In July PCT included the feature “Rodenticide Label Quandry,” an update on tough decisions facing EPA regarding professional-use rodenticides.
Additional PCT coverage includes:
- A short story about how the Rodenticide Risk Mitigation Decision affects product labeling in regards to commensal rodents
- Additional comments from industry rodenticide manufacturers
- A link to EPA
Commensal Rodents Only?
Another issue of critical concern with the Rodenticide Risk Mitigation Decision is that with products labeled for commensal rodents (Norway rat, roof rat and house mouse), manufacturersare now required to add the word “only” after the listed pests. This negates the 2(e) exemption written into FIFRA (use against a pest not on the label as long as the application site and technique are on the label). Therefore, rodenticide bait intentionally applied according to label instructions (i.e. within 50-feet of a building and inside tamper-resistant stations) for a target pest not listed on the label (e.g., voles) could be interpreted as a misapplication.
“You are going to get some unintended consequences if, say a chipmunk goes in there and feeds on material, that is a problem,” said Rick Bell, vice president of Government Affairs, Arrow Exterminators, Atlanta, Ga. “What is being removed is our protection under FIFRA 2(e), where it could be a non-target pest that gets killed even though you are applying the product correctly and legally.”
Obviously one of the stakeholder groups most impacted by any type of EPA decision regarding rodenticides is rodenticide manufacturers. Here’s what manufacturers are saying about the June 7 announcement whereby the U.S. Environmental Protection Agency reiterated its intentions previously announced in 2008 under the “Final Risk Mitigation Decision for Ten Rodenticides (RMD).
"All of our rodenticides are compliant and we already had the correct sizes." — Nick Tresslar, marketing manager, BASF Pest Control Solutions
“During the last several months, Liphatech, through considerable effort and expense, has made all the necessary label and registration changes to comply with the new EPA regulations that went into effect on June 4, 2011 for the pest control and animal health markets.” — Thomas Schmit, regulatory manager, Liphatech
“In terms of strategy, it became apparent to me that EPA was moving forward and you could choose to either fight them or choose to help participate in the setting of the rules and modifications that would occur — and that was what I chose to do. As of June 4, all of the products Bell was shipping were post mitigation-compliant and contained post mitigation-compliant labels.” —Steve Levy, chief executive officer, Bell Laboratories
“Our M2030 Victor Multi Kill Brand Block rodenticide with Difenacoum has always had an RMD-compliant label so no changes were required; it’s readily available. Our M2020 Victor Fast Kill Brand Block with Bromethalin is with EPA for re-registration to be RMD compliant.” — Mike Goldstein, PCO sales manager, Woodstream Corporation
“We complied with all the label revisions. No other changes were necessary.” — Richard Poche, president of Scimetrics, manufacter of Kaput products
“When registering our products we made sure our labels would be compliant with the EPA decision, so we had no problems there. We hope that the decision will help PCOs increase their business in the residential sector while reducing secondary poisoning risks.” — Andrej Branc, sales manager for BIMEX Corp., marketers of Brigand rodenticides
“JT Eaton takes RMD very seriously. We ‘ve had all of our bait labels converted to be compliant. We stand behind the EPA’s decision and will continue to support the proper handling of poisonous materials to keep children, pets and non target animals safe from harm. We believe this will increase the demand for professionals to handle residential rodent infestations, because this decision is far more dramatic for consumer bait products.”
—Dale Baker, vice president of sales, J.T. Eaton
“Syngenta had already switched over its WeatherBlok XT product to 16-pound packaging with the new label. Our Talon-G product with a new label will be shipping later this summer. [Syngenta] previously packaged Talon-G bait pellets in 7.5 pound pails with 140 individual place packs while the new selling unit is a 16-pound carton that contains two pails, each with 150 place packs.”
— Dr. ElRay Roper, senior technical representative, Syngenta
Important Web Resource
In the coming months, EPA will be providing additional information for occupational rodenticide users (which includes pest management professionals) on its website for the “Final Risk Mitigation Decision for Ten Rodenticides,” accessible at http://1.usa.gov/rodenticides. Additionally, be sure to visit www.pctonline.com for up-to-date coverage of this issue, as well as additional comments from rodenticide manufacturers and other industry stakeholders.