### 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 Protecti on 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 redu ce wildlife exposures and ecological risks, the Agency will require sale and distribution limits intended to prevent general consumers from purchasing residential use bait pr oducts containing four of the ten rodenticides that pose the greatest risk to wildlife (the second genera tion anticoagulants – brodi facoum, bromadiolone, difenacoum, and difethialone)” (EPA 2008). Regi strants 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 re sidential consumers who are currently using roden ticides 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-comp liant products will not result in the loss of

residential consumers’ abilities to co ntrol commensal rodents.

Overall, BEAD expects that incremental costs will be minimal from having to switch from rodenticide products currently available to t hose that would be available post-mitigation. Residential consumers treating for mouse infestations are expected to switch from rodenticides that would no longer be availabl e to similar rodentic ide products that wo uld be available postmitigation. Incremental costs from this change range from $2 to $12 for mouse control.
However, loose-form rodenticides account for a ma jority of rodenticide sales and thus residential consumers using such products make up the larges t proportion of those that will be impacted by the mitigation measures. Therefore, most reside ntial consumers are expected to see an average increase in cost of $1.50 in a minor infestati on and $3 in a major infe station. With 90% of rodenticides sales being for pr oducts 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 infesta tions, incremental costs estimates range from a potential cost savings to $97 per infestation across all rodenticid e alternatives that would be available post-mitigation. As in the case of mous e control, it is expected that most residential consumers are currently using loose-form rodent icides 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 infestatio n 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 on ly a portion of these sales are for loose-form

rodenticides.

BEAD conducted a socio-economic assessment to e xplore 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 m onthly non-housing income when trea ting for mouse infestation and approximately 10% when treating fo r 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, a nd 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 pr oducts 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 a ll products that have not complied with the RMD and are therefore subjec t to the NOIC include:

 First-generation anticoagulant (f ive products, loose formulations)

o warfarin (PC code 086002)

 Second-generation anticoagulant (1 1 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 pr oducts that are subject to the NOIC include:

 All second generation anticoagu lant rodenticides (SGAR).

 Rodenticides that are not in block form or in a form that is reasonably expected to remain in the bait station (inclu ding 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 roden ticides (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 Roden ticide 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 impact s for the proposed RMD (C hiri et al., 2006). In 2008 BEAD responded to public comments concerni ng the proposed RMD for nine rodenticides (Chiri et al., 2008). An addendum to the im pact assessment for the proposed rodenticide mitigation was published later that year that determined the amended proposed mitigation of requiring bait stations would not impose constr aints 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 form ulations of rodenticides for their commensal rodent control will be affected by the NOIC. This assessment considers homeowners, property owners, renters, household consumers, househol ds, 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 consumer s need not be considered further.

The NOIC targets only residentia l consumer rodenticide produc ts 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 consid erations, 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 assessm ents 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 assessme nts 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 hom e. Therefore, BEAD considered scenarios in which a household is facing a minor or major rodent infest ation. 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., 20 10; 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 rodenticid es post-NOIC as their preferred rodent control method. Therefore, the focus of this analys is is on the impact on residential consumers switching from non-RMD compliant rodenticid es to accepted rodenticide forms.



### 3.2 The Pests: Commensal Rodents

The Old World rodents that ty pically live in close associa tion with humans and depend upon humans for at least part of th eir food and shelter are referred to as commensal rodents (Timm 1994; Franz and Davis 1991). The term commens al literally means “t o share the table” (Merriam-Webster 2011; Corrigan 1997). Ecol ogically the term “c ommensal” 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 rodent s, probably originating in Cent ral 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 residentia l consumers. While commensal rodents can survive in many different habitats from open fiel ds to sewers, and in and around farm buildings and land, the Agency’s concerns are with resi dential consumer products. Therefore this assessment and the following informati on pertain only to residential areas.

### 7 3.2.1 House Mouse

The house mouse is a small, slender rodent. Ad ults weigh 12 to 25 grams, with head and body about 6-11 cm in length and a hairless tail e qual to the length of the body (Frantz and Davis 1991). Their coloring is grayish brown to gray ish 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, an d may range 3 to 9 meters from their nest in search of food, but the size of their territories depends on resour ces. 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 c onsidered to be “nibblers” as they take tiny bites of food many times during the night (Tim m 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 thei r environment within their home range. They typically do not fear new objects, like traps (Timm 1994a; Corr igan 2001). Corrigan (2001) does point out different populations of house mice and their specif ic environments lead to variations in their behavior; therefore, their behavior has b een referred to as unpredictable.

3.2.2 

### Norway Rat



### The Norway rat is a large, robust rodent. Th e 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 th eir nests. Often times, holes to their burrows can be seen near structures. The gestation peri od 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 daytim e foraging is not uncommon. In the field they can have an average range of 30 to 45 m di ameter 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 te nd to be steady eaters (Frantz and Davis 1991).

### 8 Similar to house mice, Norway rats also consta ntly 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 objec ts (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 weighi ng from 80 to 350 grams. Their bodies are 16 to 23 cm in length with tails longer th an the body. They also occur in a range of color from blackishgray to tawny brown with white to brownish-gre y bellies. (Frantz and Davis 1991) Roof rats favor more tropical and semi-tropical climates (M arsh 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; Corriga n 2001). In buildings where they occur with Norway rats, the Norway rats occupy the basement and lower levels and th e roof rats occupy the upper stories and attic (Marsh 1994).

Roof rats tend to prefer to ne st off the ground. They have a gestation period of 21 to 23 days; producing about 5 to 8 pups per litter. Roof ra t pups are reproductively mature by 3 months. In tropical regions these rodents can breed year-round, otherwise thei r main breeding season is in the spring and fall. A female will typically ha ve 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 mous e will produce 40 to 100 fecal pellets per day (Corrigan 1997) these droppings will tend to accum ulate 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 ar eas of activity and size of the population. There are several websites to help residential consumer s identify which rodent they have based on the differences in the droppings (Pierce 1993; Koehle r and Kern, 2008; Hovanic et al., 2010; Illinois Department of Public Health undated).

Residential consumers may also look for runway s, 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 noise s, such as squeaking, gnawing, and scratching, at night that indicate an infestation.

### 9 The signs that residential consumers use to identi fy 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 reside ntial consumers have several control options including chemical and mechanical methods. D ecisions of the residential consumer are based upon a number of preferences and situations. For instance residentia l consumers with young children and pets may prefer mechanical traps because of concerns re garding exposures of rodenticides to their family, even though trap s can injure fingers and pets. Residential consumers who are squeamish may pr efer rodenticides because they will not have to deal with dead or injured rodents. Other considerations may include their toleranc e of decomposing odors, previous experience with rodent control, and opinions regardi ng pesticides in general.

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

rodent control method. These sources include se arches for top products on major online retail store websites, professional expe rtise, 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 cons umers might choose to control rodents. These include products EPA proposes to cancel as well as alternatives availa ble 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 activ e ingredient an important com ponent, but the formulation and palatability of the bait are also critical.

3.3.1.1 

### Active Ingredients

Many of the rodenticides are anticoagulants, wh ich interfere with the animal’s blood clotting abilities, resulting in it hemorrhaging to d eath. The FGAR products include: warfarin, diphacinone, and chlorophacinone. Baits using th ese 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 register ed residential consum er 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 r odenticides are often co nsidered to be more efficient than the FGARs since rodents may obtai n a lethal dose in a single night’s feeding (Corrigan 1997; Koehler and Kern 2008). Howe ver, 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, rode nts 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) rode nticide available for residential consumers in the U.S. It is also the only “stop-feeding” ro denticide on the market. It is effective in small quantities, results in paralysis, and death usually occurs in ab out three days (Corrigan 1997). Acute rodenticides are effective against rodents resistant to anticoagulant rodenticides, and no

resistance issues have been identified with th em. 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 (K line 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 th e rodenticide market. The active ingredient most widely used, by pounds, was brodifacoum, followed by diph acinone and chlorophacinone, which in 2005 made up 30%, 3%, and 2% of the market, respectiv ely. Nearly 90% of ro denticide sales in the

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

3.3.1.2 

### Palatability

Rodents are very selective in their food choi ces and will not consume the straight active ingredient. Therefore, rodenticides must be co mbined with various ingredients that will make them palatable. In fact, the bait must not only disguise the active ingred ient, but also be more desirable than any other food sour ces available to the rodent. Th is 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 spec ies of rodent, but its lo cation and the other food

sources within its envi ronment. Individual ra ts and mice and even di fferent populations have their own preferences for f oodstuffs (Meehan 1984 and Rowe 1973 in Clapperton 2006).

