It’s been four years since the U.S. Environmental Protection Agency issued its Rodenticide Risk Mitigation Decision (RRMD) — a decision that included important revisions to rodenticide labels. While some questions about these label revisions remain, for the most part, manufacturers, distributors, pest management professionals and other stakeholders are adjusting.
Background. The 2008 RRMD included a number of key risk mitigation measures for the professional market that went into effect on June 4, 2011. Thanks to a collaborative effort by the National Pest Management Association (NPMA) and the Association of Structural Pest Control Regulatory Officials (ASPCRO), in March 2012 EPA made important additional revisions to rodenticide labels that provide pest management professionals with much-needed flexibility to manage rodent infestations. Specifically, the new label language:
- Extends the distance from which rodenticides can be placed from buildings from 50 feet to 100 feet and replaces the word “building” with the term “man-made structures” (Note: the phrase “man-made structures” is broadly defined, however, it expressly excludes “fence and perimeter baiting, beyond 100 feet from a structure…”).
- Permits the use of first-generation anticoagulant and non-anticoagulant professional products to treat burrows that are further than 100 feet from buildings and man-made structures.
While this outcome has generally been viewed as a positive for the pest control industry, a number of questions surrounding new (and old) rodenticide labels still exist. When are products with the new labels going to be available? Can I still use products that have the old labels? Has my state approved the amended labels (the new labels need to be approved by both EPA and states)? PCT contacted rodenticide manufacturers to get clarification on these and other issues related to the rodenticide label changes.
AB Bait Company — The manufacturer of Brigand bait products had four products that needed label amendments. These were submitted on April 20 and approved by EPA on May 8. The products also are registered in all 50 states, the District of Columbia, Puerto Rico and the U.S. Virgin Islands. AB Bait Company President Andrej Branc said the products (with the label changes) were expected to be available in August.
Bell Laboratories — Bell Laboratories has 21 products whose labels needed to be amended, and all products were submitted to EPA from April to May. Todd Butzow, vice president of marketing, Bell Laboratories, said that the label revisions to the company’s two top-selling rodenticides — Contrac All-Weather Blox and Final All-Weather Blox — were approved by EPA (and states) in the May/June timeframe and began shipping out of its facility in mid-July. Butzow added, “While the label amendments were being sought, Bell implemented a variety of inventory management techniques to minimize or eliminate stocks of the previous labels. These techniques included short buys, expedited deliveries, product promos, etc., which have resulted in Bell’s ability to transition its top-selling items into the updated labeling without the need for massive overlabeling.”
J.T. Eaton — J.T. Eaton has submitted six registrations to EPA and is awaiting approval. Dale Baker, vice president of sales, J.T. Eaton, said he anticipates products with the new labels to be available market-wide in 2013.
Liphatech — Liphatech submitted a revised label for every bait product it has registered. This includes all of the different products the company actively sells (about 20), and also products Liphatech has registered with EPA but does not actively sell, according to Thomas Schmit, manager of regulatory affairs, Liphatech. At press time, EPA had approved 18 labels with five more labels pending. Lipha-tech Technical Support Manager Ted Bruesch said, “We will get newly registered products on the market as soon as we can after we get the registrations.” Bruesch added that should Liphatech decide to overlabel existing product, the company will do so from its facility.
Syngenta — Pat Willenbrock, brand manager, Syngenta said the company has submitted amended labels for its Talon G and WeatherBlok rodenticides. Willenbrock said Syngenta is working through the process with EPA and the states, all while communicating with its customer base. “Our recommendation is that PMPs stay in touch with their distributors, visit syngentapmp.com and communicate with our reps,” she said.
Woodstream — Woodstream’s Victor Multi-Kill is the company’s only single-feed second-generation rodenticide for professional use. Woodstream Sales Manager Mike Goldstein said the label is currently being reviewed by EPA and then will go through the state registration approval process. Goldstein added that Woodstream will not oversticker existing product, but make available new product with the updated label.
The Distributor’s Role
Distributors play a critical role when any pesticide label is amended, both in terms of making PMPs aware of what products are available and how to comply with the label directions when using these products.
Karl Kisner, director of marketing, Univar Environmental Sciences, said as soon as the company receives both a current label and MSDS for any newly amended rodenticide product, it will begin stocking and selling that product immediately.
Even after distributors begin receiving new label rodenticides from manufacturers they can continue to sell old label rodenticides, provided they still have them in inventory. “First and foremost, we are going to sell what the manufacturing and regulatory environment is asking us and looking for us to sell,” said Kisner. “If there is old label material available we are going to continue to sell it as long as the customer continues to ask for it. So, in this situation we’ll make the customer aware of his options and, as usual, let the customer make the ultimate decision.”
Kisner added that he does not anticipate a scenario in which PMPs stock up on old label materials, as sometimes is the case when pesticide labels change. “The reality is that PMPs have known about these changes and I think that a lot of them have planned appropriately,” he said.
Multiple generations of rodenticides. One of the challenges brought about by the RRMD and subsequent revision is that nearly every rodenticide product will be available in three different versions. In other words: (1) Labels prior to the June 2011 RRMD that DO NOT include items such as the 50-foot restriction; (2) products manufactured after the June 2011 RRMD with labels that DO include items such as the requirement to use the product within 50 feet of a building; and (3) labels that came out (or are soon coming out) after EPA made its March 2012 revisions that change the application restriction to 100 feet from a man-made structure. There are also three generations of use directions for application to rodent burrows.
It’s conceivable that PMPs could have all three generations of products in their arsenal, so it will be important for them to manage their stock wisely. For example, PMPs would be wise NOT to use old label products in situations where they don’t need to use old label products. It’s also important for them to know which label is on the product they are applying and use it in accordance with the label on that product. — Brad Harbison
PCT will be providing updates on this issue as they become available both in PCT and on our website, www.pctonline.com.
The author is Internet editor and managing editor of PCT and can be contacted at firstname.lastname@example.org.