Rodenticide Proposed Interim Decisions Published

On November 29th, the U.S. EPA Office of Pesticide Programs published the proposed interim decisions (PID) for eleven rodenticide active ingredients:

• Brodifacoum, Bromadiolone, Chlorophacinone, Difenacoum, Difethialone, Diphacinone, and Warfarin (see PID here)
• Cholecalciferol and Bromethalin (see PID here)
• Strychnine (see PID here)
• Zinc phosphide (see PID here)

The PID documents and supplementary  materials are comprised of hundreds of pages of dense technical/regulatory information and NPMA is in the process of completing a full analysis. The following summary is based on an initial review of the PIDs and only accounts for structural uses.

Big Takeaways:

• Restricted Use Pesticide (RUP) status for all second generation anticoagulant rodenticides  (SGAR)
• RUP Status for all first generation anticoagulant rodenticides (FGAR) in larger than 4lb packages
• RUP status for all non-anticoagulant rodenticides (Zinc Phosphide, Strychnine, Cholecalciferol and Bromethalin)
• Advisory carcass removal statements for structural uses (except Zinc Phosphide) “While wearing gloves, collect and properly dispose of visible carcasses or target pests or non-target animals. Place carcasses in leakproof plastic bags or other suitable containers and dispose of in the trash or dispose of according to the Pesticide Disposal instructions”
• Mandatory carcass removal statements for all zinc phosphide products. This is mandatory language that requires return visits at specific intervals for at least 2 weeks following application.
• Additional respirator and glove requirements for certain formulations such as meal baits, tracking powder, and pellets. (This will require a closer review to better understand EPA’s justification for inclusion)
• Endangered species risk mitigation language for pilot species: Attwater’s prairie chicken (Texas), California condor (California, Arizona, Utah, Nevada), and Stevens’ kangaroo rat (California)
• Requirements for registrants to create stewardship training and outreach materials

Next Steps:

• NPMA will continue to analyze the PIDs and collaborate with stakeholders to identify how the proposal will impact professional use patterns, better understand the justification for additional PPE.
• EPA has opened a 75-day public comment period.  NPMA will work with registrants and other stakeholders to develop talking points and template letters for companies wishing to submit comments.
• NPMA will coordinate with state associations and outside stakeholders to encourage comment submission.