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

flavor to be attractive to th e different rodents (Clapperton 2006) as well as masking the rodenticide. Residential consumer products are bl ends of various ingredients. These blends are

### 11 formulated to attract the commens al 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. Th e residential consumer produc ts 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 usua lly 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 rodent s even cache the whole placepacks, but they do not necessarily take them to their nests to stas h, therefore rodenticide pe llets 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 bl ocks can be formulated with many different ingredients to ensure that they are palatable to th e 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 anchor ed into bait stations a nd therefore, are unlikely to be moved or cached by rodents. However, rats will move and cache unsecured bait blocks.

Since users must maintain contro l over rodenticide ba its to prevent exposur e 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 lik ely to provide the security needed to prevent accidental exposures.

Comparative product performance studies of diff erent formulations are variable. Clapperton (2006) reviewed several studies de monstrating that sometimes bloc k baits were preferred, but in other studies pellets or cereals were preferred. Kaukeinin (200 9) reports blocks are highly palatable to rodents, plus offer advantages such as durability to withstand weather conditions. Therefore, residential consumers s hould still be able to control r odents with bait blocks in bait stations, as well as they did with pell ets, and other loose formulations.

3.3.1.4 

### Bait Stations

To comply with the RMD rodentic ide bait must be sold with a RM D-compliant bait station. Bait stations are recommended to help to prevent acci dental exposures of baits or traps to children, pets, and non-target wildlife (Vantassel, et al. 2006; Corri gan 1997). Non-RMD compliant rodenticides did not require bait stations. Resi dential consumers could eas ily 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 locati on and consumption of the roden ticide. It also allowed for rodents to easily move the r odenticides to new places.

Bait stations may provide several advantages. They protect the bait from dust and moisture thereby keeping the bait palatable longer. Bait st ations 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 prop er placement of the ba it station as well as palatability of the bait. Many comme rcial stations have ways to an chor them so that they cannot be carried away by non-target animals.

Bait stations must be placed a ppropriately in the rodent’s hom e 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). Multip le bait stations are needed to increase the probability of a mouse to encounter it on any given night. The sa me holds true for rats; although because of their neophobia, it is recommended for stations to be pl aced 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 met hod of control, especially for mice and when popula tions are relatively small. Me chanical 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 su ccess, and there is no odor from decomposing rodents if disposed of daily. Some disadvantages include the time a nd 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 veri fy the success of their control method, so what some residential consumers may consider an adva ntage others may consider a disadvantage.

Generally snap traps are not expe nsive but their success is determ ined 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 rodent s 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 rese t (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 residentia l consumers use more traps than they think they need (Hovanic et al. 2010; Corrigan 1997).

Like rodenticide baits, baits used for snap trap s need to be attractive to the rodents being targeted. CDC (2010) recommends baiting snap traps with peanut butte r, but other sources recommend trying chocolate, gum dr ops, nuts, oats, dried fruit or small pieces of bacon (Illinois Department of Public Health, undated; Hovanic et al. 2010). Even using de ntal floss will attract pregnant female rodents looking for nest buildin g materials (Corrigan 1997). Therefore, there may be some added time involve d in finding the appropriate ba it for the rodent population of

concern. Baits need to be maintained with fr esh material, so checking it frequently will take more time than using rodentic ide baits (Corrigan 1997).

Some snap traps can be reused. The wooden sn ap 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 finge rs. These plastic jaw traps are intended to reduce risks to pets and fingers and still be sensitiv e to trap rodents. These jaw traps also allow residential consumers to easily release the captured rodent fr om the trap, without touching it, for disposal. In addition, there is eviden ce that previously successful snap traps are actually more attractive to rodents than new traps (Corrigan 1997).

The market now has single-use snap traps wher e 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 leve r is moved to indicate a rodent has been caught.

The residential consumer then throws the entire un it 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 fi ngers and pets by encasing the entire trapping

mechanism.

Since rodent home ranges may be relatively sma ll, 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 ensu ring 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 trappe rs bait but do not set their traps until there is evidence that feeding has begun. Th is 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 a nd 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 lik e the ease of glue boards, sin ce there are no tri ggers or baits to set. Glue boards are simply placed in the sa me general location as sn ap traps and rodenticide bait stations would be. Glue boards are typi cally placed along walls where the rodents are traveling, and since rodents can jump, some agen cies recommend placing two glue boards end to end (Illinois Department of Public Health, undated). Glue traps ma y be useful to kill snap trap wary mice and are sometimes used in conjunction w ith 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 fu r to escape (Corrigan 1997). Rodents have been observed using paper, dirt, or leaves to esse ntially create bridges over the stic ky surfaces (Corrigan 1997). CDC (2010) does not recommend glue boards because often the stuck rodents are not dead, thereby increasing the potentia l 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 ba it used is the same as for snap traps, so a variety of foodstuffs

will need to be tried to find an attractive bait fo r 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 tr aps because of increased exposure to rodents that may harbor diseases. Live traps require that residential co nsumers 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 pote ntial for disease transmissions, some state agencies are beginning to regulate th e relocation of live trapped animals (Witmer and Jojola 2006). In addition, the number of live tr aps needed to control a rodent infestation is

uncertain.

3.3.2.4 

### Other Devices

There are other devices for the residential cons umer 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 te nd to quickly acclimate to their surroundings, consequently there is little evidence that these de vices work as a long-term deterrent. There are

some electronic devices that electrocute rodents wh en 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, th e registered rodenticid e 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 leth al dose with one night’s feeding on the SGARs.

However rodents take 4 to 7 da ys 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 ha ve 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 rodent s 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 wh en they use rodenticides. Some residential consumers may prefer not to have to see or hand le rodent carcasses, and with rodenticides they probably will not have to handl e as many carcasses as they would with mechanical control

methods.

Snap traps have their advantages and disadvant ages as previously described (Section 3.3.2.1). Traps must be checked, rebaited, and reset frequen tly; therefore, they are more labor intensive than rodenticides. However, rodents caught in tr aps can be disposed of quickly, there is no odor from decomposing rodents, and residential consumers can monitor their succe ss 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 a nd major infestations of rodents. There is too much uncertainty regarding their performance in controlling rodents. Th erefore, 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 runw ay, and about 6 to 10 feet apart. It is often difficult to determine just how many rode nts have invaded a home, but the amount of droppings helps to inform whether it is a minor in festation or a major infestation. During control operations, residential consumers will need to con tinually monitor their homes for rodent signs. They are likely to continue their control unt il signs of rodents are no longer detected.

### 16 

### 3.4 NOIC Effects on Residential Consum ers’ 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 ma jor cornerstones of

rodent IPM are exclusion and sanitation. Wit hout sanitation and exclusion, no trapping or rodenticide baiting program will be effective (C hiri 2006). Reducing alternative food sources will minimize the competition with baits, whether th e 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 infe sting a home, they are critical to prevent

reinfestations and increase the success of traps or baits.

Several extension publications and websites recommend snap tr aps 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 wh ere rodenticide use is too hazardous, or where the odor of dead rodents in inaccessible pla ces would not be acceptable (Witmer and Jojola 2006; Chiri 2006; Pierce, 1993). Ho wever, 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 se tting of snap traps.

Residential consumers who used non-RMD compliant rodenticide baits will still have access to several RMD compliant rodenticides. Residen tial 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 th at 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 decompos ing odors, previous e xperiences, and personal opinions regarding poisons. Therefore, whatever reasons residential consumers used to choose rodenticides in the past will likely hold fo r 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 w ould 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 ope rate differently, they all kill rodents if placed properly. Theref ore, for the purpose of this comparison, while recognizing that these methods are not equal, rode nticides and snap traps are cons idered to be equivalent.

### 17 

### 3.5 Cost Impacts

This section presents estimates of the costs in curred 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, wh ile 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 consumer s will opt to continue using rodenticides postmitigation if rodenticides are their preferred rode nt 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 po st-mitigation to rodenticide forms that would be accepted under the proposed mitigation. This anal ysis also is based conclusions presented in

Section 3.4 which state that in a minor infesta tion, 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 diff erent benefits from distinct types of rodent control products (see Sec tion 3.3). For example, some residential consumers may prefer to use covered snap traps over traditional snap traps as th ey do not have to see the dead carcass. In addition, consumers may be facing ongoing infestat ions 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 analys is examines impacts based on the type of rodent control product rather th an across all products. Baseline pr oduct groupings in clude: (1) blockform rodenticides, (2) loose-form SGARs, (3) single-use SGARs in pre-baited, disposable bait stations, and (4) multi-pack SGARs in reusable ba it stations. Alternative product groupings that would be available post-mitigation are (1) singl e-use FGAR/acute rodenticide blocks in prebaited, disposable bait stations, (2) multi-pack FG AR/acute rodenticide bl ocks 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 incr emental 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 avai lable under the proposed mitigation (see Section 3.3.2.5). This analysis al so does not consider the impact on residential consumers from having to discontinue using rodentic ides in packages that weigh greater than one pound; however, they are included in the aver ages for their respective product type.

