NPMA Urges PMPs To Protect Their Ability To Use Rodenticides

Editor's note: As a result of EPA's recent "ecological risk assesment" the Agency may consider limitations on the use of rodenticides. In response, the National Pest Management Association is urging PMPs to provide EPA with comments detailing the benefits of these products. NPMA issued the following release:

As many of you already know, the U.S. Environmental Protection Agency has been re-evaluating all of the rodenticides used by the pest management industry for a number of years. Most recently, they issued an "ecological risk assessment," which suggests that the use of these products may result in unacceptable risks to non-target species. The next likely step for EPA is to impose limitations on the use of these products.

NPMA does not believe that EPA’s ecological risk assessment is methodologically sound, nor do we believe it has adequately considered the public health and economic benefits associated with using these products.

You have the ability to influence the outcome of this decision by submitting comments to EPA’s docket, which will close on Friday, January 21. In particular, it is especially important for PCOs to talk about the benefits of using these products. We have made this as easy as possible. Just follow the instructions below:

How to Submit Comments
We recommend that you submit your comments electronically, by using EPA’s electronic docket or by sending EPA an e-mail

Using EPA’s Online Electronic Docket (E-Docket): EPA prefers to receive comments via its "e-docket," and the process is not difficult. To submit over the computer, go directly to the EPA Dockets website at http://www.epa.gov/edocket/, and select (click on) "Submit Comment." Next, you must key in "OPP-2004-0033" in the box provided and click "Search." Finally, you must click on the comment icon (it looks like a text bubble) pictured under "Submit Comment." You will be asked to read and agree to EPA’s Terms of Service before proceeding on to the comment screen. Once at the final comment screen, you may type your comments directly or attach a computer file. Click "Submit Comment" to complete the process. Though we recommend that you provide your name, your company’s name and the location of your business, this method is anonymous, and EPA will not know your identity, e-mail address, or other contact information, unless you provide it in the body of your comment. 

Using E-mail: To submit via e-mail (other than via EPA’s E-Docket website), please send your comments to opp-docket@epa.gov, with the subject heading "Attention: Docket ID number OPP-2004-0033." Please note that if you choose to send your comments via e-mail, your e-mail address will be publicly available when EPA adds your comments to the public docket.

What to Say
You are of course free to submit any comments that you believe are appropriate. To make it as quick and easy as possible, we have provided "model comments" below. You may simply copy these, insert the correct information in the bolded areas and copy it to your E-Docket or E-mail submission. The more detail you provide, however, the more valuable the comments.

Re: Docket ID number OPP-2004-0033

This is to express my concerns regarding EPA’s revised (July 2004) document, "Potential Risks of Nine Rodenticides to Birds and Nontarget Mammals: A Comparative Approach," which EPA describes as a comparative ecological risk assessment for the nine rodenticides the document covers. As a pest control operator (PCO) in [State], I rely on one or more of these rodenticides. I know that others will be commenting on whether EPA correctly determined the "risks" associated with the uses of the nine rodenticides, but I would like to be sure that EPA fully understands the benefits of these products and the potential problems that would occur if you impose "mitigation measures" that would severely limit their use.

As a PCO, I use [name of rodenticide(s)] to protect the public from the health and economic consequences associated with [type of rodent(s)]. If I did not have the option of using rodenticides, [describe the difficulties you would encounter in residential and/or commercial settings]. These products are a vitally important tool for protecting the public from the health and economic harm that result from rodent infestations. Therefore, I urge EPA to comply with its responsibility to realistically take into account the benefits of rodenticides, as well as any documented risks, in completing its ecological risk assessment.

Thank you for your consideration of these comments.

[Your Name]
[Your Company’s Name]
[Your Address]

More Background Information
You can access background information on this issue that we produced in conjunction with the rodenticide manufacturers by clicking here and logging on to the Members Only side. If you need additional information or would like to discuss this, contact Bob Rosenberg or Gene Harrington by phone at (800) 678-6722 or at rosenberg@pestworld.org or gharrington@pestworld.org.