2 

TABLE OF CONTENTS

1 SUMMARY ................................................................................................................. 3

2 BACKGROUND .......................................................................................................... 4

2.1 Rodenticides Being Pursued under NOIC ........................................................................ 4

2.2 Previous BEAD Rodenticide Assessments ........................................................................ 5

2.3 Affected Groups ................................................................................................................ 5

3 IMPACT ASSESSMENT OF PROPOSED NOIC ...................................................... 5

3.1 Methodology ..................................................................................................................... 6

3.2 The Pests: Commensal Rodents ....................................................................................... 6

3.2.1 House Mouse ............................................................................................................ 7

3.2.2 Norway Rat ............................................................................................................... 7

3.2.3 Roof Rat .................................................................................................................... 8

3.2.4 Determination of Rodent Infestation ........................................................................ 8

3.3 Consumer Control Methods for Commensal Rodents ...................................................... 9

3.3.1 Chemical Control ...................................................................................................... 9

3.3.2 Mechanical Control ................................................................................................. 12

3.4 NOIC Effects on Residential Consumers’ Ability to Control Rodents ........................... 16

3.5 Cost Impacts ................................................................................................................... 17

3.5.1 Framework for Cost Analysis ................................................................................. 17

3.5.2 Data ......................................................................................................................... 18

3.5.3 Analysis and Results ............................................................................................... 21

3.5.4 Socio-Economic Equity Assessment ...................................................................... 36

4 ANTICOAGUALNT RODENTICIDE RESISTANCE ............................................ 41

5 CONCLUSIONS ........................................................................................................ 43

6 REFERENCES ........................................................................................................... 45

7 APPENDICES ............................................................................................................ 50

7.1 Appendix A. Product Pricing Data ............................................................................... 50

7.2 Appendix B. American Housing Survey Data ............................................................... 51
3 

1 SUMMARY 

In May 2008, the U.S. Environmental Protection Agency issued the Final Risk Mitigation 

Decision (RMD) for Ten Rodenticides (EPA 2008). One major component of this decision was 

“to minimize children’s exposure to rodenticide products used in homes, EPA is requiring that 

all rodenticide bait products marketed to general and residential consumers be sold only with bait 

stations, with loose bait (e.g. pellets and meal) as a prohibited bait form” (EPA 2008). The other 

major component of this decision was “to reduce wildlife exposures and ecological risks, the 

Agency will require sale and distribution limits intended to prevent general consumers from 

purchasing residential use bait products containing four of the ten rodenticides that pose the 

greatest risk to wildlife (the second generation anticoagulants – brodifacoum, bromadiolone, 

difenacoum, and difethialone)” (EPA 2008). Registrants were to have their consumer products 

comply with the RMD by June 4, 2011. A number of consumer rodenticide products do not 

comply with the RMD and the Agency is filing a Notice of Intent to Cancel (NOIC) for these 

products. 

The Biological and Economic Analysis Division (BEAD) expects that residential consumers who 

are currently using rodenticides will likely continue to use rodenticides allowed under the RMD. 

BEAD has also determined that alternatives are available, affordable, and meet EPA’s efficacy 

standards; therefore, the cancellation of non-compliant products will not result in the loss of 

residential consumers’ abilities to control commensal rodents. 

Overall, BEAD expects that incremental costs will be minimal from having to switch from 

rodenticide products currently available to those that would be available post-mitigation. 

Residential consumers treating for mouse infestations are expected to switch from rodenticides 

that would no longer be available to similar rodenticide products that would be available postmitigation. Incremental costs from this change range from $2 to $12 for mouse control. 

However, loose-form rodenticides account for a majority of rodenticide sales and thus residential 

consumers using such products make up the largest proportion of those that will be impacted by 

the mitigation measures. Therefore, most residential consumers are expected to see an average 

increase in cost of $1.50 in a minor infestation and $3 in a major infestation. With 90% of 

rodenticides sales being for products that are intended to control mice, BEAD concludes that a 

majority of residential consumers will be facing the impacts described above. 

For residential consumers treating for rat infestations, incremental costs estimates range from a 

potential cost savings to $97 per infestation across all rodenticide alternatives that would be 

available post-mitigation. As in the case of mouse control, it is expected that most residential 

consumers are currently using loose-form rodenticides and will incur incremental costs when 

switching to the most similar rodenticide that would be available post-mitigation. These 

incremental costs range $46 in a minor infestation to $92 in a major infestation. Only a small 

proportion of residential consumers are expected to incur these costs, however, as rat control 

products make up 10% of rodenticide sales and only a portion of these sales are for loose-form 

rodenticides. 

BEAD conducted a socio-economic assessment to explore the impacts on low-income residential 

consumers from the mitigation. For households at the poverty threshold, incremental costs are 
4 

equivalent to up to 2% of monthly non-housing income when treating for mouse infestation and 

approximately 10% when treating for rat infestations. Again, with a majority of rodenticide sales 

being for mouse control products, it is expected that impacts on most low-income residential 

consumers will be equivalent to 1% to 2% of monthly non-housing income. 

2 BACKGROUND 

A brief overview of the mitigation measures being pursued under the NOIC, assessments 

previously conducted by BEAD for the RMD, and identification of the affected groups are 

provided below. For a review of the history of rodenticides and EPA’s involvement in their 

regulation, please refer to the draft NOIC. 

2.1 Rodenticides Being Pursued under NOIC 

Currently, there are 20 rodenticide products targeting commensal rodents (i.e., those that live in 

close proximity with humans) that do not conform to the RMD. EPA intends to cancel these 20 

products as explained in the NOIC. 

The active ingredients contained in some or all products that have not complied with the RMD 

and are therefore subject to the NOIC include: 

 First-generation anticoagulant (five products, loose formulations) 

o warfarin (PC code 086002) 

 Second-generation anticoagulant (11 products, various formulations) 

o brodifacoum (PC code 112701) 

o difethialone (PC code 128967) 

 Non-anticoagulant (four products, loose formulations) 

o bromethalin (PC code 112802) 

The specific residential consumer rodenticide products that are subject to the NOIC include: 

 All second generation anticoagulant rodenticides (SGAR). 

 Rodenticides that are not in block form or in a form that is reasonably expected to remain 

in the bait station (including paste/gel form). 

 Rodenticides that are not sold packaged with a bait station. 

 Rodenticides packaged with one pound of bait or more. 

Note that under the RMD, the only allowed forms of rodenticides for the residential consumer 

market are first generation anticoagulant rodenticides (FGAR) or acute (non-anticoagulant) 

rodenticides in block or paste/gel forms that can be secured in a bait station. There are currently 
5 

32 registered rodenticide products that comply with the RMD on the market for residential 

consumer use for control of commensal rodents. 

2.2 Previous BEAD Rodenticide Assessments 

BEAD has published several documents concerning rodenticides over the years. Chiri (2006) 

assessed the uses of rodenticide baits including the pest status of rodents, integrated pest 

management (IPM) for rodent control, and each of the rodenticides in detail. A second 

document that same year assessed the cost impacts for the proposed RMD (Chiri et al., 2006). In 

2008 BEAD responded to public comments concerning the proposed RMD for nine rodenticides 

(Chiri et al., 2008). An addendum to the impact assessment for the proposed rodenticide 

mitigation was published later that year that determined the amended proposed mitigation of 

requiring bait stations would not impose constraints on rodent control programs but could 

increase costs to residential consumers, although they could switch to less expensive snap traps 

(Rim 2008). This assessment confirms previous findings and provides updated estimates of costs 

to residential consumers. 

2.3 Affected Groups 

The NOIC proposes to remove the SGARs and all loose forms of rodenticide bait from the nonprofessional residential market. Therefore, residential consumers who typically would use 

SGARs or those who typically would use loose formulations of rodenticides for their commensal 

rodent control will be affected by the NOIC. This assessment considers homeowners, property 

owners, renters, household consumers, households, and consumers as being synonymous with 

non-professional applicators, and primarily will be referred to as residential consumers in this 

analysis. 

Residential consumers who use only mechanical control methods (e.g. snap traps, glue boards, 

etc.) to control their rodent problems will not be impacted by the NOIC, nor will residential 

consumers who hire pest control operators (PCO) to control all their rodent problems. Therefore, 

economic impacts on these residential consumers need not be considered further. 

The NOIC targets only residential consumer rodenticide products for control of commensal 

rodents; therefore, PCOs and agricultural users are excluded from this analysis, as they will not 

be impacted by this action. 

3 IMPACT ASSESSMENT OF PROPOSED NOIC 

This assessment examines the biological considerations, alternatives, and estimated impacts on 

residential consumers controlling for commensal rodents if the proposed NOIC were to take 

effect. 
6 

3.1 Methodology 

Typically, pesticide impact assessments have clearly defined units that can be compared to one 

another. However, the impacts being examined in this analysis are more difficult to quantify. 

For example, in most pesticide impact assessments, data are available that indicate typical 

application rates necessary to control a pest. In this analysis those data are unavailable. Instead, 

this analysis uses placements of rodent control, as determined by the manufacturer as a unit of 

measurement. 

Furthermore, traditional pesticide impact assessments can be examined at the per acre level. 

However, a comparison of control methods at the per acre level cannot be done here as 

infestations occur within a home. Therefore, BEAD considered scenarios in which a household 

is facing a minor or major rodent infestation. Based on extension and government 

recommendations, BEAD uses six placements (whether snap traps or bait stations) for a low 

infestation of rodents and 12 placements for a high infestation of rodents (CDC 2010; Pierce 

1993; Koehler and Kern, 2008; Hovanic et al., 2010; Illinois Department of Public Health 

undated). 

In addition, despite snap traps, glue boards, and other methods of rodent control being available 

prior to the RMD, some residential consumers still chose to use rodenticides. BEAD expects 

those consumers will continue to choose rodenticides post-NOIC as their preferred rodent control 

method. Therefore, the focus of this analysis is on the impact on residential consumers 

switching from non-RMD compliant rodenticides to accepted rodenticide forms. 

3.2 The Pests: Commensal Rodents 

The Old World rodents that typically live in close association with humans and depend upon 

humans for at least part of their food and shelter are referred to as commensal rodents (Timm 

1994; Franz and Davis 1991). The term commensal literally means “to share the table” 

(Merriam-Webster 2011; Corrigan 1997). Ecologically the term “commensal” means one 

species deriving benefit from another species while not causing any harm. That is not 

necessarily true in this case, as rodents spread diseases and damage food and shelter upon which 

humans depend. Commensal rodents, probably originating in Central and Southeast Asia, have 

been introduced throughout the world by humans and include the house mouse (Mus musculus), 

the Norway rat (Rattus norvegicus), and the roof rat (Rattus rattus), (Corrigan1997; Chiri 2006). 

As mentioned, the NOIC will only impact residential consumers. While commensal rodents can 

survive in many different habitats from open fields to sewers, and in and around farm buildings 

and land, the Agency’s concerns are with residential consumer products. Therefore this 

assessment and the following information pertain only to residential areas. 
7 

3.2.1 House Mouse 

The house mouse is a small, slender rodent. Adults weigh 12 to 25 grams, with head and body 

about 6-11 cm in length and a hairless tail equal to the length of the body (Frantz and Davis 

1991). Their coloring is grayish brown to grayish black (Timm 1994a; Frantz and Davis 1991). 

Rodents are prolific breeders and the house mouse is no exception. The house mouse can breed 

year round if resources are available and the environment (i.e. temperature, harborage, 

competition) is conducive. House mice can have 5 to 10 litters per year, each consisting of an 

average of 5 to 6 pups, which are sexually mature at 6 to 10 weeks of age. Gestation is about 19 

to 21 days. If house mice are living outdoors they typically breed in the spring and fall. (Timm 

1994a; Frantz and Davis 1991; Corrigan 2001) 

House mice are mainly nocturnal, and may range 3 to 9 meters from their nest in search of food, 

but the size of their territories depends on resources. They prefer seeds and grain (Timm 1994a), 

although they can become selective toward certain foods since they are opportunistic omnivores 

(Corrigan 2001). House mice are considered to be “nibblers” as they take tiny bites of food 

many times during the night (Timm 1994a; Corrigan 2001). Since the house mouse evolved in 

desert areas, they can survive with little or no free water but will drink water when available 

(Timm 1994a; Corrigan 2001). 

House mice constantly explore their environment within their home range. They typically do not 

fear new objects, like traps (Timm 1994a; Corrigan 2001). Corrigan (2001) does point out 

different populations of house mice and their specific environments lead to variations in their 

behavior; therefore, their behavior has been referred to as unpredictable. 

3.2.2 Norway Rat 

The Norway rat is a large, robust rodent. The adults weigh 105-400 grams with body lengths of 

18-26 cm (Frantz and Davis 1991). Their tail is shorter than their body (Timm 1994b; Corrigan 

2001). The fur can vary from brownish-black to reddish-gray with paler color fur on their 

ventral surface (Timm 1994b; Corrigan 2001). 

In nature Norway rats burrow in the ground for their nests. Often times, holes to their burrows 

can be seen near structures. The gestation period for Norway rats is approximately 21 to 23 days 

and producing 6 to 12 pups per litter. Pups reach sexual maturity at about 3 months. Norway 

rats produce about 4 to 6 litters per year, with breeding typically peaking in spring and fall. 

(Timm 1994b; Corrigan 2001) 

Norway rats are mainly nocturnal, although daytime foraging is not uncommon. In the field they 

can have an average range of 30 to 45 m diameter from burrows (Timm 1994b), although 

Corrigan (2001) states that urban Norway rats may travel 8 to 30 m from nests for food and 

water. Compared to house mice, Norway rats tend to be steady eaters (Frantz and Davis 1991). 
8 

Similar to house mice, Norway rats also constantly explore and learn about their environment 

(Timm 1994b; Corrigan 2001). They detect new objects in their environment quickly; but unlike 

house mice, these rodents tend to avoid new objects (Timm 1994b; Corrigan 2001). Norway rats 

will cautiously investigate new objects (like traps) after a couple of days, especially if the new 

object is not directly on their runway but beside or near it (Corrigan 2001). 

