Page 2 of 27 incidents to children under six ye ars of age to total incidents pe r pesticide classifications is highest for rodenticides than th e other pesticide classifications.

II. BACKGROUND

In the U.S., rodenticides are registered for us e by the Environmental Protection Agency’s (EPA or Agency) Office of Pesticide Pr ograms (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 unde r OPP’s Reregistration program in the 1990s. As a result of these revi ews, rodenticide agricu ltural field uses and residential tracking powder products were successfu lly 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 W ildlife Service, rendering mitigation unnecessary. However, the path forward to mitigate risk from the remaining rodenticide use pattern (rodenticides formulated as baits/pe llets used against commensal rodents 1 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 issu ed recommendations, and helped inform the Agency’s 2008 Risk Mitigation Decision for Ten Rodenticid es (RMD). Under the terms of the 2008 RMD, products marketed to the general non-professional us er 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 product s 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 regi strants 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 num ber of accidental (unintentional) exposures involving these products. Subsequently, at this ju ncture, the Agency is compiling information to support the upcoming NOIC, and this memo in part icular focuses on residential rodenticide use and their impact on humans.

Currently, there are 10 active ingred ients and two sodium salts that are formulated as baits and used in residential-type settings, as well as hol d 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: firs t-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 ta rget pests, unlike other pesticides such as
herbicides and certain insecticides where adve rse effects on mammals tend to be different in nature than their effects on target pests. Rodenticides can be di vided into three broad classes in terms of their effects: first generation antic oagulants, second generati on anti-coagulants, and non-anticoagulants. The first- and second ge neration 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 le thal dose to rodents in one night’s feeding. The non-anticoagul ant rodenticides work in diffe rent ways to cause death.

Each of these is discussed below:

 first generation anti-coagulants disrupt the production in the live r of vitamin K dependent blood-clotting factors II (prothrombin ), VII, IX, and X. Due to the long halflives of the vitamin K-dependent clotting fact ors, the anticoagulant effect doesn’t occur in the rodent until after several days of i ngestion 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 chlor ophacinone, diphacinone, and diphacinone sodium salt block different bindi ng sites than those blocked by warfarin and
warfarin sodium salt.Page 4 of 27  second generation anticoagulants are more acute ly 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 warfar in sodium block; however, second generation anticoagulants have much longer half-lives in the body (Batten and Br att, 1990). Similar to the first generation anticoagulants, the to xic effects of these agents usually begin several days after ingestion, b ecause of the long half-life of the coagulation factors.

The non-anticoagulants work in a variety of wa ys and no single common mechanism exists. For example:

 Bromethalin, causes decreased production of ATP in the ce lls of the central nervous system by uncoupling oxidative phosphoryla tion 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 dr aws more water into ne uronal cells (cerebral edema) and increases intracranial pressure which can be lethal. Symptoms and signs of cerebral edema include headache, dizzine ss, nausea, numbness, weakness, loss of coordination or balance, a ltered level of consciousness, respiratory depression, seizures, and death.

 Cholecalciferol increases calcium absorpti on from food, and mob ilizes calcium from bone which leads to hypercalcemia (inc reased calcium levels in blood). Hypercalcemia can cause formation of calcium crystals in internal organs such as blood vessels, kidneys, stomach wall and l ungs (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, na usea, anorexia, headache and irregular heartbeats (Goldfrank et.al, 2010). Acute renal tubular in jury due to hypercalcemia may cause excessive urination, increased wate r intake, protein in urine and increased blood urea levels. Prolonged hypercalcemia may eventually cause kidney failure due to formation of kidney stones and calc ium deposition in kidney tissues.