### 18 3.5.2 Data

Rodent control product prices we re obtained from online website searches and store visits in northern Virginia and Pennsylvania. National ch ains known for carrying r odent control products were targeted for sampling. Prices were also provided by Bell Laboratori es, 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 regi on 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. Fu rthermore, since this analysis focuses on the differences in prices between products, any re gional bias in product prices that affects

rodenticides as a class would cance l out. Prices for all rodent cont rol 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 packag e, 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 electr onic and live traps. BEAD assumes for purposes of this analysis that each placement kills one rode nt. Packages for rodent control products often contain more than one placement which is reflecte d in the price per package. The price for a single placement of single-use r odenticides in bait stations re presents the price of a baited disposable station. Multi-pack rodenticide products for mice are of ten sold with one bait station; therefore, the average placement pr ice 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 fi ve baits). In some cases multiple single-use rodenticide placements are sold in a single pack age. 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 pr oducts 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

Placement 1 Range of Prices across
Products for a Single

Rodent Control

Placement

Baseline: Products Proposed to be Cancelled

Block

‐ Form Rodenticides 2 25 $10.87 $0.74 $0.31

‐ $2.20

SGARs, Loose Form 3 24 $4.73 $1.51 $0.08

‐ $2.55

SGARs in Pre

‐ Baited, Single

‐ Use

Bait Stations 4 2 $4.48 $3.49 $1.99

‐ $4.99

SGARs in Multi

‐ Packs with

Reusable Bait Stations 5 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

Placement 1 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

Stations 4 9 $4.92 $1.75 $1.37

‐ $2.74
FGAR/Acute Rodenticide Block

Multi

‐ Pack with Reusable Bait

Stations 5 10 $6.94 $0.98 $0.50

‐ $1.99

Snap Trap, Traditional 6 22 $3.80 $1.98 $0.37

‐ $5.99

Snap Trap, Covered 7 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 pl acement 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 rodentic ides in bait stations represents the price of a baited disposable station. In some cases multiple single-us e rodenticide placements are so ld in a single package. Therefore, differences exist between the pr ice of a single-use package and placement. 5 Of the mouse control products sampled in this analys is, multi-pack rodenticide produ cts are only sold with one bait station; therefore, the average placement price accounts for a proportion of the cost of th e 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 trap s 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 info rmation 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-pack s with reusable bait stations reflects the price

of one block-form rodenticide and one bait sta tion, 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 pu rchase these blocks to use within a separately purchased bait station (the average price of a ba it 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 bloc k, see Appendix A) in a separately purchased bait station, the average price fo r 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, give n 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 expect s that most consumers use bait stations in conjunction with block-form rodenticides over lo ose-form rodenticides. This assumption could not be made for FGAR/acute multi-packs with reus able 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

Placement 1 Range of Prices across
Products for a Single

Rodent Control

Placement

Baseline: Products Proposed to be Cancelled

Block

‐ Form Rodenticides 2 21 $11.03 $0.74 $0.31

‐ $2.20

SGAR, Loose Form 3 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 Stations 4 21 $27.43 $17.14 $16.71

‐ $18.59

Alternatives Under Proposed Mitigation

FGAR/Acute Rodenticide Blocks in

Pre

‐ Baited, Single

‐ Use Bait

Stations 5 5 $8.83 $8.83 $7.29

‐ $9.47

FGAR/Acute Rodenticide Block

Multi

‐ Pack with Reusable Bait

Stations 4 0

‐ ‐ ‐ Snap Trap, Traditional 6 10 $3.69 $3.27 $1.96

‐ $4.99

Snap Trap, Covered 7 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 pl acement 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 rodentic ides in bait stations represents the price of a baited disposable station. The packages are often sold w ith multiple single use sta tions, which accounts for the different in cost between the p ackage and single placement price. 5 The average placement price of a SG AR multi-pack rode nticide for rats reflects th e price of one block-form rodenticide and one bait station, purchased separately. The av erage 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 trap s 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 si ze=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 t ypes of products. Low sample size is thus likely to be a reflection of low use. Samp les for each rodent control product grouping are presented in Tables 3.1 and 3.2.

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

FGAR/acute rodenticides versus SGARs. Differen ces in price appear to be a function of other aspects, such as the type of product, packaging a nd brand. Prices may also vary for rodenticides sold with bait stations as the level of protecti on offered by a bait station in terms of weather and tamper resistance varies. EPA has grouped bait sta tions into four tiers th at represent different levels of protection, with Tier 1 offering the mo st protection and Tier IV offering the least (see http://www.epa.gov/pesticides/mice-and-rats/con sumer-prod.html for more details). For the purposes of this analysis, BEAD does not diffe rentiate bait stations by their tiers but acknowledges that bait stat ion prices may vary dependi ng on the product’s tier.

3.5.3 Analysis and Results

The average costs to control rode nt infestations usi ng 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 afte r 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 majo r mouse and rat infestations. The analysis uses average price for each type of rodent cont rol and thus represents the average change in expenditures on rodent control. As there is c onsiderable 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 a nd major infestations. The average price of a single rodenticide placement fo r mouse control (from Table 3-1) is also presented.

As noted in Section 3.4, for all mouse control met hods, 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 fo r multi-pack baits with a reusable bait station reflects the price of purchasing six packages of rodenticides in orde r 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 sta tions. 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 c ontained 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

Placement 1 Average Expenditure

for Mouse Control in

a Minor Infestation 2 Average Expenditure

for Mouse Control in

a Major Infestation 3

Baseline: Products Proposed to be Cancelled

Block

‐ Form

Rodenticides 4 $0.74 $4.45 $8.90

SGARs, Loose Form 5 $1.51 $9.04 $18.07

SGARs in Pre

‐ Baited,
Single

‐ Use Bait Stations 6 $3.49 $20.93 $41.85

SGARs in Multi

‐ Packs

with Reusable Bait

Stations 7 $8.28 $49.67 $99.34

Alternatives Under Proposed Mitigation
FGAR/Acute Rodenticide

Blocks in Pre

‐ Baited,
Single

‐ Use Bait Stations 6 $1.75 $10.53 $21.06

FGAR/Acute Rodenticide

Block Multi

‐ Pack with

Reusable Bait Stations 7 $6.94 $41.66 $83.33

Snap Trap, Traditional 8 $1.98 $11.89 $23.77

Snap Trap, Covered 9 $3.44 $20.65 $41.30

Glue trap $1.17 $7.00 $14.01

Source: In-store visits, on-line searches, and Bell Labo ratories (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 rodentic ides in bait stations represents the price of a baited disposable station. 5 Multi-pack rodenticide products ar e 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 re sidential consumer will reuse the bait station for chronic mouse control issues. The prices for the infestation scenarios refl ect 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 expe nditure per rodenticide placement for multi-pack rodenticides with bait stations reflects the average pr ice per package rather than the price per placement. 6 Traditional snap traps include plastic and wooden trap s 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, mu lti-pack SGARs in bait stations are the most expensive baseline rodent control option, followe d by single-use SGARs in bait stations. Blockform rodenticides are the mo st affordable option across a ll rodenticide co ntrol methods considered in this analysis. Of the mouse contro l alternatives that woul d be available under the proposed mitigation, multi-pack FGAR/acute rodentic ide blocks in bait stations are the most expensive option while glue traps are the least expensive. Overall, pr ices for residential consumer products to control mice in the ba seline 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 alternat ives 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 ava ilable 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 mitigati on. 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 (m ulti-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 re sult in average incremental costs of $6.08 in a minor infestation (Table 3.4).