3.2.3 Roof Rat 

The roof rat is a sleek rat with adults weighing from 80 to 350 grams. Their bodies are 16 to 23 

cm in length with tails longer than the body. They also occur in a range of color from blackishgray to tawny brown with white to brownish-grey bellies. (Frantz and Davis 1991) Roof rats 

favor more tropical and semi-tropical climates (Marsh 1994). They are more aerial than Norway 

rats and will live in trees and vine-covered fences. They typically enter buildings from the roof 

and overhead utility lines (Marsh 1994; Corrigan 2001). In buildings where they occur with 

Norway rats, the Norway rats occupy the basement and lower levels and the roof rats occupy the 

upper stories and attic (Marsh 1994). 

Roof rats tend to prefer to nest off the ground. They have a gestation period of 21 to 23 days; 

producing about 5 to 8 pups per litter. Roof rat pups are reproductively mature by 3 months. In 

tropical regions these rodents can breed year-round, otherwise their main breeding season is in 

the spring and fall. A female will typically have 3 liters per year (Marsh 1994, Corrigan 2001). 

Like the other commensal rodents, roof rats are omnivorous and opportunistic. However, they 

prefer a wider variety of fruit and nuts than either Norway rats or house mice (Marsh 1994). 

Roof rats tend to be more nibblers, like the house mouse (Frantz and Davis 1991). They become 

more active at sunrise and sunset, and tend to forage further than either Norway rats or house 

mice, generally 30 to 90 m for food and water (Marsh 1994). 

3.2.4 Determination of Rodent Infestation 

Residential consumers probably identify a rodent problem when they find rodent feces, or 

droppings, in their house. Since a house mouse will produce 40 to 100 fecal pellets per day 

(Corrigan 1997) these droppings will tend to accumulate in areas of high activity. In addition, 

these droppings can indicate the size of the population. While the rats do not produce as many 

droppings as mice, the droppings still indicate areas of activity and size of the population. There 

are several websites to help residential consumers identify which rodent they have based on the 

differences in the droppings (Pierce 1993; Koehler and Kern, 2008; Hovanic et al., 2010; Illinois 

Department of Public Health undated). 

Residential consumers may also look for runways, since rats and mice tend to use the same 

pathways between their nests and food sources. Along these runways may be grease marks and 

urine stains. Some residential consumers may hear rodent noises, such as squeaking, gnawing, 

and scratching, at night that indicate an infestation. 
9 

The signs that residential consumers use to identify their rodent problem will also be indicative 

of when their problem has been solved. 

3.3 Consumer Control Methods for Commensal Rodents 

When mice or rats have invaded a home residential consumers have several control options 

including chemical and mechanical methods. Decisions of the residential consumer are based 

upon a number of preferences and situations. For instance residential consumers with young 

children and pets may prefer mechanical traps because of concerns regarding exposures of 

rodenticides to their family, even though traps can injure fingers and pets. Residential 

consumers who are squeamish may prefer rodenticides because they will not have to deal with 

dead or injured rodents. Other considerations may include their tolerance of decomposing odors, 

previous experience with rodent control, and opinions regarding pesticides in general. 

Several sources provide anecdotal evidence that mechanical controls are the most widely used 

rodent control method. These sources include searches for top products on major online retail 

store websites, professional expertise, and discussions with retail sales managers. However, 

BEAD does not have survey or sales information that indicates whether homeowners are more 

likely to purchase mechanical controls over chemical controls. 

Below is an overview of methods residential consumers might choose to control rodents. These 

include products EPA proposes to cancel as well as alternatives available to the residential 

consumer. 

3.3.1 Chemical Control 

Rodenticides are poisons used to kill rodents and are commonly used to supplement a control 

program that also includes exclusion, sanitation, and even trapping strategies, especially if there 

is a high rodent infestation. Rodenticides must be eaten by the rodent in order to work. 

Therefore, not only is the active ingredient an important component, but the formulation and 

palatability of the bait are also critical. 

3.3.1.1 Active Ingredients 

Many of the rodenticides are anticoagulants, which interfere with the animal’s blood clotting 

abilities, resulting in it hemorrhaging to death. The FGAR products include: warfarin, 

diphacinone, and chlorophacinone. Baits using these active ingredients ordinarily require the 

rodent to feed on them for several nights to acquire a lethal dose. Consequently it is important to 

maintain fresh bait and reduce the availability of other food options for rodents to consume a 

lethal dose. There are currently registered residential consumer products containing 

chlorophacinone and diphacinone that conform to the RMD and will remain in the residential 

consumer market. 
10 

Because documented resistance to warfarin began to occur in the 1950s, more potent 

anticoagulant rodenticides, the SGARs, were developed. These include: brodifacoum, 

bromadiolone, difethialone, difenacoum. These rodenticides are often considered to be more 

efficient than the FGARs since rodents may obtain a lethal dose in a single night’s feeding 

(Corrigan 1997; Koehler and Kern 2008). However, even though a lethal dose can be obtained 

in a single night’s feeding, the rodents do not begin to die for 4 to 7 days, the same time it takes 

for the FGARs. Since death is delayed, rodents may continue to feed on these baits and 

accumulate much higher doses than is necessary for death. This increases the risks to non-target 

animals that might consume poisoned rodents. Consequently, SGARs are being removed from 

the residential consumer market under the draft NOIC. 

Bromethalin is the only acute (non-anticoagulant) rodenticide available for residential consumers 

in the U.S. It is also the only “stop-feeding” rodenticide on the market. It is effective in small 

quantities, results in paralysis, and death usually occurs in about three days (Corrigan 1997). 

Acute rodenticides are effective against rodents resistant to anticoagulant rodenticides, and no 

resistance issues have been identified with them. There are currently registered residential 

consumer products containing bromethalin that conform to the RMD that will remain in the 

residential consumer market. 

Based on the most recent data available, the annual value of the homeowner market for 

rodenticides was approximately $110 million (Kline 2006). The largest regional market by 

expenditures was estimated to be the South (35%), followed by the Midwest (31%), the West 

(18%), and the Northeast (16%). Bait packets were the most popular rodenticide product form 

and accounted for about 60% of the rodenticide market. The active ingredient most widely used, 

by pounds, was brodifacoum, followed by diphacinone and chlorophacinone, which in 2005 

made up 30%, 3%, and 2% of the market, respectively. Nearly 90% of rodenticide sales in the 

homeowner market were for the elimination of house mice (Kline 2006). 

3.3.1.2 Palatability 

Rodents are very selective in their food choices and will not consume the straight active 

ingredient. Therefore, rodenticides must be combined with various ingredients that will make 

them palatable. In fact, the bait must not only disguise the active ingredient, but also be more 

desirable than any other food sources available to the rodent. This is a critical component. 

Rodenticides will not kill rodents if the rodents do not consume them. It must also be readily 

available. If rodents refuse to consume the baits the efficacy of the active ingredient is of little 

concern (Pitt, et al. 2011; Jokic, et al. 2008; Morriss, et al. 2008; Witmer and Jojola 2006; 

Baroch 2004; Corrigan 2001). 

Palatability is determined not only by the species of rodent, but its location and the other food 

sources within its environment. Individual rats and mice and even different populations have 

their own preferences for foodstuffs (Meehan 1984 and Rowe 1973 in Clapperton 2006). 

Therefore baits are formulated with various blends of seeds, grains, oils, and sugars to tailor the 

flavor to be attractive to the different rodents (Clapperton 2006) as well as masking the 

rodenticide. Residential consumer products are blends of various ingredients. These blends are 
11 

formulated to attract the commensal rodent of most concern, for residential consumers this is 

typically the house mice. 

3.3.1.3 Bait Formulation 

To encourage a rodent to eat an active ingredient, rodenticides not only need to be palatable but 

also made into a form that the rodents like. The residential consumer products to be canceled are 

the loose forms, including pellets and loose meal. Pellets come in various sizes and rodents are 

able to pick them up and eat them like a seed or nut. Pellets were usually contained in plastic 

packages (placepacks) or in cardboard wedges. Since pellets are easily handled and since 

rodents like to cache their food, it is impossible to maintain control of where the pellets end up 

(Corrigan 2001). In addition, sometimes rodents even cache the whole placepacks, but they do 

not necessarily take them to their nests to stash, therefore rodenticide pellets could be relocated 

anywhere throughout the premises. The ability of rodents to easily move these baits makes it 

nearly impossible for users to maintain control and ensure that these poisons are unavailable to 

children, pets, and wildlife, which is one reason these loose formulations are being canceled 

under the NOIC. 

Another formulation is the block bait. Bait blocks can be formulated with many different 

ingredients to ensure that they are palatable to the rodents. They can also be manufactured with 

varying degrees of hardness to be attractive items for rodents to gnaw as well. Most bait blocks 

have hollow centers so they can be easily anchored into bait stations and therefore, are unlikely 

to be moved or cached by rodents. However, rats will move and cache unsecured bait blocks. 

Since users must maintain control over rodenticide baits to prevent exposure to children, pets, 

and non-target wildlife, a formulation that prevents the rodents from moving them is essential, 

and blocks anchored in bait stations are most likely to provide the security needed to prevent 

accidental exposures. 

Comparative product performance studies of different formulations are variable. Clapperton 

(2006) reviewed several studies demonstrating that sometimes block baits were preferred, but in 

other studies pellets or cereals were preferred. Kaukeinin (2009) reports blocks are highly 

palatable to rodents, plus offer advantages such as durability to withstand weather conditions. 

Therefore, residential consumers should still be able to control rodents with bait blocks in bait 

stations, as well as they did with pellets, and other loose formulations. 

3.3.1.4 Bait Stations 

To comply with the RMD rodenticide bait must be sold with a RMD-compliant bait station. Bait 

stations are recommended to help to prevent accidental exposures of baits or traps to children, 

pets, and non-target wildlife (Vantassel, et al. 2006; Corrigan 1997). Non-RMD compliant 

rodenticides did not require bait stations. Residential consumers could easily toss a placepack or 

cardboard wedge of rodenticide behind appliances, in attic spaces, or anywhere. However, this 

capability, while easy, did not place the rodenticide in appropriate locations nor allowed users to 
12 

maintain control over the location and consumption of the rodenticide. It also allowed for 

rodents to easily move the rodenticides to new places. 

Bait stations may provide several advantages. They protect the bait from dust and moisture 

thereby keeping the bait palatable longer. Bait stations also help prevent accidental spillage and 

help to prevent rodents from carrying them away. In addition, appropriately designed stations 

provide a protected place for rodents to feed and they may consume more bait if they feel more 

secure (Vantassel, et al. 2006; Corrigan 1997). Rodents consuming more bait are more likely to 

obtain a lethal dose. In addition, residential consumers are able to easily determine if rodents are 

feeding on the bait, which also indicates proper placement of the bait station as well as 

palatability of the bait. Many commercial stations have ways to anchor them so that they cannot 

be carried away by non-target animals. 

Bait stations must be placed appropriately in the rodent’s home range. Mice tend to move along 

walls and behind appliances and may move only about 6 to 10 ft from their nest as they forage 

(Timm 1994a; Corrigan 2001). Multiple bait stations are needed to increase the probability of a 

mouse to encounter it on any given night. The same holds true for rats; although because of their 

neophobia, it is recommended for stations to be placed near their pathways for rats to acclimate 

to the stations first (Corrigan 2001). 

3.3.2 Mechanical Control 

An alternative to using poisons is mechanical control. This is an effective method of control, 

especially for mice and when populations are relatively small. Mechanical controls include snap 

traps, glue boards, as well as live trapping. 

3.3.2.1 Snap Traps 

Snap traps have been around for many years, and are an effective way to control mice and rats. 

Selection of the appropriate size trap depends on the rodent to be controlled (i.e. small traps are 

for mice). Some advantages of snap traps are: they are relatively inexpensive, they may be 

reused, dead rodent verifies success, and there is no odor from decomposing rodents if disposed 

of daily. Some disadvantages include the time and effort of baiting and setting the traps; once 

sprung it will not work until reset; and disposing of dead and injured rodents. Rats tend to be 

more difficult to trap than mice since they are neophobic. However, some residential consumers 

may not want to dispose of dead rodents or verify the success of their control method, so what 

some residential consumers may consider an advantage others may consider a disadvantage. 

Generally snap traps are not expensive but their success is determined by a number of factors. 

Location and frequency of traps is the same as for bait stations; that is along the rodents’ 

runways. Several websites have diagrams to illustrate setting snap traps perpendicular to the 

walls where rodents run and often show two traps side by side, in case the rodents jump over the 

first one, they may land on the second trap (CDC 2010; Illinois Department of Public Health, 

undated; New York City Department of Health and Mental Hygiene, undated). Traps should be 
13 

checked daily to remove any caught rodents, to rebait, and to reset (Hovanic et al. 2010; 

Corrigan 1997). Since the number of rodents is usually underestimated and areas of activity may 

not always be clearly evident, it is recommended that residential consumers use more traps than 

they think they need (Hovanic et al. 2010; Corrigan 1997). 

Like rodenticide baits, baits used for snap traps need to be attractive to the rodents being 

targeted. CDC (2010) recommends baiting snap traps with peanut butter, but other sources 

recommend trying chocolate, gum drops, nuts, oats, dried fruit or small pieces of bacon (Illinois 

Department of Public Health, undated; Hovanic et al. 2010). Even using dental floss will attract 

pregnant female rodents looking for nest building materials (Corrigan 1997). Therefore, there 

may be some added time involved in finding the appropriate bait for the rodent population of 

concern. Baits need to be maintained with fresh material, so checking it frequently will take 

more time than using rodenticide baits (Corrigan 1997). 

Some snap traps can be reused. The wooden snap traps and the plastic “jaw” type traps are 

intended to be reused. Some of the wooden snap traps now have expanded triggers to provide a 

larger area for rodents to spring. The plastic jaw types of snap traps have a mechanism to easily 

set the trap while protecting fingers. These plastic jaw traps are intended to reduce risks to pets 

and fingers and still be sensitive to trap rodents. These jaw traps also allow residential 

consumers to easily release the captured rodent from the trap, without touching it, for disposal. 

In addition, there is evidence that previously successful snap traps are actually more attractive to 

rodents than new traps (Corrigan 1997). 

The market now has single-use snap traps where the rodent is completely contained, for the 

residential consumer who does not want to see or touch dead rodents. These products have a 

lever to set, and when the trap is sprung, the lever is moved to indicate a rodent has been caught. 

The residential consumer then throws the entire unit away, and never even has to see the rodent. 