 Zinc phosphide can quickly produce toxic phosph ine gas when it comes in contact with acids or water. Phosphine is thought to produce toxicity by blocking cytochrome oxidase and, inhibiting oxidative phosphoryla tion which may lead to cell death (Perry H.E., 1998). Most of the tissue damage can o ccur in liver, kidneys and heart. Patients may present with symptoms such as, severe gastrointestinal irritation, nausea, vomiting (with fishy odor), chills, tightness of ch est, difficulty in breathing and cough (from pulmonary edema). Development of the live r 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 Cent er (PCC) data for residential exposure to
rodenticides found that anticoa gulant rodenticides are res ponsible for a large number of exposures (over 12,000 per year, 1993-96) in childr en under six years old, accounting for 20% ofPage 5 of 27 all pesticide exposures. Fortunately, the major ity of these exposures, 97%, do not result in significant symptoms base on those cases whic h received follow up to determine medical outcome. Compared to other types of pesticides, anticoagulants (including 1 st and 2 nd
generation) were the least likely to have sy mptomatic 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 medi cal 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 anal ysis analyzed incident reports primarily concerning children (Blondell and Spann, 06/03/1999, D256673). They addressed underreporting, finding that a number of surveys indica te 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 inci dents 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 (Winfi eld, 05/08/2008, D332561) made the following summary findings:

 The combination of 9-rodentic ides (difenacoum was not included in this analysis) is below the composite of all pesticides in th e 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% hi gher than the composite of all pesticides.

 No apparent annual trend is noticed in th e 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 t oxicity studies conduc ted on animals and exposure information relevant to the pesticide’s use pattern when re gistering a pesticide. After a pesticide is registered; however, human observational data a bout the effects and exposure of registered pesticides may be collected and analyze d. For this memorandum and review, human observational data, or incidents, from the following sources were analyzed:

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

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

 NIOSH Sentinel Event Notification Syst em 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 anticipat ion 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 ri sks 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 fi ve pesticide incident data sources (IDS, NIOSH/SENSOR, NPIC, California PISP, and AAPCC ) were used in this report since they provide useful content and historic al 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 addi tional utility and were not inve stigated. 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 pois onings 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), cholecalcifer ol (PC Code 802901), difenacoum (PC Code 119901), difethialone (PC Code 128967), dipha cinone (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 Pois on Control Centers (AAPCC)

The American Association of Poison Contro l Centers (AAPCC) is a non-profit, national organization founded in 1958 that represents the poi son 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 tr ained to answer questions about poisons. Additionally, AAPCC reports prov ide clearly summarized inform ation on pesticide incidents
within the context of ot her poisoning events. http://www.aapcc.org/dnn/NPDSPois onData/NPDSAnnualReports.aspx

AAPCC produces an annual summary report gi ving 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 rodenticides 2 . 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 tr eated in a health care facility each year. Approximately 85% (~15,000 per year) of these 17,000 e xposures occurred to children under 6 years old over the 11 year period analyzed (Figure 1).

2 Note that in AAPCC rodenticides include the following categor ies/pesticides: ANTU, bromethalin, cholecalciferol, cyanide, long-acting anticoagulant (2 nd generation anticoagulants), ot her, PNU, sodium monofluroacet ate, strychnine, unknown, warfarintype anticoagulant (1 st 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 resu lt in residual disability or disfigurement (coma, cardiovascular instability, repeated seizures),

 Moderate – symptoms are more pronounced, pr olonged, or more of a systemic nature than minor symptoms with no residual disabi lity. Usually some form or treatment is indicated (high fever, disorientation),

 Minor – symptoms are minimal with no residua l 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 thes e 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 exposurePage 8 of 27 the rodenticide exposure (figure 2) 3 . Further, when compared to other types of pesticides, rodenticides were the least likely to have sy mptomatic 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 responsi ble for more total incidents and incidents to children less than six years of age than other pestic ide classes. However, the ratio of incidents to children under six years of age to total incidents per pestic ide classifications is highest for rodenticides than the other pesticide classes (Table 1, Figure 3). Appr oximately 16% of all reported exposures to pesticides are due to r odenticide exposures and 26% of all reported pesticide-related exposures to children under 6 ar e due to rodenticide exposures. In addition, approximately 25% of all pesticide-related cases s een in a health care facility were related to rodenticide exposures.

