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Rodent Reports: What the EPA's Rodenticide Ruling Means to PMPs
1 Jul, 2008 By: Dale E. Kaukeinen Pest Management ProfessionalOn May 28, the U.S. Environmental Protection Agency (EPA) released its final ruling on rodenticide mitigation measures that will become law. These risk mitigation decision (RMD) measures have been the subject of much debate for nearly a decade, and the subject of some prior articles in the pages of this magazine (for example, see the March 2007 cover story). Here are the significant points that Pest Management Professionals (PMPs) need to know about the Agency's latest decision.
WHAT PROMPTED THE EPA TO TAKE THIS ACTION?
Although the subject remains controversial, the EPA has decided that rodenticides in unskilled hands have been a significant hazard to children and wildlife, particularly from the second-generation anticoagulant rodenticides (SGARs) containing brodifacoum, bromadiolone and difethialone. During the past 30 years, these SGAR products have become the most popular rodenticides in use by homeowners and professionals alike, because of their excellent performance against pest rodents (including resistant populations).
Like earlier first-generation anticoagulants (warfarin, diphacinone and chlorophacinone), SGARs have a vitamin K antidote in the case of accidental poisoning, a low concentration in bait and delayed action that prevent bait shyness. But unlike the earlier anticoagulants, the SGARs can kill in a single feeding, which provide a significant advantage in effective use with these sporadic-feeding rodents. With greater efficacy also comes greater toxicity to non-target animals, whether from accidental exposure or misuse of products (use contrary to label directions).
 What Happens Next |
The new EPA ruling will take the SGARs completely away from homeowners and will limit retail availability of other types of rodenticides for use in the home to solid bait within bait stations. The ruling will change some aspects of rodenticide products and their use for professional and agricultural users, while allowing SGAR sales to these experienced users to continue.
The EPA collectively calls these two user categories "occupational users," and chose to not reclassify the SGARs as restricted-use products (RUPs) because the SGARs have low applicator risk and simple use directions, unlike most existing RUP products. An RUP status, it was decided, would create unnecessary hardships for applicators, such as additional certification requirements for many occupational users — including livestock and poultry producers.
SGARs will continue to be sold in bulk containers at professional applicator distributors and agricultural product outlets. After the deadline in three years, consumers will not be able to buy any rodenticides in bulk like PMPs, and none of the usual retail sources will carry SGAR products. Further, there will be a label restriction on bulk bait that it is not to be used by homeowners for application in residences.
WHAT ARE THE MAJOR PRODUCT FORMULATION CHANGES THAT PMPS WILL SEE?
The EPA will allow occupational use bait products to continue to be sold as loose (meal, grain or pellet) and solid (block, paste, gel) bait formulations or placepacks containing any of these forms. Because of restrictions in how some of these formulations can be used, some rodenticide manufacturers may choose to discontinue some formulations of rodenticide products containing some active ingredients, particularly loose baits containing the SGAR actives. New forms of solid bait may be developed, and new containment or application features may appear.
WHAT ARE THE MAJOR PACKAGING CHANGES PMPS WILL SEE?
By June 2011 or before, all SGARs containing the actives brodifacoum, bromadiolone, difethialone and difenacoum will be sold by PMP distributors, in unit quantities of 16 lbs. or more (versus 8 lbs. or more in agricultural outlets). Non-SGAR products for all occupational users can only be sold in quantities of 4 lbs. or more. This includes both the first-generation anticoagulants (warfarin, diphacinone and chlorophacinone) and the non-anticoagulant rodenticides (cholecalciferol, bromethalin and zinc phosphide).
These specific quantities come from the EPA's review of current package quantity sizes and the distinctions between purchases by occupational users and homeowners. This change will require many manufacturers to change the quantities and packaging for their professional rodenticide products. It will be illegal for professional (occupational) purchasers of bulk rodenticides to resell any bulk rodenticide in original or lesser quantities to homeowners to do their own residential rodent control.
WHAT LABEL CHANGES WILL OCCUPATIONAL USERS SEE ON PROFESSIONAL-USE PRODUCTS?
The EPA will allow all rodenticide products to be used by PMPs in and around buildings, in alleys, transport vehicles and sewers according to specific product label directions. The requirements to minimize SGARs to consumers will not change how these and other products are used in professional-use settings.
All rodenticides labeled for occupational users for use in residential structures will continue to have a label requirement that a bait station must be used where children, domestic animals or wildlife may be exposed. The EPA will not change regulations concerning existing PMP bait stations that are sold without bait.
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