Manufacturers indicate that consumers can ensure they have a mouse by the additional weight of 

the trap. These units also reduce risks to fingers and pets by encasing the entire trapping 

mechanism. 

Since rodent home ranges may be relatively small, snap traps catch more rodents when placed 

short distances apart, 6 to 10 ft (Hovanic et al. 2010; Corrigan 1997). The success of snap traps 

is usually increased by using many traps and ensuring the baits on the traps are taken prior to 

actually setting the traps (Witmer and Jojola 2006; Illinois Department of Public Health, 

undated; Corrigan 1997). Rats tend to be neophobic, so experienced trappers bait but do not set 

their traps until there is evidence that feeding has begun. This is the same recommendation as 

for rodenticide bait stations. 

3.3.2.2 Glue Boards 

Another mechanical method for rodent control and an alternative to cancelled rodenticides are 

glue boards. Glue boards have a sticky substance that will catch and hold rodents that run across 

them. Since ensnared rodents take longer than 24 hours to die, mainly from lack of food and 

water, some people believe that glue boards are inhumane. 
14 

Some residential consumers may like the ease of glue boards, since there are no triggers or baits 

to set. Glue boards are simply placed in the same general location as snap traps and rodenticide 

bait stations would be. Glue boards are typically placed along walls where the rodents are 

traveling, and since rodents can jump, some agencies recommend placing two glue boards end to 

end (Illinois Department of Public Health, undated). Glue traps may be useful to kill snap trap 

wary mice and are sometimes used in conjunction with snap traps (Illinois Department of Public 

Health, undated). 

Dampness, dust, and even temperature extremes will diminish the tackiness of the glue; 

consequently, rodents may not effectively adhere to the glue boards under these circumstances 

(Illinois Department of Public Health, undated). Since rodents trapped on glue boards do not die 

quickly, they can use their urine, feces, and fur to escape (Corrigan 1997). Rodents have been 

observed using paper, dirt, or leaves to essentially create bridges over the sticky surfaces 

(Corrigan 1997). CDC (2010) does not recommend glue boards because often the stuck rodents 

are not dead, thereby increasing the potential for disease transmission and bites. 

3.3.2.3 Live Traps 

For residential consumers averse to killing pest animals there are some live traps available on the 

market. Some live traps use baits to entice rodents; other traps will exploit a rodents’ curiosity to 

investigate. Several models of these traps have holding spaces that will hold multiple rodents. 

For many live traps, the type of bait used is the same as for snap traps, so a variety of foodstuffs 

will need to be tried to find an attractive bait for the rodents being targeted. Like bait stations, 

snap traps, and glue boards, live traps need to be placed in areas of rodent activity, usually along 

their runways. 

CDC (2010) does not recommend the use of live traps because of increased exposure to rodents 

that may harbor diseases. Live traps require that residential consumers find another location to 

release their rodents. Witmer and Jojola (2006) mention that live mice trapped and then 

introduced into new locations do not fare well or they cause similar problems at the new 

location. Because of the issues of humaneness as well the potential for disease transmissions, 

some state agencies are beginning to regulate the relocation of live trapped animals (Witmer and 

Jojola 2006). In addition, the number of live traps needed to control a rodent infestation is 

uncertain. 

3.3.2.4 Other Devices 

There are other devices for the residential consumer on the market including ultrasonic and 

electromagnetic. Some of these devices claim to repel rodents with sound. While rodents may 

avoid ultrasonic sounds at first, they tend to quickly acclimate to their surroundings, 

consequently there is little evidence that these devices work as a long-term deterrent. There are 

some electronic devices that electrocute rodents when they feed on bait contained in the units. 

Batteries power most of these units, and product claims range from 30 up to 100 mice killed with 
15 

one set of batteries. However, it is not clear how these devices should be placed or how many of 

these devices are recommended to eliminate a rodent infestation. 

3.3.2.5 Comparison of Rodenticides to Traps 

Not all control methods are equal. However, the registered rodenticide bait products meet EPA 

efficacy standards. The FGARs generally require rodents to feed on them for several nights to 

acquire a lethal dose. Rodents can obtain a lethal dose with one night’s feeding on the SGARs. 

However rodents take 4 to 7 days to die regardless of which anticoagulant they consume. 

Bromethalin has a different mode of action than the anticoagulants, and rodents usually obtain a 

lethal dose after one feeding, cease feeding, and die after 3 days. 

When using rodenticides, residential consumers have no control over where the rodents will die. 

Many rodents may die inside wall cavities and therefore cause a decomposing odor problem that 

may be unacceptable to some people. In addition, decomposing rodent carcasses can attract flies 

and ants, so there is a potential of an insect problem. Some rodents will die near the bait; others 

may die anywhere inside or outside the home. Residential consumers will not be able to 

determine how many rodents have been killed when they use rodenticides. Some residential 

consumers may prefer not to have to see or handle rodent carcasses, and with rodenticides they 

probably will not have to handle as many carcasses as they would with mechanical control 

methods. 

Snap traps have their advantages and disadvantages as previously described (Section 3.3.2.1). 

Traps must be checked, rebaited, and reset frequently; therefore, they are more labor intensive 

than rodenticides. However, rodents caught in traps can be disposed of quickly, there is no odor 

from decomposing rodents, and residential consumers can monitor their success of control. 

BEAD has little information on how live traps and other devices should be placed and how many 

of the devices would be needed to control minor and major infestations of rodents. There is too 

much uncertainty regarding their performance in controlling rodents. Therefore, although price 

information is provided, BEAD is not comparing these products to snap traps or rodenticide 

products. 

Regardless of what control method a residential consumer chooses, the placement will 

essentially be the same. Bait stations, snap traps, or the other devices need to be placed in the 

areas where the rodents are active, typically in their runway, and about 6 to 10 feet apart. It is 

often difficult to determine just how many rodents have invaded a home, but the amount of 

droppings helps to inform whether it is a minor infestation or a major infestation. During control 

operations, residential consumers will need to continually monitor their homes for rodent signs. 

They are likely to continue their control until signs of rodents are no longer detected. 
16 

3.4 NOIC Effects on Residential Consumers’ Ability to Control Rodents 

Successful control of rodents is dependent upon an IPM approach (Chiri, 2006, Witmer and 

Jojola, 2006; New York City, undated; Koehler and Kern, 2008). Two major cornerstones of 

rodent IPM are exclusion and sanitation. Without sanitation and exclusion, no trapping or 

rodenticide baiting program will be effective (Chiri 2006). Reducing alternative food sources 

will minimize the competition with baits, whether the bait is in a snap trap or a rodenticide bait 

(Witmer and Jojola, 2006; Chiri 2006). Rodent proofing a home is critical to eliminating 

immigration of new rodents (Chiri 2006; Witmer and Jojola, 2006). While these IPM strategies 

alone will not eliminate rodents already infesting a home, they are critical to prevent 

reinfestations and increase the success of traps or baits. 

Several extension publications and websites recommend snap traps to rid a home of rodents 

(CDC 2010; Pierce, 1993; Koehler and Kern, 2008; Hovanic et al., 2010). Snap traps are 

especially good for low infestation levels, or where rodenticide use is too hazardous, or where 

the odor of dead rodents in inaccessible places would not be acceptable (Witmer and Jojola 

2006; Chiri 2006; Pierce, 1993). However, placements of snap traps are the same as for 

rodenticide bait stations, i.e. in areas of high rodent activity. But the use of commercially 

prepared rodenticide bait blocks in a bait station reduces the need for residential consumers to 

prepare their own bait and setting of snap traps. 

Residential consumers who used non-RMD compliant rodenticide baits will still have access to 

several RMD compliant rodenticides. Residential consumers will have a choice of FGARs or 

acute rodenticide bait products after the NOIC, which meet EPA’s efficacy standards. 

For the purpose of this analysis, BEAD expects that consumers who have selected rodenticides 

in the past are likely to do so again in the future. Residential consumers probably make their 

decisions based on many factors, including but not limited to: pets, children, willingness to 

dispose of carcasses, tolerance of decomposing odors, previous experiences, and personal 

opinions regarding poisons. Therefore, whatever reasons residential consumers used to choose 

rodenticides in the past will likely hold for their future rodent control purchases. 

Based upon the movements of rodents (6 to 10 ft), extension and governments have 

recommended six placements (whether snap traps or bait stations) would be used in a low or 

minor infestation of rodents, and 12 placements would be used for a high or major infestation of 

rodents (CDC 2010; Pierce 1993; Koehler and Kern, 2008; Hovanic et al., 2010; Illinois 

Department of Public Health undated). While BEAD does not have evidence that residential 

consumers are following these recommendations, it is the basis for this assessment. In addition, 

while recognizing that the different rodenticides and snap traps operate differently, they all kill 

rodents if placed properly. Therefore, for the purpose of this comparison, while recognizing that 

these methods are not equal, rodenticides and snap traps are considered to be equivalent. 
17 

3.5 Cost Impacts 

This section presents estimates of the costs incurred by residential consumers from complying 

with the proposed mitigations versus the costs incurred in the baseline (i.e., the status quo). This 

difference in costs measures the incremental cost that homeowners would incur if the NOIC is 

implemented. 

The analysis is organized as follows. First, Section 3.5.1 provides an overview of the framework 

for this analysis. Section 3.5.2 looks at the data, while the results of the analysis are presented in 

3.5.3. The final section presents a socio-economic equity assessment of the proposed mitigation 

measures. 

3.5.1 Framework for Cost Analysis 

As previously mentioned, residential consumers will opt to continue using rodenticides postmitigation if rodenticides are their preferred rodent control method in the baseline. Therefore, 

the focus of this analysis will be on the impact on residential consumers switching from 

rodenticides that would no longer be available post-mitigation to rodenticide forms that would be 

accepted under the proposed mitigation. This analysis also is based conclusions presented in 

Section 3.4 which state that in a minor infestation, six mechanical or rodenticide placements 

provide equivalent control, while 12 mechanical or rodenticide placements provide equivalent 

control for a major infestation. 

Certain types of residential consumers derive different benefits from distinct types of rodent 

control products (see Section 3.3). For example, some residential consumers may prefer to use 

covered snap traps over traditional snap traps as they do not have to see the dead carcass. In 

addition, consumers may be facing ongoing infestations and prefer to purchase multi-pack 

rodenticides sold with bait stations over single-use bait stations. To account for these differences 

in benefits derived by consumers, the cost analysis examines impacts based on the type of rodent 

control product rather than across all products. Baseline product groupings include: (1) blockform rodenticides, (2) loose-form SGARs, (3) single-use SGARs in pre-baited, disposable bait 

stations, and (4) multi-pack SGARs in reusable bait stations. Alternative product groupings that 

would be available post-mitigation are (1) single-use FGAR/acute rodenticide blocks in prebaited, disposable bait stations, (2) multi-pack FGAR/acute rodenticide blocks in reusable bait 

stations, (3) traditional snap traps, (4) covered snap traps, (5) glue traps, (6) electronic and live 

traps; and (7) PCOs. 

Although prices for electronic and live traps are presented, the incremental costs associated with 

these control methods are not examined as BEAD is unable to determine whether these control 

methods are equivalent to rodenticides that would no longer be available under the proposed 

mitigation (see Section 3.3.2.5). This analysis also does not consider the impact on residential 

consumers from having to discontinue using rodenticides in packages that weigh greater than one 

pound; however, they are included in the averages for their respective product type. 
18 

3.5.2 Data 

Rodent control product prices were obtained from online website searches and store visits in 

northern Virginia and Pennsylvania. National chains known for carrying rodent control products 

were targeted for sampling. Prices were also provided by Bell Laboratories, the manufacturer of 

TomCat rodent control products, and H.C. Summers, a northern Virginia animal control and 

supply store. There may be some bias in using prices from a single region of the United States. 

However, in searching for prices in other U.S. regions by zip code on online retail sites, prices 

were found to be identical across the country. Furthermore, since this analysis focuses on the 

differences in prices between products, any regional bias in product prices that affects 

rodenticides as a class would cancel out. Prices for all rodent control products available at each 

store visited were collected; thus, multiple prices may exist for the same product. See Appendix 

A for product price data. 

The number of samples, average price per package, average price per placement, and the range 

of placement prices are presented in Table 3-1, for mouse control, and Table 3-2, for rat control. 

For mouse and rat control, a single placement reflects a single unit of control—i.e., one trap or 

rodenticide placement as determined by the manufacturer—for block-form rodenticides, looseform SGARs, snap traps, glue traps, and electronic and live traps. BEAD assumes for purposes 

of this analysis that each placement kills one rodent. Packages for rodent control products often 

contain more than one placement which is reflected in the price per package. The price for a 

single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. Multi-pack rodenticide products for mice are often sold with one bait station; 

therefore, the average placement price accounts for a proportion of the cost of the bait station in 

assuming that a residential consumer will reuse the bait station for chronic mouse control issues. 

For example, if a multi-pack is sold for $5 and contains one bait station and five baits, the 

placement price would be $1 (i.e., $5 divided by five baits). In some cases multiple single-use 

rodenticide placements are sold in a single package. Therefore, differences exist between the 

price of a single-use package and the price of a placement for mouse control. This does not hold 

for rats, however, as all single-use rodenticide products sampled in this analysis only contained 

one placement, thus making the package and placement price the same. 

Table 3-1. Sample Size and Average Price for Mouse Control Methods.