3 These calls include all age groups and are inclusiv e 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 9000IncidentCountPage 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 e xposure. The analysis also demonstrates that an average of 128 cases per year (or 1%) of the e xposures 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 year s old, approximately 39% of those seen in a health care facility are related to rodenticid e exposure and 13% of hospitalization cases are related to rodenticide expos ure. 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 2009RatioofChildren<6YearsOldtoTotalSingleSubstanceExposures

Year disinfectants

fungicides

herbicides

Insecticides ‐ other

organophosphates

pesticides ‐ other

rodenticidesPage 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 e xposures to rodenticides do occur. From 1999- 2005, 894 cases were reported having minor, modera te, or major effects. For cases reporting moderate or major effects, the most common ef fect reported was hema tological, 37% and 55% respectively (Table 3). These symptoms are lik ely a result from antic oagulant rodenticides’ abilities to interfere with blood clotting and ar e likely the result of rodenticide exposure.

Table 3. AAPCC Reported Exposu re Symptoms for Symptomatic Ch ildren 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 pers on could report both a neurological and renal symptom)

2. OPP Incident Data System (IDS)

The OPP IDS includes reports of alleged human hea lth incidents from various sources, including mandatory Federal Insecticide, Fungicide and Ro denticide Act (FIFRA) Section 6 (a) (2) reports from registrants and reports from other federal and state health and envi ronmental agencies and individual consumers. Since 1992, OPP has compiled these reports in IDS. IDS contain reports
from across the U.S. and most incidents contai ned 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 as sessing how likely it is that the reported exposure is causally related to the repo rted outcome. Because IDS has such extensive coverage, it is useful for provi ding temporal trend information and determining whether risk mitigation has helped reduce potential pesticid e 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 ingredient s: brodifacoum (PC Code 112701), bromadiolone (PC CodePage 11 of 27 112001), bromethalin (PC Code 112802), chlor ophacinone (PC Code 067707), cholecalciferol (PC Code 802901), difenacoum (PC Code 119901), difethialone (PC C ode 128967), diphacinone (PC Code 067701), diphacinone sodium salt (P C Code 067705), warfarin (PC Code 086002), warfarin sodium salt (PC Code 086003), and zi nc phosphide (PC Code 088601). This database search was done to identify the frequency and seve rity of the health eff ects as well as potential patterns and trends attributed to exposures from rodenticides formul ated as baits used for control of commensal rodents. Reports submitted to the IDS represent anecdotal reports or allegations only, and are not necessarily confirmed, validate d, or investigated by medical professionals unless otherwise stated in the report.

IDS consists of two separate modules: Main ID S 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 e xhibited symptoms which may have been lifethreatening, or resulted in adverse reproducti ve 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 th an minor symptoms, usually some form of treatment of the person would have been indi cated, 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 da ta for death (HA) and major (HB) and moderate (HC) incidents,
and it includes more details a bout the location, date and nature of the incident. Main IDS incidents involving only one pesticide are consider ed to provide more certain information about the potential effects of exposure from the pesticid e, 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 re ported by registrants as counts in the Aggregate IDS module. The less se vere human incidents include:

 H-D (minor): If the person a lleged or exhibited some sympto ms, but they were minimally traumatic, the symptoms resolved rapidly a nd usually involve ski n, eye or respiratory irritation; and

 H-E/H (unknown or no effects): If symptoms are unknown, unspeci fied 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 e ffects), 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 warf arin sodium salt in Aggregat e IDS. Note: there was only one warfarin sodium salt product regist ered 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 rodent icide active ingredients listed a bove. Of these 321 cases, there are 304 cases reported that involve exposure to a single roden ticide chemical in the database. There were no incidents reported for the new ac tive ingredient difenacoum. These incidents were mostly (267 incidents) categorized as HCs (Human Moderates); however, there are six incidents categorized as HA (deaths) and 22 incide nts 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 su spected exposures (2 incidents), applicator exposure (3 incidents), post appl ication exposure to tracking powder (2 incident), and intentional ingestion (1 incident).

