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

The PID documents and supplementary materials are comprised of hundreds of pages of dense technical/regulatory information. 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

Instructions for Submitting Comments:

To access the comment submission portal for the rodenticide you would like to comment on, please reference the table below and click the appropriate Docket ID #.

Class of Rodenticide: FGAR

Class of Rodenticide: SGAR

Class of Rodenticide: Non-Anticoagulant