UNDERSTANDING THE NEW SECOND GENERATION RODENTICIDE REGULATION
With the effective date for the upcoming changes to second generation rodenticides (SGAR) looming, July 1, 2014, many technicians and owners still seem to be confused about what these changes mean, or how it affects them. The new regulations designate SGAR products containing brodifacoum, bromadiolone, difenacoum, and difethialone in California as restricted materials. But what does this mean?
It means that only certified private applicators, certified commercial applicators and structural pest control operator and field representatives can use these restricted materials or under their direct supervision. Certified Private Applicators (PAC) and Certified Commercial Applicators (QAL/QAC) are licensed through the Department of Pesticide Regulation (DPR). Structural pest control operators and Field Representatives are licensed through the Structural Pest Control Board.
In the world of Structural Pest Control, this means that applicators cannot use these materials without the direct supervision of an operator or field representative. PCOC's General Pest Committee sent a letter to DPR seeking clarification as to "direct supervision." We are looking to include radio and cell phone communication as "direct supervision." We are waiting for a response. As we currently understand it, DPR does consider an applicator to be in contact with an operator or field rep via radio or cell phone to apply as supervision. We are still seeking clarification.
This also means that only certified applicators, except those licensed under the Structural Pest Control Board, must obtain a restricted materials permit from the County Agricultural Commissioner (CAC) before purchasing or using SGAR products. This means that Structural Pest Control companies do not need a restricted materials permit.
In addition, restricted materials used in a non-agricultural setting, meaning Structural Pest Control, do not require a notice of intent (NOI).
Another major change has been introduced. The distance SGARs can be placed in an above ground bait station from a man-made structure has been switched back to 50 feet unless there is a feature associated with the site that is harboring or attracting the target pest beyond the 50-foot limit. I would suggest that any licensee not take this last part lightly. If you are planning to use an SGAR more than 50 feet from the structure, it had better be in accord with the language of an associated site that is harboring or attracting the target pest. If an inspector sees a bait box outside of the range, you better be able to defend your position as to why the box has been placed there. Similarly, when the infestation is dealt with, I would recommend removing the box as you are supposed to do.
For an easy to use chart on certification/license types and responsibilities and related codes, click HERE.
For the official DPR outline of the changes, click HERE.
D-CON MAKER RECKITT BENCKISER SUES CDPR
-Article from San Francisco Associated Press
SAN FRANCISCO (AP) — The manufacturer of a popular rat poison is suing California over a new regulation that would prevent consumers from buying many types of pesticides for at-home use because they can harm pets and wildlife.
Reckitt Benckiser, a major producer of health and home products, including d-CON rodent poison, filed a lawsuit in San Diego against the California Department of Pesticide Regulation.
The lawsuit argues that the state agency overstepped its authority earlier this month when it classified some consumer pesticides as restricted materials and ordered stores to remove them from shelves by July 1.
"Pest control is integral to public health in California," the company's attorneys wrote in the complaint. "Before DPR eliminates consumer access to the most affordable and effective rodent control available, it must establish that there is substantial evidence supporting the need for the regulation adopted."
The new regulation applies to all pesticide products containing brodifacoum, bromadiolone, difenacoum, or difethialone — chemicals that interfere with blood clotting. The substances, called second-generation anticoagulants, essentially cause the animals that ingest them to bleed excessively.
The regulation has been hailed by advocates like Earthjustice, a public interest law firm representing a number of environmental conservation groups pushing for a federal ban on the rat poisons.
"Reckitt Benckiser knows that California's bold decision to take d-CON off the shelves is a preview of things to come in other states," said Greg Loarie, an Earthjustice attorney.
The pesticide regulation department says the rule is necessary because the substances pose a danger to pets and wildlife.
Charlotte Fadipe, an agency spokeswoman, has said that only pest control companies and trained professionals with state certifications should be able to purchase poisons containing second-generation anticoagulants.
The danger lies in other animals, including family pets, potentially eating a rodent that's ingested the restricted pesticides, she said.
Some species that have been harmed by the poisons include the barn owl, bobcat, coyote, raccoon and endangered San Joaquin kit fox, Fadipe said.
"This is a practical, sensible regulation that goes a long way to protecting our wildlife," said Brian Leahy, the agency's director.
He says the restricted poisons can contain "some pretty powerful chemistry" and stopping their sales will reduced effects to pets and other animals.
In its complaint, Reckitt Benckiser claims the pesticide regulation department violated the law by not giving the public proper notice or opportunity to comment on the rule. It also says the agency failed to study reasonable alternatives and conduct an environmental impact report on the new rule, including what effect rat poisons that don't contain the restricted chemicals would have on wildlife.
"We remain concerned that this decision will result in the increased use of alternative products which contain a powerful neurotoxin with no known antidote in the case of accidental exposure," Tony Brand, a spokesman for d-CON rodent poison, said in a statement.
CLARK PEST CONTROL ACQUIRES PEST MANAGEMENT COMPANIES BUGZ-B-GONE AND STOCK EXTERMINATORS
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