Control Method

Number

of

Samples

Average

Price

per

Package

Average Price

of a Single

Rodent Control

Placement1

Range of Prices across

Products for a Single

Rodent Control

Placement

Baseline: Products Proposed to be Cancelled   

Block‐Form Rodenticides2 25 $10.87 $0.74 $0.31  ‐  $2.20

SGARs, Loose Form3 24 $4.73 $1.51 $0.08  ‐  $2.55

SGARs in Pre‐Baited, Single‐Use

Bait Stations4 2 $4.48 $3.49 $1.99  ‐  $4.99

SGARs in Multi‐Packs with

Reusable Bait Stations5 5 $8.28 $0.96 $0.59  ‐  $1.37
19 

Control Method

Number

of

Samples

Average

Price

per

Package

Average Price

of a Single

Rodent Control

Placement1

Range of Prices across

Products for a Single

Rodent Control

Placement

Alternatives Under Proposed Mitigation

FGAR/Acute Rodenticide Blocks in

Pre‐Baited, Single‐Use Bait

Stations4 9 $4.92 $1.75 $1.37  ‐  $2.74

FGAR/Acute Rodenticide Block

Multi‐Pack with Reusable Bait

Stations5 10 $6.94 $0.98 $0.50  ‐  $1.99

Snap Trap, Traditional6 22 $3.80 $1.98 $0.37  ‐  $5.99

Snap Trap, Covered7 12 $5.40 $3.44 $2.12  ‐  $5.99

Glue trap 13 $3.48 $1.17 $1.99  ‐  $4.95

Electronic and Live Traps 7   $12.28 $11.86 $3.00  ‐  $24.99

PCO Cost per Infestation 3  ‐  $242.00 $225.00  ‐  $250.00

Source: In-store visits, on-line searches, phone calls to PCOs, and Bell Laboratories (2011). See Appendix A for a 

complete list of sources. Numbers may not add due to averaging. 

1 Single placements reflect a single unit of control—i.e., one trap or rodenticide placement as determined by the 

manufacturer—for block-form, loose-form second generation rodenticides, snap traps, glue traps, and electronic 

and live traps. 

2 Block-form rodenticides include both SGARs and FGARs/acutes and are defined as blocks, bars, pastes/gels, or 

other solids sold without stations. 

3 Loose-form rodenticides only include SGARs as no FGARs/acutes are available in the residential consumer 

market and are defined as bait bits, pellets, crushed pellet, treated whole-grain, meal, and powder. 

4 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. In some cases multiple single-use rodenticide placements are sold in a single package. 

Therefore, differences exist between the price of a single-use package and placement. 

5 Of the mouse control products sampled in this analysis, multi-pack rodenticide products are only sold with one 

bait station; therefore, the average placement price accounts for a proportion of the cost of the bait station in 

assuming that a residential consumer will reuse the bait station for chronic mouse control issues. 

6 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

Although these type of snap traps are typically reusable, this analysis assumes that homeowners will dispose of 

the trap with the rodent carcass. 

7 Covered snap traps include products that block the rodent carcass from a user’s view. 

For rats, BEAD was unable to locate price information for single-use SGAR and FGAR/acute 

multi-packs with reusable bait stations. However, as some households must use bait blocks in 

conjunction with a bait station (e.g., in the presence of children or pets) the average placement 

price for SGAR rodenticides for rats in multi-packs with reusable bait stations reflects the price 

of one block-form rodenticide and one bait station, purchased separately. For example, the 

average price for a package of SGAR blocks sold separately is $10.59 (see Appendix A). 

Therefore, if a residential consumer were to purchase these blocks to use within a separately 

purchased bait station (the average price of a bait station for rats is $16.40, see Appendix A), the 

total price for both packages would be $26.99. If a household were to only use one block from 

the SGAR multi-pack (average price $0.69 per block, see Appendix A) in a separately purchased 

bait station, the average price for the single placement would be $17.09. Note that a residential 

consumer could potentially purchase loose-form rodenticides to use in conjunction with a 
20 

separately purchased bait station. However, given that (based on the products sampled in this 

analysis) manufacturers have only chosen to market single-use and multi-pack rodenticides sold 

with bait stations with blocks, BEAD expects that most consumers use bait stations in 

conjunction with block-form rodenticides over loose-form rodenticides. This assumption could 

not be made for FGAR/acute multi-packs with reusable bait stations as blocks will no longer be 

sold separately under the proposed mitigation. 

Table 3-2: Sample Size and Average Price for Rat Control Methods 

Control Method

Number

of

Samples

Average

Price

per

Package

Average Price

of a Single

Rodent Control

Placement1

Range of Prices across

Products for a Single

Rodent Control

Placement

Baseline: Products Proposed to be Cancelled   

Block‐Form Rodenticides2 21 $11.03 $0.74 $0.31  ‐  $2.20

SGAR, Loose Form3 2 $5.48 $1.12 $1.00  ‐  $1.25

SGARs in Pre‐Baited, Single‐Use

Bait Stations 0 ‐ ‐    ‐    

SGARs in Multi‐Packs with

Reusable Bait Stations4 21 $27.43 $17.14 $16.71  ‐  $18.59

Alternatives Under Proposed Mitigation  

FGAR/Acute Rodenticide Blocks in

Pre‐Baited, Single‐Use Bait

Stations5 5 $8.83 $8.83 $7.29  ‐  $9.47

FGAR/Acute Rodenticide Block

Multi‐Pack with Reusable Bait

Stations4 0 ‐ ‐ ‐ 

Snap Trap, Traditional6 10 $3.69 $3.27 $1.96  ‐  $4.99

Snap Trap, Covered7 0 ‐ ‐    ‐    

Glue trap 5 $4.31 $1.89 $0.67  ‐  $2.48

Electronic and Live Traps 3 $20.81 $20.81 $4.47  ‐  $34.99

PCO Cost per Infestation 3 ‐ $249.67 $249.00  ‐  $250.00

Source: In-store visits, on-line searches, phone calls to PCOs, and Bell Laboratories (2011). See Appendix A for a 

complete list of sources. Numbers may not add due to averaging. 

1 Single placements reflect a single unit of control—i.e., one trap or rodenticide placement as determined by the 

manufacturer—for block-form, loose-form second generation rodenticides, snap traps, glue traps, and electronic 

and live traps. 

2 Block-form rodenticides include both SGARs and FGARs/acutes and are defined as blocks, bars, pastes/gels, or 

other solids sold without stations. 

3 Loose-form rodenticides only include SGARs as no FGARs/acutes are available in the residential consumer 

market and are defined as bait bits, pellets, crushed pellet, treated whole-grain, meal, and powder. 

4 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. The packages are often sold with multiple single use stations, which accounts for the 

different in cost between the package and single placement price. 

5 The average placement price of a SGAR multi-pack rodenticide for rats reflects the price of one block-form 

rodenticide and one bait station, purchased separately. The average price of a bait station for rats is $16.40. This 

assumption could not be made for FGAR/acute multi-packs with reusable bait stations as blocks cannot be sold 

separately under the proposed mitigation. 
21 

6 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

Although these type of snap traps are typically reusable, this analysis assumes that homeowners will dispose of 

the trap with the rodent carcass. 

7 Covered snap traps include products that block the rodent carcass from a user’s view. 

In some cases, rodent control product groupings, such as single-use SGARs in bait stations for 

mouse control, have small sample sizes (sample size=2) relative to other product groupings, such 

as block-form rodenticides for mice (sample size=25) (see Table 3-1). However, given the 

sampling technique of identifying all products available in a store or on a website, sample sizes 

are a reflection of product supply and consumer demand for certain types of products. Low 

sample size is thus likely to be a reflection of low use. Samples for each rodent control product 

grouping are presented in Tables 3.1 and 3.2. 

The price data collected do not indicate a difference in the price of active ingredients used in 

FGAR/acute rodenticides versus SGARs. Differences in price appear to be a function of other 

aspects, such as the type of product, packaging and brand. Prices may also vary for rodenticides 

sold with bait stations as the level of protection offered by a bait station in terms of weather and 

tamper resistance varies. EPA has grouped bait stations into four tiers that represent different 

levels of protection, with Tier 1 offering the most protection and Tier IV offering the least (see 

http://www.epa.gov/pesticides/mice-and-rats/consumer-prod.html for more details). For the 

purposes of this analysis, BEAD does not differentiate bait stations by their tiers but 

acknowledges that bait station prices may vary depending on the product’s tier. 

3.5.3 Analysis and Results 

The average costs to control rodent infestations using various types of control methods and the 

incremental costs associated with the proposed mitigation measures are discussed in this section. 

The incremental cost is the difference between the prices of products used in the baseline and the 

price of alternative products that would remain on the market after the proposed cancellations. 

The average placement prices presented in Tables 3-1 and 3-2 are used in determining residential 

consumer average expenditures for minor and major mouse and rat infestations. The analysis 

uses average price for each type of rodent control and thus represents the average change in 

expenditures on rodent control. As there is considerable variation in prices, there can be 

considerable variation in incremental costs. Additional assumptions, which will be further 

described in the forthcoming text, apply to multi-use rodenticide packs when calculating 

expenditures that are not reflected in the per placement cost. 

3.5.3.1 Mouse Control 

Table 3-3 presents the average price for minor and major infestations. The average price of a 

single rodenticide placement for mouse control (from Table 3-1) is also presented. 

As noted in Section 3.4, for all mouse control methods, the cost to control a minor infestation is 

the cost of six placements and the cost of rodent control in a major infestation is the cost of 12 
22 

placements. In a minor infestation, expenditure for multi-pack baits with a reusable bait station 

reflects the price of purchasing six packages of rodenticides in order to obtain six bait stations. 

The same holds for a major infestation, in which it is assumed that a consumer will purchase 12 

packages in order to obtain 12 bait stations. Alternatively, a consumer could purchase a multipack and enough separately sold bait stations for the type of infestation that they are facing. 

However, purchasing bait stations separately would be more expensive than purchasing multiple 

packages to obtain the needed number of bait stations. For example, if a consumer were to 

purchase a multi-pack, which contains six blocks of bait and one bait station, and five additional 

bait stations, the total cost would be $88. This is nearly $40 more than if a consumer were to 

purchase six multi-packs and use the bait station contained in the package (see Table 3-3). Since 

a rational consumer, given the choice, would purchase the multi-packs, BEAD evaluates this 

scenario. 

Table 3-3: Average Cost for a Residential Consumer to Control Minor and Major Mouse 

Infestations, Baseline and Post-Mitigation 

Control Method

Average Expenditure for

Mouse Control per

Single Rodenticide

Placement1

Average Expenditure

for Mouse Control in

a Minor Infestation2

Average Expenditure

for Mouse Control in

a Major Infestation3

Baseline: Products Proposed to be Cancelled   

Block‐Form

Rodenticides4 $0.74 $4.45 $8.90

SGARs, Loose Form5 $1.51 $9.04 $18.07

SGARs in Pre‐Baited,

Single‐Use Bait Stations6 $3.49 $20.93 $41.85

SGARs in Multi‐Packs

with Reusable Bait

Stations7 $8.28 $49.67 $99.34

Alternatives Under Proposed Mitigation  

FGAR/Acute Rodenticide

Blocks in Pre‐Baited,

Single‐Use Bait Stations6 $1.75 $10.53 $21.06

FGAR/Acute Rodenticide

Block Multi‐Pack with

Reusable Bait Stations7 $6.94 $41.66 $83.33

Snap Trap, Traditional8 $1.98 $11.89 $23.77

Snap Trap, Covered9 $3.44 $20.65 $41.30

Glue trap $1.17 $7.00 $14.01

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of 

sources. Numbers may not add due to averaging. 

1 Expenditure is the total cost of obtaining a single placement (e.g., baited station) given type of packaging. 

2 A minor infestation is defined as a residential consumer needing six rodent control placements. 

3 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

4 Block-form rodenticides include both SGARs and FGARs/acutes and are defined as blocks, bars, pastes/gels, or 

other solids sold without stations. 
23 

3 Loose-form rodenticides only include SGARs and no FGARs/acutes are available in the residential consumer 

market and are defined as bait bits, pellets, crushed pellet, treated whole-grain, meal, and powder. 

4 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 

5 Multi-pack rodenticide products are only sold with one bait station; therefore, the average placement price 

accounts for a proportion of the cost of the bait station in assuming that a residential consumer will reuse the bait 

station for chronic mouse control issues. The prices for the infestation scenarios reflect the cost from purchasing 

enough packages to acquire the needed number of bait station for a minor infestation (six traps) and major 

infestation (12 traps). For this reason, the average expenditure per rodenticide placement for multi-pack 

rodenticides with bait stations reflects the average price per package rather than the price per placement. 

6 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

7 Covered snap traps include products that block the rodent carcass from a user’s view. 

In both minor and major mouse infestations, multi-pack SGARs in bait stations are the most 

expensive baseline rodent control option, followed by single-use SGARs in bait stations. Blockform rodenticides are the most affordable option across all rodenticide control methods 

considered in this analysis. Of the mouse control alternatives that would be available under the 

proposed mitigation, multi-pack FGAR/acute rodenticide blocks in bait stations are the most 

expensive option while glue traps are the least expensive. Overall, prices for residential 

consumer products to control mice in the baseline range from $0.74 to $8.28 per placement, 

$4.45 to $49.67 to control a minor infestation, and $8.90 to $99.34 to control a major infestation. 

Prices for rodent control alternatives that would be available under the proposed mitigation range 

from $1.17 to $6.94 per placement, $7.00 to $41.66 in a minor infestation, and $14.01 to $83.33 

in a major infestation. 

Tables 3-4 through 3-7 present the incremental costs associated with switching from mouse 

control methods that would be cancelled to ones that would remain available after the proposed 

cancellations. Each table focuses on a separate baseline mouse control option and presents the 

incremental cost associated with minor and major infestations. 

Table 3-4 presents the incremental costs associated with switching from block-form rodenticides 

to alternatives that would be available under the proposed mitigation. In a minor infestation, the 

average cost for block-form rodenticides is $4.45 while the alternatives range in cost from $7.00 

to $41.66. Incremental costs from switching to available alternatives under the proposed 

mitigation range from $2.55 (glue trap) to $37.21 (multi-pack FGAR/acute rodenticide blocks in 

bait stations). Consumers currently using block-form rodenticides will likely turn to single-use 

FGAR/acute rodenticide blocks in bait stations, as it is the most similar product that would be 

available post-mitigation. This switch would result in average incremental costs of $6.08 in a 

minor infestation (Table 3.4). 

In a major infestation, the average cost for block-form rodenticides is $8.90. The incremental 

cost of switching to the available alternatives under the proposed mitigation for major 

infestations range from $5.11 (glue trap) to $74.43 (multi-pack FGAR/acute rodenticide blocks 

in reusable bait stations). If a consumer were to choose to continue using rodenticides, 

incremental costs would be $12.16 in the case that they switch to single-use FGAR/acute 

rodenticides in bait stations. Using traditional snap traps would imply a similar increase in cost 

while employing glue traps would entail a smaller increase. However, there are non-monetary 
24 

costs associated with these options, including disposal of dead or nearly dead mice. Snap traps 

also have to be baited by the consumer. 

