(Beyond Pesticides, June 4, 2008) On May 29, 2008, the U.S. Environmental Protection Agency (EPA) released its final risk mitigation decision for ten rodenticides, which outlines new measures it says will help protect children and the public from accidental poisonings as well as to decrease exposures to pets and wildlife from rodent-control products. However, because the decision omits key uses, allows continued applicator use of dangerous formulations, and recognizes a lack of product efficacy without a fully integrated program (yet does not require it on the label), environmentalists feel the final risk mitigation decision falls short of adequately protecting the health of people, wildlife and the environment.EPA is requiring that ten rodenticides used in bait products marketed to consumers be enclosed in bait stations, making the pesticide inaccessible to children and pets, and is also prohibiting the sale of loose bait, such as pellets, for use in homes. These ten rodenticides are:
”¢ Zinc phosphide
Exposure to children is also a major concern for these chemicals. According to the 2006 Annual Report of the American Association Poison Control Centers’ National Poison Data System, over 40,000 cases of exposures to rodenticide products occurred in children six years and younger. Data also indicate that children in low-income families are disproportionately exposed. The EPA concedes that the number of exposure incidents resulting in symptomatic diagnoses and/or requiring treatment is unacceptably high.The EPA also believes that a major cause of the child exposure incidents is residential users’ failure to adequately comply with label directions which have required the application of rodenticide bait products in locations inaccessible to children. To reduce these risks, EPA is requiring that all rodenticide bait products available for sale to consumers be sold only in tamper-resistant bait stations. Loose bait, such as pellets, will be prohibited as a bait form for residential use.
Rodenticide products containing brodifacoum, bromadiolone, difethialone and difenacoum are known to pose the greatest risk to wildlife and will no longer be allowed to be sold or distributed in the consumer market. However, use by professional applicators will be permitted, and bait stations will be required for all outdoor, above-ground uses for products containing these ingredients. EPA says this will reduce the amount of product in the environment, providing additional protection for wildlife from poisonings by these more toxic and persistent products. However, many wildlife poisonings do not come from direct contact with the bait. These rodenticides have been involved with the poisonings of federally listed threatened and endangered species, for example the San Joaquin kit fox and Northern spotted owl. Rodents can feed on poisoned bait multiple times before death, and as a result their carcasses contain residues that may be many times the lethal dose. Poisonings occur when predators or scavengers feed on these poisoned rodents.
While these measures, taken to protect the residential consumer and children, are commendable, there are several shortcomings. Human and wildlife exposures to these toxic chemicals, though slightly minimized, would nevertheless continue because of their continued availability for use in agricultural production and to pest control operators. Pest control operators will still be allowed to use these chemicals in homes, at their discretion, which means residential exposures continue, albeit at slightly lower levels. These measures also do not apply to rodenticide field uses, or to tracking powder products, which may utilize any of the ten rodenticides, and thus continue to impact residential consumers and non-target wildlife.
EPA, to its credit, recognizes that the use of toxic chemicals to control rodents is itself not effective rodent management. Integrated Pest Management (IPM) practices are recommended by the EPA for rodent control in and around households. EPA advises that effective rodent control requires sanitation, rodent proofing, and removal of rodent harborage; habitat modification to make an area less attractive to rodents, and discourage new populations from recolonizing the area. Non-chemical devices such as snap traps and other trapping systems are also affordable and quite effective as a method for rodent control.
However, while EPA recognizes that IPM practices are safe and effective methods for controlling rodents, the dependency on the rodenticides as a means of control continues. Given that EPA acknowledges that effective rodent management will not be achieved without the adoption of safer IPM techniques, it is imperative that these practices are promoted to the consumer so that efforts can work toward the elimination of public and environmental exposures to low levels of toxic rodenticides. To do this, rodenticide labels must require the users to establish IPM practices and only allow the introduction of poisons as a part of this approach as a last resort.
Even as a last resort, millions of pounds of rodenticides will be applied to homes every year and measures to protect children from these household poisons have been long overdue. In 1998, new safety regulations- which required manufacturers to include two safety measures to protect children: an ingredient that makes the poison taste more bitter, and a dye that would make it more obvious when a child ingested the poison – were revoked in 2001 after the EPA announced that a “mutual agreement” was reached with the chemical manufacturers.
In response, the Natural Resources Council (NRDC) and the West Harlem Environmental Action (WE ACT) filed a lawsuit in 2004, challenging EPA’s regulations under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Administrative Procedure Act. In 2005, a New York City’s federal court ruled that the EPA failed to protect children from exposure to chemical rat poisons, and failed to require chemical manufacturers to strengthen safeguards. (See Daily News of August 17, 2005.)
Beyond Pesticides believes that IPM is a vital tool that aids in the rediscovery of non-toxic methods to control rodents and facilitates the transition toward a pesticide-free (and healthier) world. It offers the opportunity to eliminate or drastically reduce pesticide use and to minimize the toxicity of and exposure to any products that are used. Sanitation, structural repairs, mechanical and biological control, pest population monitoring are some IPM methods that can be undertaken to control rodents. For more information on IPM, contact Beyond Pesticides or visit our IPM program page.
For more information on EPA’s risk assessment of the ten rodenticides, visit http://www.epa.gov/pesticides/reregistration/rodenticides/finalriskdecision.htm. To learn more about rodenticides, visit Beyond Pesticides’ Rodenticides fact sheet. For least toxic control of mice and other pests visit the alternatives page.
For more background information on EPA’s regulatory decision and to view previous public comments, please visit www.regulation.gov and enter docket number EPA-HQ-OPP-2006-0955, or click on this link.
Source: U.S. EPA Mitigation Decision