In a major infestation, the average cost for bloc k-form rodenticides is $8.90. The incremental cost of switching to the available alternat ives 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 we re 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 smalle r 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 Re sidential Consumers Switching from BlockForm Rodenticides to Alternatives Accepte d Under the Proposed Cancellations, Mouse

Control

Minor Infestation 1 Major Infestation 2

Cost per
Infestation ($) Incremental

Cost 3 Cost per
Infestation ($) Incremental

Cost 3

Baseline: Block

‐ Form Rodenticides 4 $4.45

‐ $8.90

‐

Alternatives

Under the
Proposed
Mitigation FGAR/Acute Rodenticide

Blocks in Pre

‐ Baited,
Single

‐ Use Bait Stations 5 $10.53 $6.08 $21.06 $12.16
FGAR/Acute Rodenticide

Block Multi

‐ Pack with

Reusable Bait Stations 6 $41.66 $37.21 $83.33 $74.43

Snap Trap, Traditional 7,8 $11.89 $7.43 $23.77 $14.87

Snap Trap, Covered 7,9 $20.65 $16.20 $41.30 $32.40

Glue trap 7 $7.00 $2.55 $14.01 $5.11

Source: In-store visits, on-line searches, and Bell Labo ratories (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 rode nt 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 rodentic ides 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 th e 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 co st from purchasing enough packages to acquire the needed number of bait station for a minor infestation (six traps) and major infest ation (12 traps). For this reason, the average expenditure per rodenticide placement for multi-pack rodenticides with bait stations re flects the average price per package rather than the price per placement. 7 Single placements reflect a single unit of control—i.e., one tr ap 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 trap s 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 mitigati on. 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 suggest s, based on the availabl e 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 bloc ks 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 trap s would be a slightly more costly option and entail additional effort in baiting and checking tr aps 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 Resident ial Consumers Switching from LooseForm SGARs to Alternatives Accepted Under the Proposed Cancellations, Mouse Control

Minor Infestation 1 Major Infestation 2

Cost per
Infestation ($) Incremental

Cost 3 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 Stations 5 $10.53 $1.49 $21.06 $2.98
FGAR/Acute Rodenticide

Block Multi

‐ Pack with

Reusable Bait Stations 6 $41.66 $32.63 $83.33 $65.26

Snap Trap, Traditional 7,8 $11.89 $2.85 $23.77 $5.70

Snap Trap, Covered 7,9 $20.65 $11.61 $41.30 $23.23

Glue trap 7 $7.00

‐ $2.03 $14.01

‐ $4.07

Source: In-store visits, on-line searches, and Bell Labo ratories (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 rode nt 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 rodentic ides 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 th e 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 co st 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 un it of control—i.e., one trap or roden ticide 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 asso ciated with switching from single-use SGAR

rodenticides in bait stations to alternative rodent control met hods that would be available under the proposed mitigation. In a minor infestation, th e average cost of a single-use SGAR in a bait station is $20.93. The cost from sw itching to available alternatives ranges from a cost savings of $13.92 (glue traps) to a cost increase of $20.74 (mu ti-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 roden ticide blocks in bait st ations—in the absence of single-use SGARs in bait stations and could se e 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 st ations to single-use FGAR/acute rodenticides in bait stations. However, cost savings from an action that reduces c onsumer choice is unlikely as there are non-monetary costs th at consumers may incur. In this case, there may be some perceived benefit to the use of SGARs since they advertise contro l 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 dos e in one feeding, but several days may pass before death occurs during which time the homeow ner will continue to see signs and will need to maintain bait placements. The estimated cost sa ving could also be a function of the small sample sizes and variability in observed prices rather th an 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 Accepte d Under the Proposed Cancellations, Mouse Control

Minor Infestation 1 Major Infestation 2

Cost per
Infestation ($) Incremental

Cost 3 Cost per
Infestation ($) Incremental

Cost

Baseline: SGARs in Pre

‐ Baited, Single

‐ Use Bait Stations 5 $20.93

‐ $41.85
‐

Alternatives

Under the
Proposed
Mitigation FGAR/Acute

Rodenticide Blocks in

Pre

‐ Baited, Single

‐ Use Bait Stations 4 $10.53

‐ $10.40 $21.06

‐ $20.79
FGAR/Acute

Rodenticide Block

Multi

‐ Pack with

Reusable Bait

Stations 5 $41.66 $20.74 $83.33 $41.48

Snap Trap,

Traditional 6,7 $11.89

‐ $9.04 $23.77

‐ $18.08

Snap Trap,

Covered 6,8 $20.65

‐ $0.28 $41.30

‐ $0.55

### 27 Minor Infestation 1 Major Infestation 2

Cost per
Infestation ($) Incremental

Cost 3 Cost per
Infestation ($) Incremental

Cost

Baseline: SGARs in Pre

‐ Baited, Single

‐ Use Bait Stations 5 $20.93

‐ $41.85
‐

Glue trap 6 $7.00

‐ $13.92 $14.01

‐ $27.84

Source: In-store visits, on-line searches, and Bell Labo ratories (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 rode nt control option less the baseline cost (i.e., the current cost of control). 4 The price for a single placement of single-use rodentic ides in bait stations represents the price of a baited disposable station. 5 Of the mouse control products sampled in this analys is, multi-pack rodenticide produ cts are only sold with one bait station; therefore, the average placement price accounts for a proportion of the cost of th e 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 co st 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 pl acement 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 trap s 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 associ ated with switching fr om SGARs in multi-packs

with reusable bait stations to th e alternative rodent control met hods 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 th at 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 re usable bait stations w ould 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 chroni c mouse problem that may not be adequately represented by the single infestat ion scenarios used in this analysis. As discussed above, the estimated cost savings may indicate a perceive d benefit from SGARs or may be a function of price variability and/or product availability. Ho wever, 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 Mu lti-Pack SGARs in Bait Stations to Mouse Control Products Accepted Under the Proposed Cancellations, Mouse Control

Minor Infestation 1 Major Infestation 2

Cost per
Infestation ($) Incremental

Cost 3 Cost per
Infestation ($) Incremental

Cost

Baseline: SGARs in Multi

‐ Packs with Reusable

Bait Stations 5 $49.67

‐ $99.34

‐

### 28 Minor Infestation 1 Major Infestation 2

Cost per Incremental

3 Cost per Incremental

Alternatives Under

the Proposed
Mitigation FGAR/Acute Rodenticide

Blocks in Pre

‐ Baited,
Single

‐ Use Bait Stations 5 $10.53

‐ $39.14 $21.06

‐ $78.28
FGAR/Acute Rodenticide

Block Multi

‐ Pack with

Reusable Bait Stations 4 $41.66

‐ $8.00 $83.33

‐ $16.01

Snap Trap, Traditional 6,7 $11.89

‐ $37.78 $23.77

‐ $75.57

Snap Trap, Covered 6,8 $20.65

‐ $29.02 $41.30

‐ $58.04

Glue trap 6 $7.00

‐ $42.66 $14.01

‐ $85.33

Source: In-store visits, on-line searches, and Bell Labo ratories (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 ro dent control option less the baseline cost (i.e., the current cost of control). 4 Of the mouse control products sampled in this analys is, multi-pack rodenticide produ cts are only sold with one bait station; therefore, the average placement price accounts for a proportion of the cost of th e 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 co st 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 rodentic ides 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 pl acement 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 trap s 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 me thods 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 w ill incur the least costs. However, with 60% of rodenticides sales being for pl ace packs and 90% of rodenticides sales being for products that control mice (Kline, 2006), the switch from l oose-form rodenticide placements to the most

similar rodenticide that would be availabl e post-mitigation (i.e., single-use FGAR/acute rodenticides in bait stations) for mouse contro l 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 placem ent price of $0.24.29Table 3-8: Incremental Cost ComparisonAcross Rodent Control Methods, Mice.AlternativesUnderProposedMitigationBlock‐FormRodenticides1SGAR,Loose‐Form2SGARsinPre‐Baited,Single‐UseBaitStations3SGARsinMulti‐PackswithReusableBaitStations4IncrementalCost5IncrementalCost5IncrementalCost5IncrementalCost5MinorInfestation6MajorInfestation7MinorInfestation6MajorInfestation7MinorInfestation6MajorInfestation7MinorInfestation6MajorInfestation7FGAR/AcuteRodenticideBlocksinPre‐Baited,Single‐UseBaitStations3$6.08$12.16$1.49$2.98‐$10.40‐$20.79‐$39.14‐$78.28FGAR/AcuteRodenticideBlockMulti‐PackwithReusableBaitStations4$37.21$74.43$32.63$65.26$20.74$41.48‐$8.00‐$16.01SnapTrap,Traditional8,9$7.43$14.87$2.85$5.70‐$9.04‐$18.08‐$37.78‐$75.57SnapTrap,Covered8,10$16.20$32.40$11.61$23.23‐$0.28‐$0.55‐$29.02‐$58.04Gluetrap8$2.55$5.11‐$2.03‐$4.07‐$13.92‐$27.84‐$42.66‐$85.33Source: 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 inthe residential consumer market and are defined as bait bits, pellets,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; therefore, the average placementprice accounts for a proportion of the cost of the bait stationin assuming that a residential consumer will reuse the bait station for chronic mouse controlissues. The prices for the infestation scenarios reflect the cost from purchasing enough packagesto acquire the needed numberof bait station for a minorinfestation (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 costof 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 ofsingle-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 stillview the rodent carcass.10 Covered snap traps include products thatblock the rodent carcass from a user’s view.