Table 3-4: Incremental Costs Incurred by Residential Consumers Switching from BlockForm Rodenticides to Alternatives Accepted Under the Proposed Cancellations, Mouse 

Control 

Minor Infestation1 Major Infestation2

Cost per

Infestation

($)

Incremental

Cost3

Cost per

Infestation

($)

Incremental

Cost3

Baseline: Block‐Form Rodenticides4 $4.45 ‐ $8.90  ‐

Alternatives

Under the

Proposed

Mitigation

FGAR/Acute Rodenticide

Blocks in Pre‐Baited,

Single‐Use Bait Stations5 $10.53 $6.08 $21.06 $12.16

FGAR/Acute Rodenticide

Block Multi‐Pack with

Reusable Bait Stations6 $41.66 $37.21 $83.33 $74.43

Snap Trap, Traditional7,8 $11.89 $7.43 $23.77 $14.87

Snap Trap, Covered7,9 $20.65 $16.20 $41.30 $32.40

Glue trap7 $7.00 $2.55 $14.01 $5.11

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of 

sources. Numbers may not add due to averaging. 

1 A minor infestation is defined as a residential consumer needing six rodent control placements. 

2 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

3 Incremental costs are calculated as the cost of each rodent control option less the baseline cost (i.e., the current 

cost of control). 

4 Block-form rodenticides include both SGARs and FGARs/acutes and are defined as blocks, bars, pastes/gels, or 

other solids sold without stations. 

5 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 

6 Of the mouse control products sampled in this analysis, multi-pack rodenticide products are only sold with one 

bait station; therefore, the average placement price accounts for a proportion of the cost of the bait station in 

assuming that a residential consumer will reuse the bait station for chronic mouse control issues. The prices for 

the infestation scenarios reflect the cost from purchasing enough packages to acquire the needed number of bait 

station for a minor infestation (six traps) and major infestation (12 traps). For this reason, the average expenditure 

per rodenticide placement for multi-pack rodenticides with bait stations reflects the average price per package 

rather than the price per placement. 

7 Single placements reflect a single unit of control—i.e., one trap or rodenticide placement as determined by the 

manufacturer—for block-form, loose-form second generation rodenticides, snap traps, glue traps, and electronic 

and live traps. 

8 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

9 Covered snap traps include products that block the rodent carcass from a user’s view. 

Table 3-5 presents the incremental costs associated with switching from loose-form rodenticides 

to alternatives that would be available under the proposed mitigation. In a minor infestation, the 

average cost for loose-form rodenticides is $9.04 while, again, alternatives range in cost from 

$7.00 to $41.66. Consumers will most likely choose to continue using rodenticides in the 

absence of loose-form rodenticides, which suggests, based on the available data, an incremental 
25 

costs for consumers of $1.49 to control mice in a minor infestation when switching to single-use 

FGAR/acute rodenticide blocks in bait stations. 

In a major infestation, a residential consumer would likely be facing incremental costs of $2.98, 

representing a switch to single-use FGAR/acute rodenticides in bait stations. As in the 

comparison to block-forms, traditional snap traps would be a slightly more costly option and 

entail additional effort in baiting and checking traps and involve disposal of carcasses. Use of 

glue traps are already less costly than loose-form SGARs, but users face non-monetary costs 

including the likelihood of finding still-living mice stuck in the traps. 

Table 3-5: Incremental Costs Incurred by Residential Consumers Switching from LooseForm SGARs to Alternatives Accepted Under the Proposed Cancellations, Mouse Control 

Minor Infestation1 Major Infestation2

Cost per

Infestation

($)

Incremental

Cost3

Cost per

Infestation

($)

Incremental

Cost

Baseline: Loose‐Form SGARs 4   $9.04 ‐ $18.07  ‐

Alternatives

Under the

Proposed

Mitigation

FGAR/Acute Rodenticide

Blocks in Pre‐Baited,

Single‐Use Bait Stations5 $10.53 $1.49 $21.06 $2.98

FGAR/Acute Rodenticide

Block Multi‐Pack with

Reusable Bait Stations6 $41.66 $32.63 $83.33 $65.26

Snap Trap, Traditional7,8 $11.89 $2.85 $23.77 $5.70

Snap Trap, Covered7,9 $20.65 $11.61 $41.30 $23.23

Glue trap7 $7.00 ‐$2.03 $14.01  ‐$4.07

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of 

sources. Numbers may not add due to averaging. 

1 A minor infestation is defined as a residential consumer needing six rodent control placements. 

2 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

3 Incremental costs are calculated as the cost of each rodent control option less the baseline cost (i.e., the current 

cost of control). 

4 Loose-form rodenticides only include SGARs and no FGARs/acutes are available in the residential consumer 

market and are defined as bait bits, pellets, crushed pellet, treated whole-grain, meal, and powder. 

5 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 

6 Of the mouse control products sampled in this analysis, multi-pack rodenticide products are only sold with one 

bait station; therefore, the average placement price accounts for a proportion of the cost of the bait station in 

assuming that a residential consumer will reuse the bait station for chronic mouse control issues. The prices for 

the infestation scenarios reflect the cost from purchasing enough packages to acquire the needed number of bait 

station for a minor infestation (six traps) and major infestation (12 traps). 

7 Single placements reflect a single unit of control—i.e., one trap or rodenticide placement as determined by the 

manufacturer—for block-form, loose-form second generation rodenticides, snap traps, glue traps, and electronic 

and live traps. 

8 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

9 Covered snap traps include products that block the rodent carcass from a user’s view. 
26 

Table 3-6 presents the incremental cost associated with switching from single-use SGAR 

rodenticides in bait stations to alternative rodent control methods that would be available under 

the proposed mitigation. In a minor infestation, the average cost of a single-use SGAR in a bait 

station is $20.93. The cost from switching to available alternatives ranges from a cost savings of 

$13.92 (glue traps) to a cost increase of $20.74 (muti-pack FGAR/acute rodenticide blocks in 

reusable bait stations). Most likely, consumers will choose to continue using the most similar 

rodenticide product—single-use FGAR/acute rodenticide blocks in bait stations—in the absence 

of single-use SGARs in bait stations and could see cost savings of $10.40 for minor infestations. 

In a major infestation, consumers could save, on average, $20.79 per major infestation if they 

switch from SGARs in pre-baited, single-use bait stations to single-use FGAR/acute rodenticides 

in bait stations. However, cost savings from an action that reduces consumer choice is unlikely 

as there are non-monetary costs that consumers may incur. In this case, there may be some 

perceived benefit to the use of SGARs since they advertise control with a single night’s feeding, 

compared to FGARs/acutes that generally require multiple feedings to deliver a lethal dose. 

However, as discussed in Section 3.4, this will not generally lead to differences in overall 

performance. A mouse may obtain a lethal dose in one feeding, but several days may pass 

before death occurs during which time the homeowner will continue to see signs and will need to 

maintain bait placements. The estimated cost saving could also be a function of the small sample 

sizes and variability in observed prices rather than actual differences in price. The small sample 

sizes could also indicate limited availability of rodenticides in this form. Ultimately, BEAD 

concludes that the cancellation of SGARs in single use bait stations will not negatively affect a 

consumer’s ability to control rodents. 

Table 3-6: Incremental Costs Incurred by Residential Consumers Switching from SGARs 

in Pre-Baited, Single-Use Bait Stations to Alternatives Accepted Under the Proposed 

Cancellations, Mouse Control 

Minor Infestation1 Major Infestation2

Cost per

Infestation

($)

Incremental

Cost3

Cost per

Infestation

($)

Incremental

Cost

Baseline: SGARs in Pre‐Baited, Single‐

Use Bait Stations5 $20.93 ‐ $41.85  ‐

Alternatives

Under the

Proposed

Mitigation

FGAR/Acute

Rodenticide Blocks in

Pre‐Baited, Single‐

Use Bait Stations4 $10.53 ‐$10.40 $21.06  ‐$20.79

FGAR/Acute

Rodenticide Block

Multi‐Pack with

Reusable Bait

Stations5 $41.66 $20.74 $83.33 $41.48

Snap Trap,

Traditional6,7 $11.89 ‐$9.04 $23.77  ‐$18.08

Snap Trap,

Covered6,8 $20.65 ‐$0.28 $41.30  ‐$0.55
27 

Minor Infestation1 Major Infestation2

Cost per

Infestation

($)

Incremental

Cost3

Cost per

Infestation

($)

Incremental

Cost

Baseline: SGARs in Pre‐Baited, Single‐

Use Bait Stations5 $20.93 ‐ $41.85  ‐

Glue trap6 $7.00 ‐$13.92 $14.01  ‐$27.84

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of 

sources. Numbers may not add due to averaging. 

1 A minor infestation is defined as a residential consumer needing six rodent control placements. 

2 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

3 Incremental costs are calculated as the cost of each rodent control option less the baseline cost (i.e., the current 

cost of control). 

4 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 

5 Of the mouse control products sampled in this analysis, multi-pack rodenticide products are only sold with one 

bait station; therefore, the average placement price accounts for a proportion of the cost of the bait station in 

assuming that a residential consumer will reuse the bait station for chronic mouse control issues. The prices for 

the infestation scenarios reflect the cost from purchasing enough packages to acquire the needed number of bait 

station for a minor infestation (six traps) and major infestation (12 traps). 

6 Single placements reflect a single unit of control—i.e., one trap or rodenticide placement as determined by the 

manufacturer—for block-form, loose-form second generation rodenticides, snap traps, glue traps, and electronic 

and live traps. 

7 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

8 Covered snap traps include products that block the rodent carcass from a user’s view. 

Table 3-7 presents the incremental costs associated with switching from SGARs in multi-packs 

with reusable bait stations to the alternative rodent control methods that would be available under 

the proposed mitigation. BEAD estimates the cost of controlling a minor infestation with this 

type of product to be $49.67. Alternatives that would be available post-mitigation are less 

expensive, suggesting a cost savings ranging from $8.00 to $42.66. Most likely, consumers that 

are currently using SGARs in multi-packs with reusable bait stations would switch to FGARs in 

multi-packs with reusable stations post-mitigation. Here, consumers would, on average, save 

$39.14 with a minor infestation and $78.28 with a major infestation. However, the use of 

reusable bait stations may indicate a chronic mouse problem that may not be adequately 

represented by the single infestation scenarios used in this analysis. As discussed above, the 

estimated cost savings may indicate a perceived benefit from SGARs or may be a function of 

price variability and/or product availability. However, these results clearly suggest that there 

will be little or no negative effect on consumers if the registrations of SGARs in reusable stations 

are cancelled. 

Table 3-7: Incremental Cost from Switching from Multi-Pack SGARs in Bait Stations to 

Mouse Control Products Accepted Under the Proposed Cancellations, Mouse Control 

Minor Infestation1 Major Infestation2

Cost per

Infestation

($)

Incremental

Cost3

Cost per

Infestation

($)

Incremental

Cost

Baseline: SGARs in Multi‐Packs with Reusable

Bait Stations5 $49.67 ‐ $99.34  ‐
28 

Minor Infestation1 Major Infestation2

Cost per Incremental

3

Cost per Incremental

Alternatives Under

the Proposed

Mitigation

FGAR/Acute Rodenticide

Blocks in Pre‐Baited,

Single‐Use Bait Stations5 $10.53 ‐$39.14 $21.06  ‐$78.28

FGAR/Acute Rodenticide

Block Multi‐Pack with

Reusable Bait Stations4 $41.66 ‐$8.00 $83.33  ‐$16.01

Snap Trap, Traditional6,7 $11.89 ‐$37.78 $23.77  ‐$75.57

Snap Trap, Covered6,8 $20.65 ‐$29.02 $41.30  ‐$58.04

Glue trap6 $7.00 ‐$42.66 $14.01  ‐$85.33

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of 

sources. Numbers may not add due to averaging. 

1 A minor infestation is defined as a residential consumer needing six rodent control placements. 

2 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

3 Incremental costs are calculated as the cost of each rodent control option less the baseline cost (i.e., the current 

cost of control). 

4 Of the mouse control products sampled in this analysis, multi-pack rodenticide products are only sold with one 

bait station; therefore, the average placement price accounts for a proportion of the cost of the bait station in 

assuming that a residential consumer will reuse the bait station for chronic mouse control issues. The prices for 

the infestation scenarios reflect the cost from purchasing enough packages to acquire the needed number of bait 

station for a minor infestation (six traps) and major infestation (12 traps). 

5 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 

6 Single placements reflect a single unit of control—i.e., one trap or rodenticide placement as determined by the 

manufacturer—for block-form, loose-form second generation rodenticides, snap traps, glue traps, and electronic 

and live traps 

7 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

8 Covered snap traps include products that block the rodent carcass from a user’s view. 

The incremental costs across all rodent control methods are summarized in Table 3-8. Generally, 

residential consumers currently using block-form rodenticides will incur the most cost from 

having to comply with the proposed mitigation, while residential consumers using multi-pack 

SGAR rodenticides with reusable bait stations will incur the least costs. However, with 60% of 

rodenticides sales being for place packs and 90% of rodenticides sales being for products that 

control mice (Kline, 2006), the switch from loose-form rodenticide placements to the most 

similar rodenticide that would be available post-mitigation (i.e., single-use FGAR/acute 

rodenticides in bait stations) for mouse control will impact the largest proportion of residential 

consumers that are choosing to use rodenticides. That is, most residential consumer will see an 

average increase in cost of $1.49 in a minor infestation to $2.98 in a major infestation, with an 

average increase placement price of $0.24. 
29 

Table 3-8: Incremental Cost Comparison Across Rodent Control Methods, Mice.