Figure 4: Main IDS Incidents for Ro denticides 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, 1 st generation anticoagulant, or 2 nd
generation anticoagulant) from 1999 to 2009. Over that 11 year period, non-anticoagulant and 0 5 10 15 20 25 30 35 40IncidentCount

Year Sum of H

Sum of HA

Sum of HB

Sum of HC

Sum of HD

Sum of HEPage 13 of 27 1 st generation anticoagulant rodenticide incide nts appear to be st eady over time, while 2 nd
generation anticoagulant rodenticid e incidents appear to have been increasing coming to a peak in 2008, and decreasing in 2009.

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

Of the rodenticide active ingred ients queried in Main and Aggr egate IDS, brodifacoum accounts for the most incidents (41%), followed by brom adiolone 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 2009IncidentCount

Year 1st Generation

2nd Generation

Non

‐ AnticoagulantsPage 14 of 27 Table 4: Rodenticides Ranked by Total Ex posure 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 GENERA TION II (Reg. No 003282- 00081) (116 incidents or 7%), and C ONTRAC 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, eith er 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 Tota l Exposure Count from Main and Aggregate IDS

Registration

Number Sum of Exposure

Count # of HAs (Deaths) and HBs (Majors) Product Name Active Ingredient Rodenticide Type

003282-
00065* D-CON MOUSE PRUFE II Brodifacoum 2 nd Generation 320 1 HA (malicious intent), and 6 HBs

(5 cases suicide attempts)

003282-
00081* D-CON READY MIXED
GENERATION II Brodifacoum 2 nd Generation 116 1HB (malicious intent)

012455-
00079-
003240 CONTRAC ALLWEATHER BLOX Bromadiolone 2 nd Generation 98 -

000270-

00373 BROMADIOLONE BAIT

BAR Bromadiolone 2 nd Generation 71 -Page 15 of 27 Registration

Number Sum of Exposure

Count # of HAs (Deaths) and HBs (Majors) Product Name Active Ingredient Rodenticide Type

012455-
00069-
003240 CONTRAC RODENTICIDE Bromadiolone 2 nd Generation 60 -

003282-
00066* D-CON PELLETS
GENERATION II Brodifacoum 2 nd Generation 56 1 HB (suicide attempt)

003282-
00074* D-CON BAIT PELLETS II Brodifacoum 2 nd Generation 55 1 HB (suicide attempt)

012455-
00086-
003240 CONTRAC RODENTICIDE
PLACE PAC Bromadiolone 2 nd Generation 49 -

067517-
00066-
000478 ASSAULT ALL WEATHER

BAIT Bromethalin NonAnticoagulant 46 -

000270-

00372 BROMADIOLONE BAIT
PELLETS Bromadiolone 2 nd Generation 35 -

008845-
00127* HOT SHOT SUDDEN
DEATH BRAND MOUSE

AND RAT KILLER Bromethalin NonAnticoagulant 34 1 HB

061282-

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

000100-

01056 HAVOC RODENTICIDE
BAIT PACK PELLETS

WITH BITREX Brodifacoum 2 nd 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 2 nd Generation 16 -

012455-

00075 CONTRAC RAT AND
MOUSE BAIT READY TO
USE PLACE PACS Bromadiolone 2 nd Generation 15 -Page 16 of 27 Registration

Number Sum of Exposure

Count # of HAs (Deaths) and HBs (Majors) Product Name Active Ingredient Rodenticide Type

012455-

00056 DITRAC TRACKING
POWDER Diphacinone 1 st Generation 14 1 HA (suspected
exposure to

product)