### 30 3.5.3.2 

### Rat Control

Although incremental costs faced by residential c onsumers treating for rats differs in comparison to costs being faced when treating for mice, th e general method of comparing baseline costs to costs incurred when adopting alternatives av ailable under the proposed mitigation is similar between the two. Table 3-9 presents the averag e price of rat control op tions per placement and for minor and major infestations. The averag e price of a single rodenticide placement for controlling rats from Table 3-2 is also presented.

Table 3-9: Average Price Faced by a Reside ntial Consumer Treating for Minor and Major

Rat Infestations

Control Method Average Expenditure

for Rat Control per Single Rodenticide

Placement 1 Average Expenditure

for Rat Control in a
Minor Infestation 2 Average Expenditure

for Rat Control in a Major Infestation 3

Baseline ‐ Products Proposed to be Cancelled

Block

‐ Form Rodenticides 4 $0.74 $4.46 $8.92

SGARs, Loose Form 5 $1.12 $6.73 $13.46

SGARs in Pre

‐ Baited,
Single

‐ Use Bait Stations 6

‐ ‐ ‐ SGARs in Multi

‐ Packs

with Reusable Bait

Stations 7 $17.14 $102.83 $199.01

Alternatives Under Proposed Mitigation

FGAR/Acute Rodenticide

Blocks in Pre

‐ Baited,
Single

‐ Use Bait Stations 6 $8.83 $53.00 $106.01

FGAR/Acute Rodenticide

Block Multi

‐ Pack with

Reusable Bait Stations 7

‐‐‐ Snap Trap, Traditional 8 $3.27 $19.62 $39.23

Snap Trap, Covered 9

‐‐‐
Glue trap $1.89 $11.35 $22.69

Source: In-store visits, on-line searches, and Bell Laborato ries (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., baite d 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 rodentic ides in bait stations represents the price of a baited disposable station.

### 31 7 The average placement price of a SG AR multi-pack rode nticide 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 trap s 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 contro l, the cost of rodent control in a minor infestation and major infestation reflects six and 12 placements, resp ectively. As mentioned in Section 3.5.2, the methodology for determining the placement price fo r multi-pack rodenticides in bait stations

differs from that used in the mouse control scenar io. That is, for rat control, since no multi-packs are sold with a bait station, it is assumed that multi-pack roden ticides are used in conjunction with bait stations purchased separately which co st, 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 separa tely from a bait station post-mitigation.

Although actual costs of mouse and rat control options diffe r, mouse and rat control show somewhat similar differences in the relative pric es of alternatives. For rat control, SGAR multipack rodenticides in bait st ations are the most expensive, followed by SGAR single-use

rodenticide in bait stations. Block-form roden ticides are the most affordable option across all

rodenticide control methods consid ered in this analysis. Prices for rat control products in the baseline range from $0.74 to $17.14 per placem ent, $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 sta tions are the most expensive opti on while glue traps are the least expensive. Prices for rat control alternativ es that would be ava ilable under the proposed mitigation range from $1.89 to $8.83 per plac ement. 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 incrementa l costs associated with switching from rat

control methods that would be canceled to altern atives that would rema in available under the proposed mitigation. Each table focuses on a sepa rate baseline rat control option and presents

the incremental cost associated w ith minor and major infestations.

Table 3-10 presents the incremental costs as sociated with switching from block-form

rodenticides to alternatives that would be av ailable under the proposed mitigation. In a minor infestation, the average cost for block-form rode nticides 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 ch oose to continue using rodent control methods post-mitigation that are most similar to those th ey 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 bloc k-form rodenticides is $8.92, and the cost of switching to the available alternatives under th e proposed mitigation ranges from $13.78 (glue trap) to $97.09 (single-use FGAR/acu te rodenticide blocks in bait st ations). 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 th is case is FGAR/acute rodenticide blocks with

stations. If a consumer were to make th is 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 near ly 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 Re sidential Consumers Switching from BlockForm Rodenticides to Alternatives Accepte d Under the Proposed Cancellations, Rat

Control

Minor Infestation 1 Major Infestation 2

Cost per
Infestation ($) Incremental

Cost 3 Cost per
Infestation ($) Incremental

Cost

Baseline: Block

‐ Form Rodenticides 4 $4.46

‐ $8.92

‐

Alternatives

Under the
Proposed
Mitigation FGAR/Acute

Rodenticide Blocks in

Pre

‐ Baited, Single

‐ Use

Bait Stations 5 $53.00 $48.55 $106.01 $97.09
FGAR/Acute

Rodenticide Block

Multi

‐ Pack with

Reusable Bait

Stations 6

‐ ‐ ‐  ‐ Snap Trap,

Traditional 7,8 $19.62 $15.16 $39.23 $30.32

Snap Trap, Covered 7,9

‐ ‐ ‐  ‐ Glue trap 7 $11.35 $6.89 $22.69 $13.78

Source: In-store visits, on-line searches, and Bell Labo ratories (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 rode nt 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 rodentic ides in bait stations represents the price of a baited

disposable station. 6 FGAR/acute rodenticide multi-pack blocks with bait st ations 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 un it of control—i.e., one trap or roden ticide 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 as sociated with switching from loose-form

rodenticides to alternatives that would be avai lable under the proposed mitigation. In a minor rat infestation, the average cost for loose-form roden ticides 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 co nsumers will most likely face incremental costs of $46.28 per minor infestation.

In a major infestation, the average cost for loos e-form rodenticides is $13.46 and the cost of switching to the alternatives available under th e 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 roden ticides to control rats, post-mitigation, the most

similar rodenticide that would be available is si ngle-use FGAR/acute rodenticide blocks in bait stations, resulting in averag e incremental costs of $92.55.

Table 3-11: Incremental Costs Incurred by Re sidential Consumers Switching from LooseForm SGARs to Alternatives Accepted Und er the Proposed Cancellations, Rat Control

Minor Infestation 1 Major Infestation 2

Cost per
Infestation ($) Incremental

Cost 3 Cost per
Infestation ($) Incremental

Cost 3

Baseline: Loose

‐ Form SGARs 4 $6.73

‐ $13.46

‐

Alternatives

Under the
Proposed
Mitigation FGAR/Acute

Rodenticide Blocks in

Pre

‐ Baited, Single

‐ Use

Bait Stations 5 $53.00 $46.28 $106.01 $92.55
FGAR/Acute

Rodenticide Block

Multi

‐ Pack with

Reusable Bait

Stations 6

‐ ‐ ‐  ‐ Snap Trap,

Traditional 7,8 $19.62 $12.89 $39.23 $25.78

Snap Trap, Covered 7,9

‐ ‐ ‐  ‐ Glue trap 7 $11.35 $4.62 $22.69 $9.24

Source: In-store visits, on-line searches, and Bell Labo ratories (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 rode nt 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 av ailable 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 rodentic ides 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 pl acement 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 trap s 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 ba it stations, suggesting that these products are not currently marketed to homeowners. Ta ble 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. Alt hough 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 cont rol 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 av ailable 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 rodentic ide blocks in bait stations. In this case there is a potential cost savings of $49.82.

In a major infestation, the average cost for SGAR s 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 rodent icide 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 sugge sts a chronic rat problem rather than a single

infestation.

Table 3-12: Incremental Cost from Switching from SGARs in Multi-Packs with Reusable

Bait Stations to Alternatives Accepted Under the Proposed Cancellations, Rat Control

Minor Infestation 1 Major Infestation 2

Cost per
Infestation ($) Incremental

Cost 3 Cost per
Infestation ($) Incremental

Cost

Baseline: SGARs in Multi

‐ Packs with

Reusable Bait Stations 4 $102.83

‐ $199.01

‐

Alternatives

Under the
Proposed
Mitigation FGAR/Acute

Rodenticide Blocks in

Pre

‐ Baited, Single

‐ Use Bait Stations 5 $53.00

‐ $49.82 $106.01

‐ $93.00

### 35 Minor Infestation 1 Major Infestation 2

Cost per
Infestation ($) Incremental

Cost 3 Cost per
Infestation ($) Incremental

Cost

Baseline: SGARs in Multi

‐ Packs with

Reusable Bait Stations 4 $102.83

‐ $199.01

‐

FGAR/Acute

Rodenticide Block

Multi

‐ Pack with

Reusable Bait

Stations 4

‐ ‐ ‐  ‐ Snap Trap,

Traditional 6,7 $19.62

‐ $83.21 $39.23

‐ $159.77

Snap Trap, Covered 6,8

‐ ‐ ‐  ‐ Glue trap 6 $11.35

‐ $91.48 $22.69

‐ $176.32

Source: In-store visits, on-line searches, and Bell Laborato ries (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 rode nt control option less the baseline cost (i.e., the current

cost of control). 4 The average placement price of a SG AR multi-pack rode nticide for rats reflects th e price of one block-form

rodenticide and one bait station, purchased separately. Th e 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 an d 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 co mpleted 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 rodentic ides in bait stations represents the price of a baited

disposable station. 6 Single placements reflect a single un it of control—i.e., one trap or roden ticide 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 ra t control is presented in Table 3-13. In general, the switch from bl ock- and loose-form rode nticides 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 plac e 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 availa ble 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 rodenticid es are expected to incur these costs, however, as rat control products make up 10% of rodenticide sales and on ly 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

