt 2% 1 

5. California Pesticide Illness Surveillance Program (PISP) Incident Data 

The Pesticide Illness Surveillance Program (PISP) maintains a database of pesticide-related 

illnesses and injuries. Case reports are received from physicians and via workers’ compensation 

records. The local County Agricultural Commissioner investigates circumstances of exposure. 

Medical records and investigative findings are then evaluated by DPR technical experts and 

entered into an illness registry. 

PISP contains both residential and occupational pesticide incidents. PISP has limited coverage 

(only California) and is not particularly useful for trend over time information. However, the 

incident information is entered by professionals with expertise in pesticides, with extensive 

follow-up on each reported case so there is a high level of confidence in the information 

provided for each reported incident. http://www.cdpr.ca.gov/docs/whs/pisp.htm

Sixteen incidents that are attributable to rodenticide exposures were reported to the California 

Pesticide Illness Surveillance Program between 2004 and 2008. These exposures included three 

accidental exposures to adults (through contact while applying), three exposures to children 

ingesting products used in home by parents, one exposure was due to an outdoor product being 

used indoors, and nine suicide attempts. 

IV. LITERATURE REVIEW 

The available literature agrees that accidental ingestion of anticoagulant rodenticides is occurring 

to children. Many of these sources agree that these child exposures can be managed with home 

observation. Caravati et al. (2007) developed a guideline to assist poison control center 

personnel in the out-of-hospital triage and initial management of patient with suspected exposure 

to SGARs. They analyzed AAPCC data from 2000 to 2003, and found that 0.7% of 

unintentional ingestions of SGARs, for all reported ages, were classified as having moderate or 

major effects or death. They recommend that patients with unintentional ingestion of less than 1 

mg of SGAR active ingredient (which includes practically all unintentional ingestions in children 

less than 6 years of age) can be safely observed at home without laboratory monitoring. 

However, they also recommend that symptomatic patients (i.e. experiencing bruising or 

bleeding) with unintentional ingestion of SGAR should “refer to the emergency department 

immediately.” Mullins et al. (2000) conducted a retrospective review of poison center charts 

involving pediatric SGAR exposures occurring in two 2-year periods. They found that although 

some children had slightly elevated prothrombin times, none required or received vitamin K or 
Page 20 of 27

experienced any bleeding. They, similarly, concluded that normal preschool-aged children with 

unintentional acute exposures to SGAR rodenticides do not require any routine follow-up 

laboratory studies and do not require medical intervention. Bartlett (2003) also concluded, in 

his review of nondrug substances that cause harm, that the vast majority of rodenticides in use at 

that time were anticoagulant products and, unless large amounts are ingested, these rodenticides 

have shown to be relatively harmless. Shepherd et al. (2002) characterized the toxicity from 

single, acute brodifacoum ingestions in young children and evaluated the utility of 

gastrointestinal decontamination in preventing toxicity. They found that acute pediatric 

ingestions of brodifacoum rarely caused clinical effects and were not associated with lifethreatening symptoms or death in young children. They conclude that “it seems reasonable that 

acute unintentional ingestion of small quantities of brodifacoum by young children can be 

adequately managed with home observation and parent education.” 

Kendrick (2006) found that studies with in the last five years show that most unintentional 

SGAR ingestions can be managed at home with close outpatient follow-up, but concludes that 

the placement of rodenticide baits make accidental ingestion by children a realistic concern. 

Badakhs et al (2010) analyzed data from the Louisiana Hospital Inpatient Discharge Database 

from 1998 through 2007 to characterize hospitalizations involving pesticides. They found that 

while only six percent of the cases in the final dataset of pesticide-related hospitalizations were 

due to rodenticides, children had a significantly higher rate of rodenticide exposure than adults 

(i.e., 14% of the pesticide-related children hospitalizations involved rodenticide exposure vs. 2% 

of the pesticide-related adult hospitalizations involved rodenticide exposure). The majority of 

the rodenticide hospitalizations (64%) occurred to very young children (ages 0 to 4 years old). 

They conclude that rodenticide pellets being placed in areas accessible to children coupled with 

the hand-to-mouth behavior of young children and their accidental contact with household 

pesticides are reflected in the elevated children’s exposure rates. Further, the trend observed 

among young children reinforces the importance of protecting children from exposures to 

potentially hazardous products such as rodenticides. 

V. DISCUSSION AND CONCLUSION 

When looking across human incident data sources, as well as the open literature, rodenticides are 

found to be involved in numerous incidents, especially involving children less than 6 years old. 

These exposures to children are especially evident in the analysis of the AAPCC data which 

showed an average of 15,000 exposures per year occur to children under 6 years old from 1999 

to 2009. While exposures generally result in no clinical harm to children, the resulting human 

exposures to rodenticides have the potential to result in severe outcomes and/or medical care. 