Alternatives Under

Proposed Mitigation

Block‐Form

Rodenticides1

SGAR,

Loose‐Form2

SGARs in Pre‐Baited,

Single‐Use Bait Stations3

SGARs in Multi‐P

Reusable Bait S

Incremental Cost5 Incremental Cost5 Incremental Cost5 Incremental C

Minor

Infestation6

Major

Infestation7

Minor

Infestation6

Major

Infestation7

Minor

Infestation6

Major

Infestation7

Minor

Infestation6

In

FGAR/AcuteRodenticide Blocks in

Pre‐Baited, Single‐UseBait Stations3 $6.08 $12.16 $1.49 $2.98  ‐$10.40  ‐$20.79  ‐$39.14  

FGAR/AcuteRodenticide BlockMulti‐Pack with

Reusable Bait Stations4 $37.21 $74.43 $32.63 $65.26 $20.74 $41.48  ‐$8.00  

Snap Trap, Traditional8,9 $7.43 $14.87 $2.85 $5.70  ‐$9.04  ‐$18.08  ‐$37.78  Snap Trap, Covered8,10 $16.20 $32.40 $11.61 $23.23  ‐$0.28  ‐$0.55  ‐$29.02  Glue trap8 $2.55 $5.11  ‐$2.03  ‐$4.07  ‐$13.92  ‐$27.84  ‐$42.66  

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of sources. Numbers may n

1 Block-form rodenticides include both SGARs and FGARs/acutes and are defined as blocks, bars, pastes/gels, or other solids sold wi2 Loose-form rodenticides only include SGARs and no FGARs/acutes are available in the residential consumer market and are define

crushed pellet, treated whole-grain, meal, and powder. 

3 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited disposable station. 

4 Of the mouse control products sampled in this analysis, multi-pack rodenticide products are only sold with one bait station; therefor

price accounts for a proportion of the cost of the bait station in assuming that a residential consumer will reuse the bait station for ch

issues. The prices for the infestation scenarios reflect the cost from purchasing enough packages to acquire the needed number of b

infestation (six traps) and major infestation (12 traps). 

5 Incremental costs are calculated as the cost of each rodent control option less the baseline cost (i.e., the current cost of control). 

6 A minor infestation is defined as a residential consumer needing six rodent control placements. 7 A major infestation is defined as a residential consumer needing 12 rodent control placements. 8 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited disposable station. 9 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

10 Covered snap traps include products that block the rodent carcass from a user’s view. 
30 

3.5.3.2 Rat Control 

Although incremental costs faced by residential consumers treating for rats differs in comparison 

to costs being faced when treating for mice, the general method of comparing baseline costs to 

costs incurred when adopting alternatives available under the proposed mitigation is similar 

between the two. Table 3-9 presents the average price of rat control options per placement and 

for minor and major infestations. The average price of a single rodenticide placement for 

controlling rats from Table 3-2 is also presented. 

Table 3-9: Average Price Faced by a Residential Consumer Treating for Minor and Major 

Rat Infestations 

Control Method

Average Expenditure

for Rat Control per

Single Rodenticide

Placement1

Average Expenditure

for Rat Control in a

Minor Infestation2

Average Expenditure

for Rat Control in a

Major Infestation3

Baseline‐ Products Proposed to be Cancelled   

Block‐Form Rodenticides4 $0.74 $4.46 $8.92

SGARs, Loose Form5 $1.12 $6.73 $13.46

SGARs in Pre‐Baited,

Single‐Use Bait Stations6

 ‐ ‐ ‐

SGARs in Multi‐Packs

with Reusable Bait

Stations7 $17.14 $102.83 $199.01

Alternatives Under Proposed Mitigation  

FGAR/Acute Rodenticide

Blocks in Pre‐Baited,

Single‐Use Bait Stations6 $8.83 $53.00 $106.01

FGAR/Acute Rodenticide

Block Multi‐Pack with

Reusable Bait Stations7

 ‐‐‐

Snap Trap, Traditional8 $3.27 $19.62 $39.23

Snap Trap, Covered9  ‐‐‐

Glue trap $1.89 $11.35 $22.69

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of 

sources. Numbers may not add due to averaging. 

1 Expenditure is the total cost of obtaining a single placement (e.g., baited station) given type of packaging . 

2 A minor infestation is defined as a residential consumer needing six rodent control placements. 

3 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

4 Block-form rodenticides include both SGARs and FGARs/acutes and are defined as blocks, bars, pastes/gels, or 

other solids sold without stations. 

5 Loose-form rodenticides only include SGARs and no FGARs/acutes are available in the residential consumer 

market and are defined as bait bits, pellets, crushed pellet, treated whole-grain, meal, and powder. 

6 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 
31 

7 The average placement price of a SGAR multi-pack rodenticide for rats reflects the average price of one blockform rodenticide ($0.74/placement) and one bait station ($16.40), purchased separately. The prices for the 

infestation scenarios reflect the cost from purchasing enough block rodenticides and separately sold bait stations 

needed for a minor infestation (six block and six traps) and major infestation (12 blocks and 12 traps). This 

assumption could not be made for FGAR/acute multi-packs with reusable bait stations as blocks cannot be sold 

separately under the proposed mitigation. 

8 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

9 Covered snap traps include products that block the rodent carcass from a user’s view. 

As in the case of mouse control, the cost of rodent control in a minor infestation and major 

infestation reflects six and 12 placements, respectively. As mentioned in Section 3.5.2, the 

methodology for determining the placement price for multi-pack rodenticides in bait stations 

differs from that used in the mouse control scenario. That is, for rat control, since no multi-packs 

are sold with a bait station, it is assumed that multi-pack rodenticides are used in conjunction 

with bait stations purchased separately which cost, on average, $16.40 per station. Therefore, in 

a minor infestation six separately purchased bait stations and six blocks from a multi-pack would 

be necessary for control while 12 separately purchased stations and 12 blocks from a multi-pack 

would be needed for a major infestation. Note that this only holds for multi-pack SGARs premitigation, as blocks cannot be sold separately from a bait station post-mitigation. 

Although actual costs of mouse and rat control options differ, mouse and rat control show 

somewhat similar differences in the relative prices of alternatives. For rat control, SGAR multipack rodenticides in bait stations are the most expensive, followed by SGAR single-use 

rodenticide in bait stations. Block-form rodenticides are the most affordable option across all 

rodenticide control methods considered in this analysis. Prices for rat control products in the 

baseline range from $0.74 to $17.14 per placement, $4.46 to $102.83 in a minor infestation, and 

$8.92 to $199.01 in a major infestation (Table 3-9). 

Of the rat control alternatives that would be available post-mitigation, single-use FGAR/acute 

rodenticide blocks in bait stations are the most expensive option while glue traps are the least 

expensive. Prices for rat control alternatives that would be available under the proposed 

mitigation range from $1.89 to $8.83 per placement. Costs range from $11.35 to $53.00 to 

control a minor infestation and $22.69 to $106.01 to control a major infestation (Table 3-9). 

Tables 3-10 through 3-12 present the incremental costs associated with switching from rat 

control methods that would be canceled to alternatives that would remain available under the 

proposed mitigation. Each table focuses on a separate baseline rat control option and presents 

the incremental cost associated with minor and major infestations. 

Table 3-10 presents the incremental costs associated with switching from block-form 

rodenticides to alternatives that would be available under the proposed mitigation. In a minor 

infestation, the average cost for block-form rodenticides is $4.46. The cost of switching from 

this form of rodent control to the alternatives available under the proposed mitigation for a minor 

infestation ranges from $6.89 (glue trap) to $48.55 (single-use FGAR/acute rodenticide blocks 

with stations). Most likely, consumers would choose to continue using rodent control methods 

post-mitigation that are most similar to those they are currently using. For consumers currently 

using block-form rodenticides, the most similar alternative is single-use FGAR/acute rodenticide 
32 

blocks in bait stations, which again would result in incremental costs of $48.55 per minor 

infestation. 

In a major infestation, the average cost for block-form rodenticides is $8.92, and the cost of 

switching to the available alternatives under the proposed mitigation ranges from $13.78 (glue 

trap) to $97.09 (single-use FGAR/acute rodenticide blocks in bait stations). Again, it is most 

likely that consumers would choose to continue using rodenticides most similar to those that 

would not be available post-mitigation, which in this case is FGAR/acute rodenticide blocks with 

stations. If a consumer were to make this switch, incremental costs would be $97.09. 

Incremental costs would be much lower if a consumer were to use snap or glue traps, but as with 

mouse control, these measures would entail non-monetary costs including greater effort in 

setting traps and in disposing of dead or nearly dead rats. These non-monetary costs may be 

substantially higher in the case of rats than with mice. 

Table 3-10: Incremental Costs Incurred by Residential Consumers Switching from BlockForm Rodenticides to Alternatives Accepted Under the Proposed Cancellations, Rat 

Control 

Minor Infestation1 Major Infestation2

Cost per

Infestation

($)

Incremental

Cost3

Cost per

Infestation

($)

Incremental

Cost  

Baseline: Block‐Form Rodenticides4 $4.46 ‐ $8.92  ‐

Alternatives

Under the

Proposed

Mitigation

FGAR/Acute

Rodenticide Blocks in

Pre‐Baited, Single‐Use

Bait Stations5 $53.00 $48.55 $106.01 $97.09

FGAR/Acute

Rodenticide Block

Multi‐Pack with

Reusable Bait

Stations6

  ‐ ‐ ‐  ‐

Snap Trap,

Traditional7,8 $19.62 $15.16 $39.23 $30.32

Snap Trap, Covered7,9  ‐ ‐ ‐  ‐

Glue trap7 $11.35 $6.89 $22.69 $13.78

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of 

sources. Numbers may not add due to averaging. 

1 A minor infestation is defined as a residential consumer needing six rodent control placements. 

2 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

3 Incremental costs are calculated as the cost of each rodent control option less the baseline cost (i.e., the current 

cost of control). 

4 Block-form rodenticides include both SGARs and FGARs/acutes and are defined as blocks, bars, pastes/gels, or 

other solids sold without stations. 

5 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 

6 FGAR/acute rodenticide multi-pack blocks with bait stations for rat control are not considered since (1) no 

products packaged with both blocks and bait stations were identified based on the market research completed for 

this analysis and (2) blocks cannot be sold separately from a bait station under the proposed mitigation. 
33 

7 Single placements reflect a single unit of control—i.e., one trap or rodenticide placement as determined by the 

manufacturer—for block-form, loose-form second generation rodenticides, snap traps, glue traps, and electronic 

and live traps. 

8 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

9 Covered snap traps include products that block the rodent carcass from a user’s view. 

Table 3-11 presents the incremental costs associated with switching from loose-form 

rodenticides to alternatives that would be available under the proposed mitigation. In a minor rat 

infestation, the average cost for loose-form rodenticides is $6.73. The cost of switching to the 

available alternatives under the proposed mitigation ranges from $4.62 (glue trap) to 46.28 

(single-use FGAR/acute rodenticide blocks in bait stations). With single-use FGAR/acute 

rodenticide blocks in bait stations being the most similar product to loose-form rodenticides that 

would be available post-mitigation, residential consumers will most likely face incremental costs 

of $46.28 per minor infestation. 

In a major infestation, the average cost for loose-form rodenticides is $13.46 and the cost of 

switching to the alternatives available under the proposed mitigation ranges from $9.24 (glue 

trap) to $92.55 (single-use FGAR/acute rodenticide blocks in bait stations). Again, if a 

consumer were to choose to continue using rodenticides to control rats, post-mitigation, the most 

similar rodenticide that would be available is single-use FGAR/acute rodenticide blocks in bait 

stations, resulting in average incremental costs of $92.55. 

Table 3-11: Incremental Costs Incurred by Residential Consumers Switching from LooseForm SGARs to Alternatives Accepted Under the Proposed Cancellations, Rat Control 

Minor Infestation1 Major Infestation2

Cost per

Infestation

($)

Incremental

Cost3

Cost per

Infestation

($)

Incremental

Cost3

Baseline: Loose‐Form SGARs4   $6.73 ‐ $13.46  ‐

Alternatives

Under the

Proposed

Mitigation

FGAR/Acute

Rodenticide Blocks in

Pre‐Baited, Single‐Use

Bait Stations5 $53.00 $46.28 $106.01 $92.55

FGAR/Acute

Rodenticide Block

Multi‐Pack with

Reusable Bait

Stations6

  ‐ ‐ ‐  ‐

Snap Trap,

Traditional7,8 $19.62 $12.89 $39.23 $25.78

Snap Trap, Covered7,9  ‐ ‐ ‐  ‐

Glue trap7 $11.35 $4.62 $22.69 $9.24

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of 

sources. Numbers may not add due to averaging. 

1 A minor infestation is defined as a residential consumer needing six rodent control placements. 

2 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

3 Incremental costs are calculated as the cost of each rodent control option less the baseline cost (i.e., the current 

cost of control). 
34 

4 Loose-form rodenticides only include SGARs and no FGARs/acutes are available in the residential consumer 

market and are defined as bait bits, pellets, crushed pellet, treated whole-grain, meal, and powder. 

5 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 

6 FGAR/acute rodenticide multi-pack blocks with bait stations for rat control are not considered since (1) no 

products packaged with both blocks and bait stations were identified based on the market research completed for 

this analysis and (2) blocks cannot be sold separately from a bait station under the proposed mitigation. 7 

Single placements reflect a single unit of control—i.e., one trap or rodenticide placement as determined by the 

manufacturer—for block-form, loose-form second generation rodenticides, snap traps, glue traps, and electronic 

and live traps. 

8 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

9 Covered snap traps include products that block the rodent carcass from a user’s view. 

No samples were found for single-use SGARs in bait stations, suggesting that these products are 

not currently marketed to homeowners. Table 3-12 presents the incremental costs from 

switching from SGARs for rats in multi-packs with reusable bait stations to rat control products 

available under the proposed mitigation. Although BEAD expects that residential consumers 

would prefer to continue using multi-pack rodenticides, no samples were found for RMDcompliant multi-packs rodenticides which, again, suggests that such products are not currently 

available in the market. The switch from multi-pack SGARs with reusable bait stations to any of 

the currently available RMD-compliant rodent control methods would result in a cost savings for 

residential consumers in both the minor and major infestation scenarios. In a minor infestation, 

the average cost for SGARs in multi-packs with reusable bait stations is $102.83 and the cost 

savings from switching to the available alternatives is as much as $91.48 (glue trap). Most 

likely, however, consumers will choose to continue using rodenticides, which implies they will 

adopt single-use FGAR/acute rodenticide blocks in bait stations. In this case there is a potential 

cost savings of $49.82. 

In a major infestation, the average cost for SGARs in multi-packs with reusable rat bait stations 

is $199.01. The cost savings for homeowners is as much as $176.32 (glue trap), while switching 

to the single-use FGAR/acute rodenticide blocks with bait stations will result in a cost savings of 

$93.00in a major infestation. In both minor and major infestations, cost savings may entail nonmonetary costs, as in the use of mechanical control measures, or would ultimately be more 

expensive given that the use of multi-packs suggests a chronic rat problem rather than a single 

infestation. 