003282-
00009* D-CON MOUSE PRUFE
KILLS MICE Warfarin 1 st Generation 13
-

012455-

00079 CONTRAC ALLWEATHER BLOX Bromadiolone 2 nd Generation 11 -

012455-
00018-
003240 ZP POCKET GOPHER

BAIT Zinc phosphide NonAnticoagulant 11 -

000100-
01056-
061282 HAVOC RODENTICIDE
BAIT PACK PELLETS

WITH BITREX Brodifacoum 2 nd Generation 10 -

061282-

00023 RAMIK GREEN MINI
BAIT PACKS Diphacinone 1 st Generation 10 -

- has no HA (deaths) or HBs (majors) associated with it in IDS. *products that are on the cancellation list

3. National Pesticide Info rmation Center (NPIC)

NPIC is a cooperative effort between Oregon St ate University and EPA which is funded by EPA to serve as a source of objective, science-base d pesticide information and respond to inquiries from the public and to incidents. NPIC f unctions 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 primar y purpose is not to collect incident data, but rather to provide information to inquirers on a wi de range of pesticide to pics, and direct callers for pesticide incident investigation and emerge ncy treatment. NPIC receives approximately 25,000 calls per year, with about 4000 of these bei ng incidents. NPIC collects the information
about the incidents and records th at information in a database. NPIC is a source of national incident information, but generally receives fewe r reports than IDS. Regardless, NPIC can provide an additional source of incident information.

Unlike IDS, incidents reported to NPIC are as signed a certainty classification, which helps ascertain whether the exposure and reported ou tcome are related. However, NPIC has only recently begun recording a severity classifica tion (i.e., whether the outcome was severe or minor). Of all the rodenticid e human incidents, only 27 incl uded 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 Certai nty Index classification for the time period 1999- 2010. Although a majority of the incidents were considered “unclassif iable,” they werePage 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 Expo sures 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 regard ing rodenticides received by NPIC in the database. Of these total calls, 204 we re incidents, 2 were suspected incidents and 1321 (or 87%) were information calls . Of the rodenticides querie d 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 diphacino ne sodium salt or warfarin sodium salt. The Agency examined the calls to NPIC regarding ro denticides and found that they have declined from 2005 to 2010 by about 60% (Table 8). The rode nticide related incident s 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 ingestio n; adult accidental ingestion; adult contact; malicious intent; suicide attempts; and inquiries about the safety of eating food from a garden after a rodentic ide 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 Syst em for Occupational Risks (SENSOR)

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

state to state

. Pesticide-related incidents are collecte d from Department of Labor workers’ compensation claims when reported by physicia ns, 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 e ach call in the SENSOR database is likely to correspond to an exposure incident. Although bot h occupational and non-occupational incidents are included in the database, the data in SENSOR are predominately occupational incidents, and is of particular value in provi ding that information. A state SENS OR contact specialist performs follow-up with workers and obtains medical re cords to verify symptoms, circumstances surrounding the exposure, severity, and outcome. Using standardized protocol and case definitions, SENSOR coordinators at State Depart ments 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 th e states track incidents. http://www.cdc.gov/niosh/topi cs/pesticides/overview.html

There were 50 rodenticide in cidents reported to NIOSH SE NSOR from 1998-2006. Of these, there was one death (no details av ailable), two were cl assified high severit y, 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 accident al 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 Ca lls 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 Surveilla nce Program (PISP) Incident Data