Rodenticides 1 SGAR,

Loose

‐ Form 2 SGARs in Multi

‐ Packs

with Reusable Bait

Stations 3

Incremental Cost 4 Incremental Cost 4 Incremental Cost 4

Minor

Infestation 5 Major

Infestation 6 Minor

Infestation 5 Minor

Infestation 6 Major

Infestation 5 Minor

Infestation 6

FGAR/Acute

Rodenticide

Blocks in Pre

‐ Baited, Single

‐ Use

Bait Stations 7 $48.55 $97.09 $46.28 $92.55

‐ $49.82

‐ $93.00
FGAR/Acute

Rodenticide Block

Multi

‐ Pack with

Reusable Bait

Stations 3

‐  ‐ ‐ ‐ ‐  ‐ Snap Trap,

Traditional 8,9 $15.16 $30.32 $12.89 $25.78

‐ $83.21

‐ $159.77

Snap Trap,

Covered 8,10

‐  ‐ ‐ ‐ ‐  ‐
Glue trap 8 $6.89 $13.78 $4.62 $9.24

‐ $91.48

‐ $176.32

Source: In-store visits, on-line searches, and Bell Laboratori es (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 SG AR multi-pack rode nticide for rats reflects th e price of one block-form rodenticide and one bait station, purchased separately. Th e 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 bl ocks cannot be sold sepa rately under the proposed mitigation.

4 Incremental costs are calculated as the cost of each rodent control option le ss 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 rodentic ides 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 certai n rodent control products, BEAD places the estimated incremental changes in rode nt control costs in the context of household income and other expenditures. This analysis fo cuses 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 impact s. 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 inco me 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-thre shold 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 th e last three months, while this figure is less than six percent for households above the poverty line in the United St ates. Thus, the impact s of cancelling certain rodent control products may be dispropor tionately felt by low-income households.

In this analysis, EPA considers the impacts of th e 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 Bu reau’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, hous ing 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, in cluding food. In orde r 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 mi nor or major infestati on, monthly—rather than annual—disposable income is cons idered. Monthly income is appr opriate in this situation since low-income households may have limited savi ngs on which they can draw for unexpected expenses and high borrowing costs if those expens es are distributed across future periods. Further, available data only indicate recent signs of rodents; it is uncl ear 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 a nd 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 co ntrol measures in comparison to the baseline average cost of rodent contro l 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 fo r 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., er ring 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 percen tage 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 mont hly non-housing income (using multi-pack

FGAR/acute rodenticide blocks in reusable bait stations rather than block-form rodenticides) when considering all rodent cont rol alternatives that would be available under the proposed mitigation. The most likely outcomes are repres ented by households that would typically use

block-form rodenticides or loose-form SGAR s and would under the proposed mitigation use single-use FGAR/acute rodenticide blocks in ba it stations. The impacts from switching from loose-form and block-form rodenticides to sing le-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, respec tively, 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 switchi ng to certain alterna tives 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 cont rol 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 mu ltiple 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. Househol ds switching from multi-pack SGARs in reusable bait stations to multi-pack FGAR/acute rodentic ide blocks in reusable bait stations are not expected to be measurably affected.39Table 3-14. Incremental Cost to a Low-Income Household with $900 Post-Housing Monthly Disposable Income, MouseControl.1AlternativesUndertheProposedMitigationBlock‐FormRodenticides2SGAR,Loose‐Form3SGARsinPre‐Baited,Single‐UseBaitStations4SGARsinMulti‐PackswithReusableBaitStations5MinorInfestation6MajorInfestation7MinorInfestation6MajorInfestation7MinorInfestation6MajorInfestation7MinorInfestation6MajorInfestation7FGAR/AcuteRodenticideBlocksinPre‐Baited,Single‐UseBaitStations40.87%2.12%0.35%1.09%‐0.99%‐1.59%‐4.23%‐8.07%FGAR/AcuteRodenticideBlockMulti‐PackwithReusableBaitStations54.19%8.39%3.68%7.35%2.34%4.67%‐0.90%‐1.80%SnapTrap,Traditional8,90.84%1.68%0.32%0.64%‐1.02%‐2.04%‐4.26%‐8.51%SnapTrap,Covered8,101.83%3.65%1.31%2.62%‐0.03%‐0.06%‐3.27%‐6.54%Gluetrap80.29%0.58%‐0.23%‐0.46%‐1.57%‐3.14%‐4.81%‐9.61%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 maynot 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. Percentage impact calculated as theincrease 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 solidssold without stations.3 Loose-form rodenticides only include SGARs and no FGARs/acutes are available inthe 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 Of the mouse control products sampled in this analysis,multi-pack rodenticide products are only sold with one bait station; therefore, the average placementprice accounts for a proportion of the cost of the bait stationin assuming that a household will reuse the bait station for chronic mouse control issues. Theprices for the infestation scenarios reflectthe cost from purchasing enough packages to acquire the needed number of bait station for a minor infestation (sixtraps) 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 ofsingle-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 stillview 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 contro l costs are presented in Table 3-15 and range from a cost savings of 19.87% (using glue traps ra ther 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 sta tions in a major infestation) of a household’s monthly non-housing income at the poverty threshold. Households at the poverty threshold are e xpected to incur costs ranging from approximately 5.47% (minor infestati on) to 10.94% (major infestation) of their monthly non-housing income when switching from block-form rodenticid es to single-use

FGAR/acute rodenticide blocks in bait stati ons. For households adopting single-use FGAR/acute

rodenticides in bait stations who used SGAR loos e-form rodenticides in the baseline, incremental costs range from 5.21% (minor infestation) to 10.43% (major infestat ion) of a household’s monthly non-housing income. If a household were to switch from mu lti-pack SGAR with

reusable bait stations to single-use FGAR/acute r odenticides in bait statio ns 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-pack s suggests a chronic rat problem rather than a single infestation.

Table 3-15. Incremental Cost to a Low-In come Household with $900 Post-Housing Monthly Disposable Income, Rat Control. 1

Alternatives

Under the
Proposed
Mitigation Block

‐ Form

Rodenticides 2 SGARs,

Loose

‐ Form 3 SGARs in Multi

‐ Packs

with Reusable Bait

Stations 4

Minor

Infestation 5 Major

Infestation 6 Minor

Infestation 5 Major

Infestation 6 Minor

Infestation 5 Major

Infestation 6

FGAR/Acute

Rodenticide

Blocks in Pre

‐ Baited, Single

‐ Use Bait

Stations 7 5.47% 10.94% 5.21% 10.43%

‐ 5.61% ‐ 10.48% FGAR/Acute

Rodenticide

Block Multi

‐ Pack with

Reusable Bait

Stations 4

‐  ‐ ‐ ‐ ‐  ‐ Snap Trap,

Traditional 8,9 1.71% 3.42% 1.45% 2.90%

‐ 9.38% ‐ 18.00%

Snap Trap,

Covered 8,10

‐  ‐ ‐ ‐ ‐  ‐
Glue trap 8 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 av ailable 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 an alysis, SGAR multi-pack rodenticide products are only sold with one bait station; therefore, the average placement price accounts for a proportio n 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 co st 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 bl ocks cannot be sold sepa rately 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 rodentic ides in bait stations represents the price of a baited disposable station 8 The price for a single placement of single-use rode nticides in bait stations represents the price of a baited disposable station. 9 Traditional snap traps include plastic and wooden trap s 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 resi dential 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 hous ehold would decide to adopt. In terms of total impacts to society, the impact of the proposed mitigation on th e 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 househol ds (i.e., those treating for mice), impacts equivalent to one to two percent of monthl y non-housing income are expected. Impacts are negligible for households that are already usi ng bait stations, whether single-use or multi-pack rodenticides. Although effects will be higher on re sidential 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 contro l 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 (Co rrigan 1997). This inte nse 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 detail ed information see Jacobs 2011)

The Rodenticide Resistance Action Committee (RRAC) and other authors use Greaves’

definition for rodenticide resistan ce. Anticoagulant resistance ha s been defined as “a major loss of efficacy in practical conditions where the antic oagulant has been applied correctly, the loss of efficacy being due to the presence of a strain of rodent with a heri table and commensurately

### 42 reduced sensitivity to the anticoagulant” (Gr eaves,1994 cited in Corrigan 1997; Buckle, et al., 1994; RRAC). This definition recogn izes that resistance is geneti c, and excludes control failures attributable to poor operating t echniques and reinvasion (Corriga n 1997; Buckle, et al., 1994).