According to AAPCC data from 1999-2005, even though only 1% of the children less than 6 

years old were symptomatic as a result of rodenticide exposure, 25% sought treatment in a health 

care facility. The Agency believes that the number of non-symptomatic exposure incidents is 

unacceptably high because of the social costs associated with evaluating and treating children 

who might have been exposed. 

Almost all incidents occurring due to rodenticide exposure are the result of label directions, to 

keep bait away from children, pets and non-target wildlife, not being followed. Despite label 
Page 21 of 27

directions stating “apply bait out of the reach of children,” exposures to children are happening, 

even in cases where users are attempting to comply. This may be due to the size, shape and 

placement of rodenticide baits, such that they are easily accessed and handled by children, in 

combination with the hand-to-mouth behaviors of small children. Additionally, review of 

available exposure information from IDS, NPIC, NIOSH SENSOR, and CA PISP, suggests that 

children appear to gain access to baits placed in homes because 1) parents underestimate places 

their children are capable of accessing and 2) children visit a different environment (such as 

grandparents, friends, neighbor’s) and their parent or guardian is unaware that the baits are 

accessible. 

Subsequently, it follows that the RMD proposal (containing rodenticides in bait stations that are 

tamper-resistant) may mitigate child incidents involving rodenticides. 

 
Page 22 of 27

VI. REFERENCES: 

BARTLETT, D. 2003. Dangerous in Small Amounts: Ten Nondrug Substances That Cause 

Harm. Journal of Emergency Nursing, 29, 377-9. 

BATTEN, P. & BRATT, H. 1990. Brodifacoum: elimination from the tissues of rats following 

administration of single oral doses. Unpubl. report submitted to EPA by ICI Americas, 

Inc., Wilmington, DE. 65 pp. 

BRONSTEIN, A. C., SPYKER, D. A., CANTILENA, L. R., JR., GREEN, J., RUMACK, B. 

 H. & HEARD, S. E. 2007. 2006 Annual Report of the American Association of Poison 

Control Centers' National Poison Data System (NPDS). Clinical Toxicology, 45, 815-

917. 

BRONSTEIN, A. C., SPYKER, D. A., CANTILENA, L. R., JR., GREEN, J. L., RUMACK, 

 B. H. & GIFFIN, S. L. 2009. 2008 Annual Report of the American Association of Poison 

 Control Centers' National Poison Data System (NPDS): 26th Annual Report. Clinical 

 Toxicology, 47, 911-1084. 

BRONSTEIN, A. C., SPYKER, D. A., CANTILENA, L. R., JR., GREEN, J. L., RUMACK, B. 

H. & GIFFIN, S. L. 2010. 2009 Annual Report of the American Association of Poison 

Control Centers' National Poison Data System (NPDS): 27th Annual Report. Clinical 

Toxicology, 48, 979-1178. 

BRONSTEIN, A. C., SPYKER, D. A., CANTILENA, L. R., JR., GREEN, J. L., RUMACK, B. 

H. & HEARD, S. E. 2008. 2007 Annual Report of the American Association of Poison 

Control Centers' National Poison Data System (NPDS): 25th Annual Report. Clinical 

Toxicology, 46, 927-1057. 

CARAVATI, E. M., ERDMAN, A. R., SCHARMAN, E. J., WOOLF, A. D., CHYKA, P. A., 

COBAUGH, D. J., WAX, P. M., MANOGUERRA, A. S., CHRISTIANSON, G., 

NELSON, L. S., OLSON, K. R., BOOZE, L. L. & TROUTMAN, W. G. 2007. Longacting anticoagulant rodenticide poisoning: An evidence-based consensus guideline for 

out-of-hospital management. Clinical Toxicology, 45, 1-22. 

CHAVHAN, S. G., BRAR, R. S., BANGA, H. S. & N D, S. 2011. Cholecalciferol (Vitamin D3) 

Toxicity in Animals. IPJ-Online, 3, 54-58. 

KENDRICK, D. B. 2006. Mosquito repellents and superwarfarin rodenticides - are they 

really toxic in children? Current Opinion in Pediatrics, 18, 180-183. 

LAI, M. W., KLEIN-SCHWARTZ, W., RODGERS, G. C., ABRAMS, J. Y., HABER, D. A., 

BRONSTEIN, A. C. & WRUK, K. M. 2006. 2005 Annual Report of the American 

Association of Poison Control Centers' National Poisoning and Exposure Database. 

Clinical Toxicology, 44, 803-932. 