The Pesticide Illness Surveillance Program (PISP) maintains a database of pesticide-related illnesses and injuries. Case repor ts are received from physicians and via workers’ compensation records. The local County Agricultural Commissi oner 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 par ticularly 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 attrib utable 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 inge stion of anticoagulant r odenticides 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 tria ge 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 pa tients with unintentional i ngestion of less than 1 mg of SGAR active ingredient (whi ch includes practically all uninten tional ingestions in children less than 6 years of age) can be safely obs erved at home without laboratory monitoring. However, they also recommend that symptoma tic patients (i.e. e xperiencing bruising or bleeding) with unintentional inge stion 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 orPage 20 of 27 experienced any bleeding. They, similarly, conc luded that normal presc hool-aged children with unintentional acute exposures to SGAR roden ticides do not require any routine follow-up laboratory studies and do not requ ire medical intervention. Bart lett (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) characteri zed the toxicity from single, acute brodifacoum ingestions in young children and evaluated the utility of gastrointestinal decontamination in preventi ng toxicity. They found that acute pediatric ingestions of brodifacoum rarely caused clinic al 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 brodif acoum by young children can be adequately managed with home obs ervation 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 acciden tal ingestion by children a realistic concern.

Badakhs et al (2010) analyzed data from the L ouisiana Hospital Inpatient Discharge Database from 1998 through 2007 to characteri ze hospitalizations involving pe sticides. They found that while only six percent of the cases in the final da taset of pesticide-relate d hospitalizations were due to rodenticides, children had a significantly higher rate of r odenticide exposure than adults (i.e., 14% of the pesticide-related children hospi talizations involved roden ticide exposure vs. 2% of the pesticide-related adult hos pitalizations involved rodenticid e 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 a ccessible to children coupled with the hand-to-mouth behavior of young children a nd their accidental c ontact 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 litera ture, 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 anal ysis 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 clin ical 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 rodentic ide 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 as sociated 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-ta rget wildlife, not bei ng followed. Despite labelPage 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 comp ly. 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 rodenticid es 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: Te n 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., CANTILE NA, 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., CANTILE NA, L. R., JR., GREEN, J. L., RUMACK,

B. H. & GIFFIN, S. L. 2009. 2008 Annual Repor t of the American Association of Poison
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, 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., MANO GUERRA, A. S., CHRISTIANSON, G., NELSON, L. S., OLSON, K. R., BOOZE, L. L. & TROUTMAN, W. G. 2007. Longacting anticoagulant rodenticid e poisoning: An evidence-bas ed consensus guideline for out-of-hospital management. Clinical Toxicology, 45
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CHAVHAN, S. G.

, BRAR, R. S.

, BANGA, H. S. & N D, S. 2011. Cholecalciferol (Vitamin D3) Toxicity in Animals. IPJ-Online, 3
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KENDRICK, D. B. 2006. Mosquito repellents and superwarfarin rode nticides - are they really toxic in children? Current Opinion in Pediatrics, 18
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LAI, M. W., KLEIN-SCHWARTZ, W., RODGERS, G. C., ABRA MS, J. Y., HABER, D. A., BRONSTEIN, A. C. & WRUK, K. M. 2006. 2005 Annual Report of the American
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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 Associ ation of Poison Control Centers Toxic Exposure Surveillance System. American Journal of Emergency Medicine, 20
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LITOVITZ, T. L., KLEIN-SCHWARTZ, W., WHI TE, S., COBAUGH, D. J., YOUNISS, J., DRAB, A. & BENSON, B. E. 2000. 1999 Annual Report of the American Association of
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LITOVITZ, T. L., KLEIN-SCHWARTZ, W., WHI TE, S., COBAUGH, D. J., YOUNISS, J., OMSLAER, J. C., DRAB, A. & BENSON, B. E. 2001. 2000 Annual Report of the
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NELSON, L., LEWIN, N., HOWLAND, M. A., HOFFMAN, R., GOLDFRANK, L. & FLOMENBAUM, N. 2010. Goldfrank’s Toxicologic Emergencies , The McGraw-Hill Companies.