Chiri (2006) reported that previous research de monstrated 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 worl dwide, including Canada, but none have yet been identified in the U.S. Resistance to all anticoagulants is possi ble since they essentially use the same mode of action, but it requires intensive sele ction pressure to change alle le frequency in populations.

Typically, anticoagulants, such as warfarin, inhibit vitamin K 2,3-epoxide reductase and block the production of vitamin K-dependent blood-clo tting factors. This results in lethal hemorrhaging. Warfarin-resistant rats initially showed that wa rfarin no longer inhibited the vitamin K epoxide reductase (VKOR). Subseque ntly much research has focused on rat VKOR complex (VKORC) mutations (Rost, et al., 2009; Ro st, 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 th e 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). Misenh eimer, 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 Da nish 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, Heiber g (2009) found that resist ant sewer rats did not

have resistance-related mutati ons in the VKORC1 gene. Hen ce resistance alleles at VKORC1 alone do not totally explain an ticoagulant resistance.

Genetic differences do not account for all the failur es of rodenticides attr ibutable. Behavioral resistance has been offered as another explan ation. Clapperton (2006) reported that the house

mouse has been demonstrated to have an inheri table behavioral cereal aversion; exacerbated by ample alternative foods. Rats are known to be neophobic and ma y avoid anything new in their environment, thus avoiding rodenticide ba its (Marsh 1994; Corrigan 2001; Timm 1994b; Clapperton, 2006).

After the proposed cancellations, re sidential 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 residentia l consumers choose their products based on active ingredients. One common rodentic ide, 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 c onsumers are likely to be usi ng the same rodenticide active ingredient in an area. Ther efore it is unknown how much sel ection 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). Howe ver, 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 cu rrently rely on rodenticides will most likely continue to use rodenticides (i.e., FGAR/acute rodenticide blocks in ba it 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 cons umer’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 anti coagulants. Furthermore, rode nts’ bait preference is based on other factors, such as palatability, rather than active ingredient. Evid ence suggests that bait stations have similar product performance to r odenticides placed without bait stations. No differences in rodent consumption were found between block and loose formulations. The rodenticides have unique chemistries, different a ffinities for binding sites and therefore, different lethal doses, but if lethal doses are obtained, they result in th e 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 rode nts. It is likely that consumers switching to products that would be available under the pr oposed 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 t hose that would be available post-mitigation. Residential consumers treating for mouse infestations are expected to switch from rodenticides that would no longer be availabl e to similar rodentic ide products that wo uld be available postmitigation. Incremental costs from this change range from $2 to $12 for mouse control.
However, loose-form rodenticides account for a ma jority of rodenticide sales and thus residential consumers using such products make up the larges t proportion of those that will be impacted by the mitigation measures. Therefore, most reside ntial consumers are expected to see an average increase in cost of $1.50 in a minor infesta tion and $3 in a major infestation, or $0.25 per placement. With 90% of rodenticides sales bein g 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 infest ations, incremental costs range from a cost savings to $97 per infestation ac ross all rodenticide alternatives that would be available postmitigation; note that a cost savings may entail th at non-monetary costs exist that have not been accounted for in this analysis.

For mouse control, it is expected that most resi dential consumers are currently using loose-form rodenticides and will incur incremental costs rang ing 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 ra t control, there are lower cost alternative contro l 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 car cass 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 fro m switching from control options that would no longer be available under the NOIC to sim ilar products that woul d be available postmitigation was also examined. For mouse control, the average incremental costs for consumers switching from non-RMD conforming rodenticide products to rodenticides th at 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 infest ation and up to 2.12% for a major infestation. For rat control, consumers at the poverty th reshold 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 mi nor infestation and 10.94% of their monthly nonhousing income in a major infestation.

### 45 

### 6 REFERENCES

Baroch, J. 2004. Warfar in: a forgotten weapon? Pest Control Technology , August issue, 44-52.

Bell Laboratories. Personal Communication. 6/23/2011.

Buckle, A. P., C. V. Prescott, and K. J. Wa rd. 1994. Resistance to the first and second generation anticoagulant rodenticides – a new perspective. Pro. 16 th 

### Vertebr. Pest Conf, Eds, W.

S. Halverson & A. C. Crabb. Published at Univ . of Calif., Davis. Pp 138-144. Available at: http://digitalcommons.unl.edu/vpc16/7. Accessed July 25, 2011.

CDC. 2010. Centers for Disease Control and Prevention. Rodents. Located at http://www.cdc.gov/rodents/ Accessed June 21, 2011.

Chiri, A. A. August 3,2005. Response to comments from stakeholders on analysis of rodenticide bait use. Memorandum to Kelly White. Located at: http://www.regulations.gov/#!documen tDetail;D=EPA-HQ-OPP-2006-0955-0007.

Chiri, A. A. January 23, 2006. Analysis of rodenticide bait use. BEAD Memorandum to SRRD/Kelly Sherman. Located at: http://www.regulations.gov/#! documentDetail;D=EPA-HQOPP-2006-0955-0004

.

Chiri, A. A., J. Becker, and Jin Kim. Sept. 20, 2006. Impact assessment for proposed rodenticide mitigation (DP 332577). BEAD Memorandum to SRRD/Kelly Sherman. Located

at: http://www.regulations.gov/#!documentDe tail;D=EPA-HQ-OPP-2006-0955-0003.

Chiri, A. A., J. Becker, and E. Rim. Janua ry 3, 2008. Response to comments submitted to Docket No. EPA-HQ-OPP-2006-0955, proposed risk mitig ation decision for nine rodenticides. BEAD Memorandum to SRRD/Kelly Sherman. Located at: http://www.regulations.gov/#!documen tDetail;D=EPA-HQ-OPP-2006-0955-0755.

City of Alexandria, VA. 2011. Code Administ ration: Rodent Control Program. Found at: http://alexandriava.gov/fire/code/info/de fault.aspx?id=5382. Accessed: July 18, 2011.

Clapperton, B. K. 2006. A review of the current knowledge of r odent behaviour in relation to

control devices. Science for Cons ervation 263. 55 p. Available at: http://www.conservation.org.nz/upload/documents /science-and-technical/sfc263.pdf. Accessed: July 25, 2011.

Corrigan, R. M. 1997. Rats and mice. In : Handbook of Pest Control- Mallis, 8 th 

### ed. Mallis

Handbook and Technical Traini ng Company. Pp. 11-105.

Corrigan, R. M. 2001. Rodent Control: A Practical Guide for Pest Management Professionals. GIE Media, Cleveland. 351 pp.

### 46 EPA. May 2008 (Revised June 2008). Risk Miti gation Decision for Ten Rodenticides. Located at: http://www.regulations.gov/#!documen tDetail;D=EPA-HQ-OPP-2006-0955-0764.

Frantz, S.C. and D.E. Davis. 1991. Bionomics and integrated pest management of commensal rodents. In: Gorham, J.R. (ed.) Ecolo gy and Management of Food-Industry Pests , FDA

Technical Bulletin 4 , Association of Official Analyt ical Chemists, Arlington, VA, 243-313.

Frieden, T.R. 2003. New York City Department of Health and Mental Hygiene, Rodent Control in New York City, Testimony before New York City Council, Committees on Health and on Governmental Operations, October 28, 200 3, City Hall, New York, New York. Located at: http://www.nyc.gov/html/doh/htm l/public/testi/testi20031028.html.

Heiberg. A.C. 2009. Anticoagulant resistance: a re levant issue in sewer rat (Rattus norvegicus) control? Pest Manag Sci 65(4):444-449.

Hovanic, C., S. J. Collman, and D. Pehling. 201 0. Rats and mice. Wash ington State University Extension. Available at: http://gardening.w su.edu/library/comm001/comm001.htm. Accessed: July 18, 2011.

Illinois Department of Public Health. Undated. House mouse prevention a nd control. Available at: http://www.idph.state.il.us/envhealth/p chousemouse.htm. Accessed: July 18, 2011

Illinois Department of Public Health. 2005. Prevention and Control. Municipal Rodent Management. Located at: http://www.idph.s tate.il.us/pcmunicipal_rodents.html.