LITOVITZ, T. L., KLEIN-SCHWARTZ, W., RODGERS, G. C., COBAUGH, D. J., 
Page 23 of 27

YOUNISS, J., OMSLAER, J. C., MAY, M. E., WOOLF, A. D. & BENSON, B. E. 2002. 

2001 Annual Report of the American Association of Poison Control Centers Toxic 

Exposure Surveillance System. American Journal of Emergency Medicine, 20, 391-452. 

LITOVITZ, T. L., KLEIN-SCHWARTZ, W., WHITE, S., COBAUGH, D. J., YOUNISS, J., 

DRAB, A. & BENSON, B. E. 2000. 1999 Annual Report of the American Association of 

Poison Control Centers Toxic Exposure Surveillance System. American Journal of 

Emergency Medicine, 18, 517-574. 

LITOVITZ, T. L., KLEIN-SCHWARTZ, W., WHITE, S., COBAUGH, D. J., YOUNISS, J., 

OMSLAER, J. C., DRAB, A. & BENSON, B. E. 2001. 2000 Annual Report of the 

American Association of Poison Control Centers Toxic Exposure Surveillance System. 

American Journal of Emergency Medicine, 19, 337-395. 

MULLINS, M. E., BRANDS, C. L. & DAYA, M. R. 2000. Unintentional pediatric 

superwarfarin exposures: Do we really need a prothrombin time? Pediatrics, 105, 402-

404. 

NELSON, L., LEWIN, N., HOWLAND, M. A., HOFFMAN, R., GOLDFRANK, L. & 

FLOMENBAUM, N. 2010. Goldfrank’s Toxicologic Emergencies, The McGraw-Hill 

Companies. 

PERRY, H. E. 2007. Rodenticides. In: SHANNON, M. W., BURNS, M. & BORRON, S. 

W. (eds.) Haddad and Winchester’s Clinical Management of Poisoning and Drug 

Overdose. 4th ed.: Elsevier Health Sciences. 

REIGART, J. R. & ROBERTS, J. R. 1999. Rodenticides. Recognition and Management of 

Pesticide Poisonings. 5th ed.: U.S. Environmental Protection Agency. 

SHEPHERD, G., KLEIN-SCHWARTZ, W. & ANDERSON, B. D. 2002. Acute, 

unintentional pediatric brodifacoum ingestions. Pediatric Emergency Care, 18, 174-178. 

WATSON, W. A., LITOVITZ, T. L., KLEIN-SCHWARTZ, W., RODGERS, G. C., 

YOUNISS, J., REID, N., ROUSE, W. G., REMBERT, R. S. & BORYS, D. 2004. 2003 

Annual Report of the American Association of Poison Control Centers Toxic Exposure 

Surveillance System. American Journal of Emergency Medicine, 22, 335-404. 

WATSON, W. A., LITOVITZ, T. L., RODGERS, G. C., KLEIN-SCHWARTZ, W., REID, 

N., YOUNISS, J., FLANAGAN, A. & WRUK, K. M. 2005. 2004 Annual Report of the 

American Association of Poison Control Centers Toxic Exposure Surveillance System. 

American Journal of Emergency Medicine, 23, 589-666. 

WATSON, W. A., LITOVITZ, T. L., RODGERS, G. C., KLEIN-SCHWARTZ, W., 

YOUNISS, J., ROSE, S. R., BORYS, D. & MAY, M. E. 2003. 2002 annual report of the 

American Association of Poison Control Centers Toxic Exposure Surveillance System. 

American Journal of Emergency Medicine, 21, 353-421. 
Page 24 of 27

Appendix A Table A1: Incident Data System (IDS) Summary of Human Deaths (HAs) and Human Majors (HBs) from 1999-

