EPA Denies Comment Extension Request for Rodenticide PIDs

Background

As previously reported by PCT, on Nov. 29 EPA announced its proposed interim decision (PID) on three first- generation anticoagulant rodenticides (FGARs), four second- generation anticoagulant rodenticides (SGARs) and four non-anticoagulant rodenticides, was announced on Nov. 29. (Strychnine was not part of the 2008 Risk Mitigation Decision but is now included as part of EPA’s registration review of the rodenticide group.) Significant outcomes of this decision included:

• RUP (restricted use permit) status for all anticoagulant rodenticides except first-generation anticoagulants that are packaged in containers less than 4 pounds. RUP classification restricts a product, or its uses, for use by a certified applicator or someone under the certified applicator’s direct supervision.
• PPE (respiratory and glove) recommendations that would be required on labels for certain formulations — specifically for tracking powder, for pelletized rodenticides and meal-based rodenticides.
• EPA did not make carcass removal a requirement, but instead said that rodenticide labels include an advisory carcass removal statement 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.”

Bell Labs Encourages PMPs to Take Action

Editor’s note: Rodenticide manufacturer Bell Laboratories issued the following statement encouraging PMPs to make their voices heard in regards to EPA’s Proposed Interim Decisions (PIDs) on rodenticides.

EPA issued a PID (Proposed Interim Decision) for rodenticides at the end of November, which is a general notice of their intention to make major adjustments to all registered rodenticides. There are ten separate dockets, one for each rodenticide active ingredient, which include lengthy proposed changes regarding application and availability of what is currently commonly available professional use rodenticides.

While these proposed changes will require pest management professionals (PMPs) to alter how they purchase rodenticides and service their rodent accounts, perhaps the largest overall impact to the pest control business will be on the labor force itself. Recruiting technicians is a critical challenge our industry faces and will only become more prominent. Additional expensive training, frustrating service regulations, along with requiring almost every applicator to be licensed, will make these jobs even less desirable for entry level workers. Do not underestimate how difficult it will be to hire and retain new employees due to these restrictions. The most significant changes on how this decision will impact PMPs are listed below:

1. All Rodenticides will become Restricted Use Pesticides (RUPs). This means licenses to apply bait will be mandatory and will require anyone purchasing or applying rodenticide to be a certified applicator OR be working under the supervision of a certified applicator.

2. Rules will vary state by state. Some states require supervising certified applicators to be available by phone when PMPs are applying bait, while others require them to be onsite within visual contact of the applicator. States that require licenses to apply RUP rodenticides will severely restrict the entry level labor market for PMPs.

3. Distributors will need to do reporting (confirm licenses and communicate back to the state) for each and every sale of rodenticide, by applicator.

 

 

The above changes will add great expense to the any pest control company conducting rodent control. There are other costly restrictions that the EPA is suggesting for PMPs, including multiple post application carcass checks, fitted respirators for applying pellets and other loose bait, as well as thicker gloves for technicians. Professionals must also be aware of the less obvious costs that will occur. One unintended consequence will be that insurance costs will rise, due to more exposure to fines and misuse, both civil and criminal, because of the nature of restrictive use products. Recruiting labor is difficult and is already expensive work. With the additional training requirements, the amount of time and money that is needed to get a technician fully licensed grows, and so will the employee sunk costs, if the technician decides to leave.  Costs for rodent control will expand exponentially if rodenticides become RUPs for professionals. Why further regulate PMPs who are already the most educated on how best to use these necessary tools, when homeowners will be able to continue buying rodenticides at retail stores?

These changes will impact every facet of rodent control. As an industry, we know how critical it is to protect the public health from disease and destruction caused by pests such as rodents, and these restrictions will simply cause more rodents, more disease, and more death. 

We need as many voices as possible to create the largest impact. Please tell the EPA that these restrictions are bad for public health and bad for business. Join us in taking action right now by going to www.protectthepublichealth.com, to quickly submit letters to the EPA, as well as your federal Senators and Representatives. The deadline for comments is Feb. 13, 2022. The very last thing our homes, businesses, food production facilities, schools, hospitals and restaurants need are extensive obstacles to eliminate rodents.