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SHEPHERD, G., KLEIN-SCHWARTZ, W. & ANDERSON, B. D. 2002. Acute, unintentional pediatric brodifacoum ingestions. Pediatric Emergency Care, 18
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WATSON, W. A., LITOVITZ, T. L., K LEIN-SCHWARTZ, W., RODGERS, G. C., YOUNISS, J., REID, N., ROUS E, 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
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WATSON, W. A., LITOVITZ, T. L., RODGER S, G. C., KLEIN-SCHWARTZ, W., REID, N., YOUNISS, J., FLANAGAN, A. & WRUK , K. M. 2005. 2004 Annual Report of the
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WATSON, W. A., LITOVITZ, T. L., RO DGERS, 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 Ce nters Toxic Exposure Surveillance System. American Journal of Emergency Medicine, 21
, 353-421.Page24of27Appendix ATable A1: Incident Data System (IDS) Summary of Human Deaths (HAs)and Human Majors (HBs) from 1999-2010IncidentPackageReportIncidentDateLocationReg.NumberProduct NamePC CodeIngredientNameExposureTypeIncident Description008626 -00003 3/18/1999BICENTENNIAL,CA003282-00065D-CON MOUSEPRUFE II 112701 Brodifacoum HB A 25 year old female attempts suicide008701 -00001 4/13/1999 ATLANTA, GA012455-00016ZP TRACKINGPOWDER (4 OZ.,1.1 & 25 LB.) 088601Zincphosphide HBA 76 year old male had exposure totracking powder. He used the producton the property where he works oncars over the period of about sixmonths. Patient presents now withabdominal pain with negativeJaproscopy findings, increasedprothrombin time, decreasedfibrinogen, elevated BUN, decreasedplatelets. metabolic acidosis,increased temp.He has a history of bladder cancer,pulmonary embolism and diverticulitis009738 -00001 12/1/1999LINCHBURG,TNHAVOCRODENTICIDEBAIT PACK 112701 Brodifacoum HBA 67 year old male became ill withedema and renal failure. He ate meatthat was suspected to have theproduct on it.010103 -00001 4/12/2000 CONYERS, GAZINCPHOSPHIDEDUST 088601Zincphosphide HAA male in his 70s applied 10 lbs of theproduct in a car storage area. He didnot wear PPE. He experiencedfever/hyperthermia, tremors, renalfailure, diaphoresis, and eventuallydeath.010768 -00006 6/6/2000JUST ONE BITERAT POISONBAR 112001 Bromadiolone HBA 32 year old female had dermalexposure to product. She experiencedblood clots in urine, fatigue and lowabdominal pain. She was treated withmultiple transfusions and vitamin K.010849 -00004 10/29/2000 EVERETT, MA BRODIFACOUM 112701 Brodifacoum HBAn 87 year old female suspected "selfpoisoning" attempt.Page25of27IncidentPackageReportIncidentDateLocationReg.NumberProduct NamePC CodeIngredientNameExposureTypeIncident Description011027 -00002 8/25/2000 CAD-CON BAITPELLETS(BRODIFACOUM) 112701 Brodifacoum HB A 23 year old male suicide attempt011027 -00005 10/29/2000 CA003282-00065D-CON MOUSEPRUFE II 112701 Brodifacoum HB A 48 year old male suicide attempt011390 -00001 1/1/2001 SANFORD, FL067517-00071-000478REAL KILL RAT &MOUSE KILLERPELLETS 112802 Bromethalin HB Unknown age poisoning victim011489 -00001 5/16/2001MELBOURNE,FL012455-00056DITRACTRACKINGPOWDER (6 & 25LB PAILS) 067701 Diphacinone HAUnknown age adult died fromunknown causes. The product wasfound at the work site.012715 -00001 2/1/2002 AZ000100-00987 BRODIFACOUM 112701 Brodifacoum HBUnknown age adult male withelevated PT and PTT levels. No