Incident Package Report

Incident Date Location

Reg. Number Product Name PC Code

Ingredient Name

Exposure Type Inc

008626 - 00003 3/18/1999 

BICENTENNIAL, CA 

003282-00065 

D-CON MOUSE PRUFE II 112701 Brodifacoum HB A 2

008701 - 00001 4/13/1999 ATLANTA, GA 

012455-00016 

ZP TRACKING POWDER (4 OZ., 1.1 & 25 LB.) 088601 

Zinc phosphide HB 

A 7traon camoabJapprofibplaincHe pu

009738 - 00001 12/1/1999 

LINCHBURG, TN 

HAVOC RODENTICIDE BAIT PACK 112701 Brodifacoum HB 

A 6edthapro

010103 - 00001 4/12/2000 CONYERS, GA 

ZINC PHOSPHIDE DUST 088601 

Zinc phosphide HA 

A mpronot fevfailde

010768 - 00006 6/6/2000 

JUST ONE BITE RAT POISON BAR 112001 Bromadiolone HB 

A 3expbloabmu

010849 - 00004 10/29/2000 EVERETT, MA BRODIFACOUM 112701 Brodifacoum HB 

An po
Page 25 of 27

Incident Package Report

Incident Date Location

Reg. Number Product Name PC Code

Ingredient Name

Exposure Type Inc

011027 - 00002 8/25/2000 CA 

D-CON BAIT PELLETS (BRODIFACOUM) 112701 Brodifacoum HB A 2

011027 - 00005 10/29/2000 CA 

003282-00065 

D-CON MOUSE PRUFE II 112701 Brodifacoum HB A 4

011390 - 00001 1/1/2001 SANFORD, FL 

067517-00071-000478 

REAL KILL RAT & MOUSE KILLER PELLETS 112802 Bromethalin HB Un

011489 - 00001 5/16/2001 

MELBOURNE, FL 

012455-00056 

DITRAC TRACKING POWDER (6 & 25 LB PAILS) 067701 Diphacinone HA 

Ununfou

012715 - 00001 2/1/2002 AZ 

000100-00987 BRODIFACOUM 112701 Brodifacoum HB 

Uneleinfo

013052 - 00023 1/1/2002 MA 

D-CON PRODUCT UNIDENTIFIED 112701 Brodifacoum HB 

An ingmoan

013565 - 00008 12/18/2001 

SAN FRANCISCO, CA 

003282-00065 

D-CON MOUSE PRUFE II 112701 Brodifacoum HB 

A 2witthe mowitexc

013565 - 00011 10/29/1999 CA 

003282-00065 

D-CON MOUSE PRUFE II 112701 Brodifacoum HB A 2

013792 - 00007 5/5/2002 SAN DIEGO, CA 

003282-00065 

D-CON MOUSE PRUFE II 112701 Brodifacoum HB A 5

013858 - 00001 3/10/2003 PADUCAH, KY 

TALON G RODENTICIDE (PELLETS) 112701 Brodifacoum HA 

A 4he

014083 - 00007 4/11/2002 CA 

UNKNOWN - 2% ZINC PHOSPHIDE 088601 

Zinc phosphide HB A 3

014118 - 00027 9/1/2002 

LOS ANGELES, CA 

008845-00127-

REAL KILL RAT KILLER PLACE 112802 Bromethalin HB 

An hu
Page 26 of 27

Incident Package Report

Incident Date Location

Reg. Number Product Name PC Code

Ingredient Name

Exposure Type Inc

000478 PACKS she 

ven

015097 - 00001 5/21/2004 

BONNERS FERRY, IA 

003282-00065 

D-CON MOUSE PRUFE II 112701 Brodifacoum HA 

Sumasud

016043 - 00001 11/6/2004 

WASHINGTON, DC 

061282-00046 RAMIK GREEN 067701 Diphacinone HA 

Sufemhe

016036 - 00023 10/17/2004 

CORCORAN, CA 

062577-00007 

ECHOLS MOUSE & RAT PELLETS 086002 Warfarin HB 

Sufem

016136 - 00006 11/12/2004 TN 

003282-00081 

D-CON READY MIXED BAIT BITS 3 OZ 4 PK. 112701 Brodifacoum HB 

Sufemcrahyd

017138 - 00006 12/4/2005 MADISON, WI 

003282-00066 

D-CON BAIT PELLETS 112701 Brodifacoum HB 

An sui

017893 - 00017 3/5/2006 CA 

SUPER COUMADIN PRODUCT 086003 

Coumadin sodium HB 

A 4sui

018793 - 00001 6/20/2007 TERRELL, TX 

D-CON (UNSPECIFIED FORMULATION) 086002 Warfarin HC,HA 

Deexppeblecon

019260 - 00001 10/9/2007 POLLAND, IN 

000100-01055-061282 

HAVOC XT BLOK KILLS RATS AND MICE 112701 Brodifacoum HB 

Unexpunexpadbre

019519 - 00037 3/13/2008 CA 

ZINC PHOSPHIDE 088601 

Zinc phosphide HB A 2

020180 - 00020 5/1/2008 CA 

003282-00074 

D-CON RODENTICIDE PELLETS 112701 Brodifacoum HB A 2
Page 27 of 27

Incident Package Report

Incident Date Location

Reg. Number Product Name PC Code

Ingredient Name

Exposure Type Inc

(UNSPECIFIED) 

021605 - 00008 9/2/2009 SAN DIEGO, CA 

TROUNCE (UNSPECIFIED) 112802 Bromethalin HB 

A 4sui

021982 - 00005 5/10/2010 CA 

003282-00065 

D-CON MOUSE PRUFE II 112701 Brodifacoum HB A 2