Table 3-12: Incremental Cost from Switching from SGARs in Multi-Packs with Reusable 

Bait Stationsto Alternatives Accepted Under the Proposed Cancellations, Rat Control 

Minor Infestation1 Major Infestation2

Cost per

Infestation

($)

Incremental

Cost3

Cost per

Infestation

($)

Incremental

Cost  

Baseline: SGARs in Multi‐Packs with

Reusable Bait Stations4 $102.83 ‐ $199.01  ‐

Alternatives

Under the

Proposed

Mitigation

FGAR/Acute

Rodenticide Blocks in

Pre‐Baited, Single‐

Use Bait Stations5 $53.00 ‐$49.82 $106.01  ‐$93.00
35 

Minor Infestation1 Major Infestation2

Cost per

Infestation

($)

Incremental

Cost3

Cost per

Infestation

($)

Incremental

Cost  

Baseline: SGARs in Multi‐Packs with

Reusable Bait Stations4 $102.83 ‐ $199.01  ‐

FGAR/Acute

Rodenticide Block

Multi‐Pack with

Reusable Bait

Stations4

  ‐ ‐ ‐  ‐

Snap Trap,

Traditional6,7 $19.62 ‐$83.21 $39.23  ‐$159.77

Snap Trap, Covered6,8  ‐ ‐ ‐  ‐

Glue trap6 $11.35 ‐$91.48 $22.69  ‐$176.32

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of 

sources. Numbers may not add due to averaging. 

1 A minor infestation is defined as a residential consumer needing six rodent control placements. 

2 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

3 Incremental costs are calculated as the cost of each rodent control option less the baseline cost (i.e., the current 

cost of control). 

4 The average placement price of a SGAR multi-pack rodenticide for rats reflects the price of one block-form 

rodenticide and one bait station, purchased separately. The prices for the infestation scenarios reflect the cost 

from purchasing enough block rodenticides and separately sold bait stations needed for a minor infestation (six 

block and six traps) and major infestation (12 blocks and 12 traps). FGAR/acute rodenticide multi-pack blocks 

with bait stations for rat control are not considered since (1) no products packaged with both blocks and bait 

stations were identified based on the market research completed for this analysis and (2) blocks cannot be sold 

separately from a bait station under the proposed mitigation. 

5 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 

6 Single placements reflect a single unit of control—i.e., one trap or rodenticide placement as determined by the 

manufacturer—for block-form, loose-form second generation rodenticides, snap traps, glue traps, and electronic 

and live traps 

7 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

8 Covered snap traps include products that block the rodent carcass from a user’s view. 

A comparison of the incremental costs associated with each scenario for rat control is presented 

in Table 3-13. In general, the switch from block- and loose-form rodenticides to alternative 

rodent control methods available under the proposed mitigation is similar in terms of their impact 

on residential consumers. The smallest impacts would be felt by residential consumers that are 

currently using multi-pack SGARs in bait stations. As in the case of mouse control, with 60% of 

rodenticide sales being for place packs (Kline, 2006), the most likely switch that a residential 

consumer will make for rat control is from loose-form rodenticide placements to the most similar 

rodenticide that would be available post-mitigation for rat control (i.e., single-use FGAR/acute 

rodenticides in bait stations). As previously mentioned, residential consumers currently using 

loose-form rodenticides would, on average, incur incremental costs of $46.28 in a minor 

infestation and $92.55 in a major infestation. Only a small proportion of all residential 

consumers currently using rodenticides are expected to incur these costs, however, as rat control 

products make up 10% of rodenticide sales and only a portion of these sales are for loose-form 

rodenticides. 
36 

Table 3-13: Incremental Cost Comparison across Rodent Control Methods, Rats 

Alternatives

Under the

Proposed

Mitigation  

Block‐Form

Rodenticides1

SGAR,

Loose‐Form2

SGARs in Multi‐Packs

with Reusable Bait

Stations3

Incremental Cost4 Incremental Cost4 Incremental Cost4

Minor  

Infestation5

Major

Infestation6

Minor

Infestation5

Minor

Infestation6

Major

Infestation5

  

Minor

Infestation6

FGAR/Acute

Rodenticide

Blocks in Pre‐

Baited, Single‐Use

Bait Stations7 $48.55 $97.09 $46.28 $92.55 ‐$49.82  ‐$93.00

FGAR/Acute

Rodenticide Block

Multi‐Pack with

Reusable Bait

Stations3

  ‐  ‐ ‐ ‐ ‐  ‐

Snap Trap,

Traditional8,9 $15.16 $30.32 $12.89 $25.78 ‐$83.21  ‐$159.77

Snap Trap,

Covered8,10  ‐  ‐ ‐ ‐ ‐  ‐

Glue trap8 $6.89 $13.78 $4.62 $9.24 ‐$91.48  ‐$176.32

Source: In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list of 

sources. Numbers may not add due to averaging. 

1 Block-form rodenticides include both SGARs and FGARs/acutes and are defined as blocks, bars, pastes/gels, or 

other solids sold without stations. 

2 Loose-form rodenticides only include SGARs and no FGARs/acutes are available in the residential consumer 

market and are defined as bait bits, pellets, crushed pellet, treated whole-grain, meal, and powder. 

3 The average placement price of a SGAR multi-pack rodenticide for rats reflects the price of one block-form 

rodenticide and one bait station, purchased separately. The prices for the infestation scenarios reflect the cost 

from purchasing enough block rodenticides and separately sold bait stations needed for a minor infestation (six 

block and six traps) and major infestation (12 blocks and 12 traps). This assumption could not be made for 

FGAR/acute multi-packs with reusable bait stations as blocks cannot be sold separately under the proposed 

mitigation. 

 4 Incremental costs are calculated as the cost of each rodent control option less the baseline cost (i.e., the current 

cost of control). 

5 A minor infestation is defined as a residential consumer needing six rodent control placements. 

6 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

7 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 

3.5.4 Socio-Economic Equity Assessment 

In order to better characterize the impacts of cancelling certain rodent control products, BEAD 

places the estimated incremental changes in rodent control costs in the context of household 

income and other expenditures. This analysis focuses on a household at the poverty line. This is 

not the worst-case scenario, as some households may be below the poverty line, but it provides 
37 

an indication of the relative magnitude of impacts. Moreover, one of the main concerns related 

to the proposed mitigation is how it would impact low-income households. This concern is not 

only a function of households having less income with which to purchase rodent control 

products, but also that, according to the U.S. Census Bureau’s American Housing Survey (2009), 

households below the poverty-threshold have a greater likelihood of sighting rodent problems. 

The survey states that nearly nine percent of households below the poverty-threshold reported 

having seen rodent signs within the last three months, while this figure is less than six percent for 

households above the poverty line in the United States. Thus, the impacts of cancelling certain 

rodent control products may be disproportionately felt by low-income households. 

 

In this analysis, EPA considers the impacts of the incremental costs estimated in the previous 

section on an average size, single-family household. In the U.S. from 2005 to 2009, an average 

size family, as reported by the U.S. Census Bureau’s American Community’s Survey, is 3.19 

persons across all income levels (U.S. Census Bureau, 2005-2009).1

 Therefore, BEAD assessed 

the average incremental costs as a percentage of a household income at the poverty-threshold for 

a three-member household, which is $18,530/year in 2011 (U.S. DHS, 2011).2

 

Although most households face many fixed costs, housing is the only fixed cost that is more or 

less constant across all households. According to the U.S. Census Bureau (2009), households at 

or below the poverty line spend 42% of their income on housing (U.S. Census Bureau, 2009), 

leaving $10,650 for other expenses annually, including food. In order to appropriately 

characterize the costs that a household in poverty may be facing when having to suddenly invest 

in enough rodent control problems to treat for a minor or major infestation, monthly—rather than 

annual—disposable income is considered. Monthly income is appropriate in this situation since 

low-income households may have limited savings on which they can draw for unexpected 

expenses and high borrowing costs if those expenses are distributed across future periods. 

Further, available data only indicate recent signs of rodents; it is unclear how frequently an 

infestation may occur. With annual disposable income after housing at $10,650, this implies that 

a household’s monthly disposable income after housing is approximately $900. 

Both mouse and rat control efforts in minor and major infestation scenarios (i.e., 6 or 12 

placements, respectively) were examined. Tables 3-3 and 3-9 present the average incremental 

cost from switching to post-mitigation rodent control measures in comparison to the baseline 

average cost of rodent control options being used by households whose current rodent control 

methods would no longer be available under the proposed mitigation. Although not examined in 

this analysis, the impact from having to pay for rodent control as a percentage of household 

income will be larger for households whose income is less than the poverty threshold. 

3.5.4.1 Mouse Control 

 

1

 BEAD was unable to locate information on the household size specific to income level. 2

 Note that the U.S. Department of Housing and Urban Development uses a different poverty threshold than DHS. 

Specifically, from October, 2008 to September, 2009, HUD’s U.S. poverty threshold was $25,600 (U.S. Census 

Bureau, 2009). EPA chose to DHS’s poverty threshold for two reasons. First, their data are more recent; second, 

EPA preferred to use the more conservative estimate (i.e., erring on the side of higher rather than lower impacts 

from the proposed mitigation) in this analysis. 
38 

Table 3-14 presents the increased cost of rodent control resulting from the proposed 

cancellations provided in Table 3-8 as a percentage of monthly non-housing income. Impacts 

could range from a cost savings of 9.61% of a household’s monthly non-housing income (using 

glue traps rather than multi-pack SGAR blocks in reusable bait stations) to increased costs 

amounting to 8.39% of a household’s monthly non-housing income (using multi-pack 

FGAR/acute rodenticide blocks in reusable bait stations rather than block-form rodenticides) 

when considering all rodent control alternatives that would be available under the proposed 

mitigation. The most likely outcomes are represented by households that would typically use 

block-form rodenticides or loose-form SGARs and would under the proposed mitigation use 

single-use FGAR/acute rodenticide blocks in bait stations. The impacts from switching from 

loose-form and block-form rodenticides to single-use FGAR/acute rodenticide blocks in bait 

stations are estimated to be equivalent to 0.35% to 0.87% of monthly, non-housing income in a 

minor infestation for mouse control, respectively, and 1.09% to 2.12% of monthly, non-housing 

income in a major infestation. 

 In some cases, households currently using loose-form rodenticides and single-use SGARs in bait 

stations could incur a cost savings when switching to certain alternatives post-mitigation (e.g., 

glue traps). However, as noted in Section 3.5.3.1, most rodenticide users will continue to use 

rodenticides post-mitigation, so it is not likely that current users will choose to use a glue trap or 

other non-rodenticide rodent control method. In addition, there may be some perceived benefit 

to the use of SGARs since they advertise control with a single night’s feeding, compared to 

FGARs/acute rodenticides that generally require multiple feedings to deliver a lethal dose, which 

could lead to an increased price for SGARs. This difference in price could also be a function of 

the limited availability of products. Households switching from multi-pack SGARs in reusable 

bait stations to multi-pack FGAR/acute rodenticide blocks in reusable bait stations are not 

expected to be measurably affected. 
39 

Table 3-14. Incremental Cost to a Low-Income Household with $900 Post-Housing Monthly Disposable InControl.1

Alternatives Under theProposed Mitigation

Block‐Form Rodenticides2 SGAR, Loose‐Form3 SGARs in Pre‐Baited, Single‐Use Bait Stations4 SG

R

Minor

Infestation6

Major

Infestation7

Minor

Infestation6

Major

Infestation7

Minor

Infestation6

Major

Infestation7

Inf

FGAR/Acute Rodenticide

Blocks in Pre‐Baited,

Single‐Use Bait Stations4 0.87% 2.12% 0.35% 1.09% ‐0.99% ‐1.59% 

FGAR/Acute Rodenticide

Block Multi‐Pack with

Reusable Bait Stations5 4.19% 8.39% 3.68% 7.35% 2.34% 4.67% Snap Trap, Traditional 8,9 0.84% 1.68% 0.32% 0.64% ‐1.02% ‐2.04% Snap Trap, Covered8,10 1.83% 3.65% 1.31% 2.62% ‐0.03% ‐0.06% Glue trap8 0.29% 0.58% ‐0.23% ‐0.46% ‐1.57% ‐3.14% 

Source: U.S. Census Bureau, 2009; In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A for a complete list 

not add due to averaging. 

1 Post-housing monthly disposable income based on annual income of $18,530 and housing costs of 42 percent of income. Percentag

increase in cost of rodent control (Table 3-8) divided by $900. 

2 Block-form rodenticides include both SGARs and FGARs/acutes and are defined as blocks, bars, pastes/gels, or other solids sold w

3 Loose-form rodenticides only include SGARs and no FGARs/acutes are available in the residential consumer market and are define

crushed pellet, treated whole-grain, meal, and powder. 

4 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited disposable station. 

5 Of the mouse control products sampled in this analysis, multi-pack rodenticide products are only sold with one bait station; therefor

price accounts for a proportion of the cost of the bait station in assuming that a household will reuse the bait station for chronic mou

prices for the infestation scenarios reflect the cost from purchasing enough packages to acquire the needed number of bait station fo

traps) and major infestation (12 traps). 

6 A minor infestation is defined as a residential consumer needing six rodent control placements. 7 A major infestation is defined as a residential consumer needing 12 rodent control placements. 8 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited disposable station. 

9 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

10 Covered snap traps include products that block the rodent carcass from a user’s view. 
40 

3.5.4.1.1 Rat Control 

The impacts of the proposed mitigation on rat control costs are presented in Table 3-15 and range 

from a cost savings of 19.87% (using glue traps rather than multi-pack SGAR blocks in reusable 

bait stations in a major infestation) to a cost increase of 10.94% (using single-use FGAR/acute 

rodenticide blocks in bait stations in a major infestation) of a household’s monthly non-housing 

income at the poverty threshold. Households at the poverty threshold are expected to incur costs 

ranging from approximately 5.47% (minor infestation) to 10.94% (major infestation) of their 

monthly non-housing income when switching from block-form rodenticides to single-use 

FGAR/acute rodenticide blocks in bait stations. For households adopting single-use FGAR/acute 

rodenticides in bait stations who used SGAR loose-form rodenticides in the baseline, incremental 

costs range from 5.21% (minor infestation) to 10.43% (major infestation) of a household’s 

monthly non-housing income. If a household were to switch from multi-pack SGAR with 

reusable bait stations to single-use FGAR/acute rodenticides in bait stations they may expect to 

see a cost savings equivalent to 5.61% to 10.48% of a household’s monthly non-housing income 

in a minor and major infestation, respectively. As mentioned previously, a cost savings from this 

comparison suggests that non-monetary costs exist or that rodent control would ultimately be 

more expensive given that the use of multi-packs suggests a chronic rat problem rather than a 

single infestation. 