otherinformation.013052 -00023 1/1/2002 MAD-CONPRODUCTUNIDENTIFIED 112701 Brodifacoum HBAn unknown age adult femaleingested the product over a couple ofmonths. She experienced hearing lossand paresthesia.013565 -00008 12/18/2001SANFRANCISCO,CA003282-00065D-CON MOUSEPRUFE II 112701 Brodifacoum HBA 20 year old female was diagnosedwith rodenticide poisoning. She usedthe bait stations in a residence andmoved them about 2 times per daywith bare hands. She experiencedexcessive bleeding and bruising.013565 -00011 10/29/1999 CA003282-00065D-CON MOUSEPRUFE II 112701 Brodifacoum HB A 27 year old male suicide attempt.013792 -00007 5/5/2002 SAN DIEGO, CA003282-00065D-CON MOUSEPRUFE II 112701 Brodifacoum HB A 53 year old male suicide attempt.013858 -00001 3/10/2003 PADUCAH, KYTALON GRODENTICIDE(PELLETS) 112701 Brodifacoum HAA 46 year old male died from cerebralhemorrhage. Suspected homicide.014083 -00007 4/11/2002 CAUNKNOWN - 2%ZINCPHOSPHIDE 088601Zincphosphide HB A 33 year old female suicide attempt014118 -00027 9/1/2002LOS ANGELES,CA008845-00127-REAL KILL RATKILLER PLACE 112802 Bromethalin HBAn unknown age adult female and herhusband became ill 8 months afterPage26of27IncidentPackageReportIncidentDateLocationReg.NumberProduct NamePC CodeIngredientNameExposureTypeIncident Description000478 PACKS she placed product in her heatingvents.015097 -00001 5/21/2004BONNERSFERRY, IA003282-00065D-CON MOUSEPRUFE II 112701 Brodifacoum HASuspected poison of a 72 year oldmale. He experienced dyspnea andsudden death016043 -00001 11/6/2004WASHINGTON,DC061282-00046 RAMIK GREEN 067701 Diphacinone HASuspected poisoning of unknown agefemale. She experienced a massiveheart attack and sudden death.016036 -00023 10/17/2004CORCORAN,CA062577-00007ECHOLS MOUSE& RAT PELLETS 086002 Warfarin HBSuspected poisoning of unknown agefemale.016136 -00006 11/12/2004 TN003282-00081D-CON READYMIXED BAIT BITS3 OZ 4 PK. 112701 Brodifacoum HBSuspected poisoning of 33 year oldfemale. She experienced abdominalcramps, vomiting, diarrhea, andhydroencephalopy017138 -00006 12/4/2005 MADISON, WI003282-00066D-CON BAITPELLETS 112701 Brodifacoum HBAn unknown age adult male attemptedsuicide/poisoning017893 -00017 3/5/2006 CASUPERCOUMADINPRODUCT 086003Coumadinsodium HBA 43 year old female attemptedsuicide018793 -00001 6/20/2007 TERRELL, TXD-CON(UNSPECIFIEDFORMULATION) 086002 Warfarin HC,HADeath of 15 yr. old male after possibleexposure to D-Con;autopsy resultspending. Mother has minor GIbleeding after eating beanscontaminated w/product.019260 -00001 10/9/2007 POLLAND, IN000100-01055-061282HAVOC XT BLOKKILLS RATS ANDMICE 112701 Brodifacoum HBUnknown age adult male wasexposed to product at work over andunknown period of time. Heexperienced malaise and was recentlyadmitted to the ER with difficultybreathing and anemia.019519 -00037 3/13/2008 CAZINCPHOSPHIDE 088601Zincphosphide HB A 25 year old female attempts suicide020180 -00020 5/1/2008 CA003282-00074D-CONRODENTICIDEPELLETS 112701 Brodifacoum HB A 20 year old male attempted suicidePage27of27IncidentPackageReportIncidentDateLocationReg.NumberProduct NamePC CodeIngredientNameExposureTypeIncident Description(UNSPECIFIED)021605 -00008 9/2/2009 SAN DIEGO, CATROUNCE(UNSPECIFIED) 112802 Bromethalin HBA 44 year old female attemptedsuicide021982 -00005 5/10/2010 CA003282-00065D-CON MOUSEPRUFE II 112701 Brodifacoum HB A 23 year old male suicide attempt