Jacobs, W.W. 2011. Efficacy issues regarding c ontrol of commensal rodents in the U.S. using registered rodenticides. 62 pages.

Jokic, G, M Vuksa, and S Dedovic. 2008. Effic acy and palatiablity of different rodenticide formulations applied against house mouse (Mus musc ulus L.) in plant storage facilities. Pestic. Phytomed. (Belgrade), 23:115-121. Found at: http://www.doiserbia.nb.rs/img/doi/1820- 3949/2008/1820-39490802115J.pdf. Accessed: May 18, 2011.

Kaukeinen, D. 2009. Parrafinized rodenticides are he re to stay. Pest Management Professional. Available at: http://www.mypmp.net/rodents/parra finized-rodenticides-are -here-stay?print=1. Accessed: October 5, 2011.

Kaukeinen, D. and C. Prescott. 2007. Warf arin Revisited: New Information on an Old

Rodenticide. Pest Control Web Exclusive, 3/21/2007, at: http://www.pestcontrolmag.com/ME2/dirmod.asp?sid=&nm=&type=news&mod=News&mid=9

A02E3B96F2A415ABC72CB5F516B4C10&tie r=3&nid=6D480F7DCABB4BB88BE7C9EAB1

886171.

Koehler, P.G. and W. H. Kern, Jr. 2008. Ra t and mouse control. University of Florida Cooperative Extension Service, Institute of Food and Agricultural Sciences ENY-224. http://edis.ifas.ufl.edu/pdffiles/DH/DH04400.pdf. Accessed: July 21, 2011.

### 47 Marsh, R.E. 1994. Roof rats. Pages B-125 - B-131. In : S.E. Hyngstrom, R.M. Timm, and G.E. Larson (Eds.) Prevention and Control of Wildlife Damage , University of Nebraska Cooperative Extension, Institute of Agriculture and Natural Resources, University of Nebraska, Lincoln, NE; and U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Animal Damage Control, Riverdale, MD.

Massachusettes Tenet’s Handbook. The 'Lectric Law Library. Found at: http://www.lectlaw.com/files/lat07.h tm. Accessed: July 26, 2011.

Merriam-Webster Online. 2011. Commensal. http://www.merriamwebster.com/dictionary/commensal.

Misenheimer, T. M., M Lund, A.E. M. Baker, a nd J. W. Suttie. 1994. Biochemical basis of

warfarin and bromadiolone resistance in th e house mouse, Mus musculus domesticus. Biochemical Pharmacology 47 (4):673-678.

Morriss, G.A., C.E. O’Connor, A. T. Airey, and P. Fisher. 2008. Factors in fluencing palatability and efficacy of toxic baits in ship rats, Norway rats, and house mice. Science for Conservation 282. 26 p. Available at: http://www.cons ervation.gen.nz/upload/documents/science-andtechnical/sfc282.pdf. Accessed: July 13, 2011.

New York City (NYC). 2007. Housing and Mainte nance Code. New York City Administrative Code, Title 27, Chapter 2. Located at: http://www.housingnyc.com/html/resources/hmc/hmc.html.

New York City Department of Health and Ment al Hygiene. Undated. Preventing rats on your property – a guide for property owners a nd tenets. Publication number EHS6356051- 408.Available at: http://www.nyc.gov/html/doh/dow nloads/pdf/pest/rodent_control.pdf.

New York City Department of Health and Me ntal Hygiene. 2011. Who is responsible for preventing rats? Available at: http://www.nyc .gov/html/doh/html/rats/responsible.shtml.

Pelz, H. J., S. Rost, M. Hunerberg, A. Fregin, A. Heiberg, K. Baert, A. D. MacNicoll, C. V. Prescott, A. Walker, J. Oldenburg, and C. R. Mulle r. 2005. The genetic basis of resistance to anticoagulants in rodents. Genetics 170:1839-1847.

Pierce, R. A. 1993. Controlling house mice. University of Miss ouri Extension G9441.

Available at: http://extension.missouri.edu/p/G9442 . Accessed August 31, 2011.

Pitt, WC, LC Driscoll, and RT Sugihara. 2011. E fficacy of rodenticide ba its for the control of three invasive rodent species in Hawaii. Arch. Environ Cont am Toxicol 60:533-542. Available at: http://www.springerlink.com/content/10r m084318524012/ . Accessed: April 11, 2011.

### 48 Rim, E. May 20, 2008. Addendum to impact a ssessment for proposed rodenticide mitigation (DP 332574). BEAD Memorandum to SRRD/Kelly Sherman. Located at: http://www.regulations.gov/#!documen tDetail;D=EPA-HQ-OPP-2006-0955-0754.

Rost, S., A. Fregin, V. Ivaskevicius, E. Conzel mann, K. Hortnagel, H. Pelz, K. Lappegard, E. Seifried, I. Scharrer, E. G. D. Tuddenham, C. R. Muller, T. M. Strom, and J. Oldenburg. 2004.

Mutations in VKORC1 cause warfarin resistance a nd multiple coagulation factor deficiency type

2. Nature 427:537-541.

Rodenticide Resistance Action Committee (RRAC). Definition of resistance. Available at: http://www.rrac.info/ab out_rrac_02.htm. Acce ssed: June 15, 2011.

Rost, S., H. Pelz, S. Menzel, A. D. MacNicoll, V. Leon, K. Song, T. Jakel, J. Oldenburg, and C.

R. Muller. 2009. Novel mutations in the VKORC1 gene in wild rats and mice – a response to 50 years of selection pressure by warfar in? BMC Genetics 2009, 10:4. Doi:10.1186/1471-2156-

10-4.

Timm, R.M. 1994a. House mice. Pages B-31 - B-46. In : Hyngstrom, S.E., Timm, R.M., and Larson, G.E. (Eds.) Prevention and Control of Wildlife Damage, University of Nebraska Cooperative Extension, Institute of Agriculture an d Natural Resources, University of Nebraska, Lincoln, NE; and U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Animal Damage Control, Riverdale, MD.

Timm, R.M. 1994b. Norway rats. Pages B-105 - B-120. In : Hyngstrom, S.E., Timm, R.M., and Larson, G.E. (Eds.) Prevention and control of wildlife damage, Univ ersity of Nebraska Cooperative Extension, Institute of Agriculture an d Natural Resources, University of Nebraska, Lincoln, NE; and U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Animal Damage Control, Riverdale, MD.

U.S. Census Bureau. 2005-2009. American Community Survey 5-Year Estimates: Data Profile Highlights. Located at: http://factfinder.census.gov/ servlet/ACSSAFFFacts?_event=& geo_id=01000 US&_geoContext= 01000US&_street=&_county=&_cityTown=&_sta te=&_zip=&_lang=en &_sse=on&ActiveGeo

Div.

U.S. Census Bureau. 2009. American Housing Surv ey (AHS) for the United States. Series H150. Located at: http://www.census.gov/hhes/www/housing/ahs/ahs09/ahs09.html.

U.S. Census Bureau. 2010. Pove rty Highlights. Located at: http://www.census.gov/hhes/www/povert y/about/overview/index.html.

U.S. Department of Health and Human Services (DHS). 2011. The 2011 HHS Poverty Guidelines. Located at: http://a spe.hhs.gov/poverty/11poverty.shtml.

Vantassel, S., S. Hygnstrom, and D. Ferraro. 2006. Bait stations for contro lling rats and mice. University of Nebraska-Lincoln Extension, In stitute of Agriculture and Natural Resources

### 49 G1646. Available at: http://www.ianrpubs.unl.e du/live/g1646/build/g1646.pdf . Accessed July
21, 2011.

Wallin, R., S. M. Hutson, D. Cain, A. Sweatt, and D. C. Sane. 2001. A molecular mechanism for genetic warfarin resistance in the rat. FASEB J. (September 17, 2001) 10.1096/fj.01-0337fje.

Witmer, G and S Jojola. 2006. What’s up w ith house mice? -- a review. Proc. 22 nd 

### Vertebr. Pest Conf., Eds: RM Timm and JM O’Brien. Pub lished at Univ. of Calif., Davis. Pp 124-130.

Available at: http://www.aphis.usda.gov/wildlife_dama ge/nwrc/publications/06pubs/witmer063.pdf. Accessed: May 17, 2011.

### 50 

### 7 APPENDICES

7.1 Appendix A. Product Pricing Data

Attached as separate doc ument in docket. See:

Cook, C. and E.S. Hill. 2011. Appendix A to Impact Assessment of the Draf t Notice of Intent to

Cancel Selected Residential Consumer Roden ticide Products to Control Commensal Rodents. Environmental Protection Agency Office of Pe sticide 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 obs ervations 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 prev ious 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).