 

Table 3-15. Incremental Cost to a Low-Income Household with $900 Post-Housing 

Monthly Disposable Income, Rat Control.1

Alternatives

Under the

Proposed

Mitigation

Block‐Form

Rodenticides2

SGARs,

Loose‐Form3

SGARs in Multi‐Packs

with Reusable Bait

Stations4

Minor

Infestation5

Major

Infestation6

Minor

Infestation5

Major

Infestation6

Minor

Infestation5

Major

Infestation6

FGAR/Acute

Rodenticide

Blocks in Pre‐

Baited, Single‐

Use Bait

Stations7 5.47% 10.94% 5.21% 10.43% ‐5.61%  ‐10.48%

FGAR/Acute

Rodenticide

Block Multi‐

Pack with

Reusable Bait

Stations4

  ‐  ‐ ‐ ‐ ‐  ‐

Snap Trap,

Traditional 8,9 1.71% 3.42% 1.45% 2.90% ‐9.38%  ‐18.00%

Snap Trap,

Covered8,10  ‐  ‐ ‐ ‐ ‐  ‐

Glue trap8 0.78% 1.55% 0.52% 1.04% ‐10.31%  ‐19.87%

Source: U.S. Census Bureau, 2009. In-store visits, on-line searches, and Bell Laboratories (2011). See Appendix A 

for a complete list of sources. Numbers may not add due to averaging. 
41 

1 Post-housing monthly disposable income based on annual income of $18,530 and housing costs of 42 percent of 

income. Percentage impact calculated as the increase in cost of rodent control (Table 3-8) divided by $900. 

2 Block-form rodenticides include both SGARs and FGARs/acutes and are defined as blocks, bars, pastes/gels, or 

other solids sold without stations. 

3 Loose-form rodenticides only include SGARs and no FGARs/acutes are available in the residential consumer 

market and are defined as bait bits, pellets, crushed pellet, treated whole-grain, meal, and powder. 

4 Of the mouse control products sampled in this analysis, SGAR multi-pack rodenticide products are only sold 

with one bait station; therefore, the average placement price accounts for a proportion of the cost of the bait 

station in assuming that a household will reuse the bait station for chronic mouse control issues. The prices for 

the infestation scenarios reflect the cost from purchasing enough packages to acquire the needed number of bait 

station for a minor infestation (six traps) and major infestation (12 traps). This assumption could not be made for 

FGAR/acute multi-packs with reusable bait stations as blocks cannot be sold separately under the proposed 

mitigation. 

5 A minor infestation is defined as a residential consumer needing six rodent control placements. 

6 A major infestation is defined as a residential consumer needing 12 rodent control placements. 

7 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station 

8 The price for a single placement of single-use rodenticides in bait stations represents the price of a baited 

disposable station. 

9 Traditional snap traps include plastic and wooden traps in which the user can still view the rodent carcass. 

10 Covered snap traps include products that block the rodent carcass from a user’s view. 

Overall, BEAD thinks that the impacts on residential consumers from the proposed mitigation 

are relatively low and are dependent on what baseline control method was in use and what 

alternative control measures a household would decide to adopt. In terms of total impacts to 

society, the impact of the proposed mitigation on the control of mice is the primary focus, where 

nearly 90% of rodenticide sales in the homeowner market were for the elimination of house mice 

(Kline, 2006). For most low-income households (i.e., those treating for mice), impacts 

equivalent to one to two percent of monthly non-housing income are expected. Impacts are 

negligible for households that are already using bait stations, whether single-use or multi-pack 

rodenticides. Although effects will be higher on residential consumers controlling for rats, they 

make up a smaller proportion of sales in the homeowner market and therefore impacts are 

expected to be a rare event. As is the case for mouse control, low-income households currently 

using rodenticides with bait stations for rat control are not expected to incur any notable increase 

in costs. 

4 ANTICOAGUALNT RODENTICIDE RESISTANCE

Resistance to warfarin, and other anticoagulants, has occurred in rodent populations worldwide. 

It is thought to have resulted from widespread government rodent control programs in some 

locations, where a single rodenticide was used (Corrigan 1997). This intense selection pressure 

removed susceptible genes (or alleles) in those populations, causing a loss of sensitivity by the 

rodents to the rodenticide used, i.e. resistance. (For more detailed information see Jacobs 2011) 

The Rodenticide Resistance Action Committee (RRAC) and other authors use Greaves’ 

definition for rodenticide resistance. Anticoagulant resistance has been defined as “a major loss 

of efficacy in practical conditions where the anticoagulant has been applied correctly, the loss of 

efficacy being due to the presence of a strain of rodent with a heritable and commensurately 
42 

reduced sensitivity to the anticoagulant” (Greaves,1994 cited in Corrigan 1997; Buckle, et al., 

1994; RRAC). This definition recognizes that resistance is genetic, and excludes control failures 

attributable to poor operating techniques and reinvasion (Corrigan 1997; Buckle, et al., 1994). 

Chiri (2006) reported that previous research demonstrated there were some localized rodent 

populations in the U.S. that were resistant to warfarin. There are some rodent populations that 

are resistant to some SGARs worldwide, including Canada, but none have yet been identified in 

the U.S. Resistance to all anticoagulants is possible since they essentially use the same mode of 

action, but it requires intensive selection pressure to change allele frequency in populations. 

Typically, anticoagulants, such as warfarin, inhibit vitamin K 2,3-epoxide reductase and block 

the production of vitamin K-dependent blood-clotting factors. This results in lethal 

hemorrhaging. Warfarin-resistant rats initially showed that warfarin no longer inhibited the 

vitamin K epoxide reductase (VKOR). Subsequently much research has focused on rat VKOR 

complex (VKORC) mutations (Rost, et al., 2009; Rost, et al., 2004; Wallin, et al., 2001; Pelz, et 

al., 2005; Misenheimer, et al., 1994). Rost, et al. (2009) identified 18 novel and 5 missense 

mutations as well as 8 neutral variants on the VKORC1 gene. It is not clear from these 

publications how these mutations affect practical control strategies. 

House mice have been known to be less susceptible to anticoagulant rodenticides than Norway 

and roof rats (Witmer and Jojola 2006). Misenheimer, et al. (1994) demonstrated that the house 

mouse had VKORC mechanisms analogous to Norway rats. However, it appears that other 

resistance mechanisms exist. A resistant Danish strain of house mouse did not show VKORC 

enzyme alterations, and may have metabolized the anticoagulant with cytochrome P450 

(Misenheimer, et al. 1994). In Denmark, Heiberg (2009) found that resistant sewer rats did not 

have resistance-related mutations in the VKORC1 gene. Hence resistance alleles at VKORC1 

alone do not totally explain anticoagulant resistance. 

Genetic differences do not account for all the failures of rodenticides attributable. Behavioral 

resistance has been offered as another explanation. Clapperton (2006) reported that the house 

mouse has been demonstrated to have an inheritable behavioral cereal aversion; exacerbated by 

ample alternative foods. Rats are known to be neophobic and may avoid anything new in their 

environment, thus avoiding rodenticide baits (Marsh 1994; Corrigan 2001; Timm 1994b; 

Clapperton, 2006). 

After the proposed cancellations, residential consumers would continue to have access to FGAR 

and acute rodenticide products. To manage and prevent resistance issues, RRAC recommends 

alternating active ingredients, but it is unlikely that residential consumers choose their products 

based on active ingredients. One common rodenticide, bromethalin, used in several products that 

conform to the NOIC, is an acute rodenticide with no reports of resistance. There are no data to 

indicate how many residential consumers are likely to be using the same rodenticide active 

ingredient in an area. Therefore it is unknown how much selection pressure consumers could 

place on a rodent population that would result in an alteration of their allele frequencies (i.e., 

cause the rodents to develop resistance). However, BEAD thinks it is highly unlikely that 

residential consumers using rodenticide products that comply with the RMD could put enough 
43 

selection pressure on a rodent population to change its gene frequency and thereby cause 

resistance. 

5 CONCLUSIONS

In summary, BEAD expects that consumers who currently rely on rodenticides will most likely 

continue to use rodenticides (i.e., FGAR/acute rodenticide blocks in bait stations) under the 

proposed NOIC as their preferred method of rodent control. There is no evidence to conclude 

that this change will result in the loss of a consumer’s ability to control commensal rodents. 

Although the performance of different types of rodenticides vary between mice and rats, 

evidence suggests that options will still be available under the proposed NOIC that perform 

similarly to second generation anticoagulants. Furthermore, rodents’ bait preference is based on 

other factors, such as palatability, rather than active ingredient. Evidence suggests that bait 

stations have similar product performance to rodenticides placed without bait stations. No 

differences in rodent consumption were found between block and loose formulations. The 

rodenticides have unique chemistries, different affinities for binding sites and therefore, different 

lethal doses, but if lethal doses are obtained, they result in the death of the rodent. All the 

registered rodenticide products have met the Agency’s efficacy standards. So while the 

rodenticides are not all equal, they will kill rodents. It is likely that consumers switching to 

products that would be available under the proposed mitigation will choose products most like 

the ones they are currently using. 

Overall, BEAD expects that incremental costs will be small from having to switch from 

rodenticide products currently available to those that would be available post-mitigation. 

Residential consumers treating for mouse infestations are expected to switch from rodenticides 

that would no longer be available to similar rodenticide products that would be available postmitigation. Incremental costs from this change range from $2 to $12 for mouse control. 

However, loose-form rodenticides account for a majority of rodenticide sales and thus residential 

consumers using such products make up the largest proportion of those that will be impacted by 

the mitigation measures. Therefore, most residential consumers are expected to see an average 

increase in cost of $1.50 in a minor infestation and $3 in a major infestation, or $0.25 per 

placement. With 90% of rodenticides sales being for products that are intended to control mice, 

BEAD concludes that a majority of residential consumers currently using rodenticides will be 

facing the impacts described above. 

For residential consumers treating for rat infestations, incremental costs range from a cost 

savings to $97 per infestation across all rodenticide alternatives that would be available postmitigation; note that a cost savings may entail that non-monetary costs exist that have not been 

accounted for in this analysis. 

For mouse control, it is expected that most residential consumers are currently using loose-form 

rodenticides and will incur incremental costs ranging from $46 in a minor infestation to $92 in a 

major infestation, or $8 per placement. Only a small proportion of residential consumers are 
44 

expected to incur these costs, however, as rat control products make up 10% of rodenticide sales 

and only a portion of these sales are for loose-form rodenticides. 

Both in the case of mouse and rat control, there are lower cost alternative control methods that 

would be available post-mitigation that could result in a cost savings. As mentioned, issues such 

as ease of use and disposal of the rodent carcass would entail non-monetary costs to residential 

consumers. Therefore, EPA thinks that most consumers would likely incur at least some 

incremental costs from complying with the proposed NOIC. 

The impact on households at the poverty level from switching from control options that would 

no longer be available under the NOIC to similar products that would be available postmitigation was also examined. For mouse control, the average incremental costs for consumers 

switching from non-RMD conforming rodenticide products to rodenticides that they would most 

likely adopt in post-mitigation ranges from a cost savings to 0.87% of monthly non-housing 

income at the poverty threshold for a minor infestation and up to 2.12% for a major infestation. 

For rat control, consumers at the poverty threshold who would no longer be able to use nonRMD conforming rodenticides would likely incur incremental costs equal to as much as 5.47% 

of their monthly non-housing income in a minor infestation and 10.94% of their monthly nonhousing income in a major infestation. 
45 

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50 

7 APPENDICES 

7.1 Appendix A. Product Pricing Data 

Attached as separate document in docket. See: 

Cook, C. and E.S. Hill. 2011. Appendix A to Impact Assessment of the Draft Notice of Intent to 

Cancel Selected Residential Consumer Rodenticide Products to Control Commensal Rodents. 

Environmental Protection Agency Office of Pesticide Programs, Biological and Economic 

Analysis Division. 
51 

7.2 Appendix B. American Housing Survey Data 

The American Housing Survey (AHS) is conducted every other year by the U.S. Census Bureau 

to obtain housing statistics for the Department of Housing and Urban Development. The 2009 

survey includes questions about the presence of rodents in the dwelling during the last three 

months and is based on a sample of over 60,000 housing units (U.S. Census Bureau, 2009). 

Table D-1 presents information that supports observations made in Section 3.3.5 of this 

document about what types of dwellings tend to report having seen rodents in the last three 

months. In addition to these previous remarks, the survey also indicates signs of mice are more 

typical than for rats across all groups surveyed. Furthermore, renters saw more signs of rodents 

that owners, but out of all total occupied units, rents make up a small proportion of all rodent 

sightings than owner occupied dwellings. 

Table D-1. Characteristics of Occupied U.S. Housing Units by Dwelling Type. 

Characteristics 

Total 

occupied 

units 

(thousands)

Tenure 

Below 

poverty level 

(thousands) 

Owner 

(thousands)

Renter 

(thousands)

Total 111,806 76,428 35,378 15,739

Signs of rats in last 3 months 613 354 258 148

Signs of mice in last 3 months 6,122 3,984 2,138 1,134

Signs of rodents, not sure 

which kind in last 3 months 353 164 189 98

Signs of any type of rodent in 

last 3 months 7,087 4,503 2,585 1,381

Percentage of dwellings for 

each grouping (i.e. column 

headings) that have seen signs 

of any type of rodent in the 

last 3 months 

6.34% 5.89% 7.31% 8.77%

Percentage of each grouping 

in comparison to total 

occupied units that have seen 

any type of rodent in the last 3 

months 

6.34% 4.03% 2.31% 1.23%

Source: American Housing Survey for the United States (2009).