Rodenticides at the Crossroads as PCOs Head to Capitol Hill

It’s been two-plus years since the U.S. Environmental Protection Agency (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.

The November 2022 PID was part of EPA’s reregistration of rodenticides. Under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), EPA is required to review registered pesticides every 15 years to ensure that — as the ability to assess risk evolves and as policies and practices change — the pesticides continue to meet the statutory standard of causing no unreasonable adverse effects on human health or the environment.

This PID built on earlier protections by proposing additional mitigation measures based on findings in the 2020 draft human health and ecological risk assessments (DRAs) and feedback submitted during the DRAs’ public comment period. These measures are intended to reduce exposure to non-target organisms such as mammals and birds that may inadvertently consume rodenticides through their prey, or animals that may consume the rodenticide directly.

Proposed measures included requiring bait to be placed in tamper-resistant bait boxes to ensure it is contained and requiring users to collect carcasses of rodents that may have consumed rodenticides to prevent further exposures to non-target organisms that could consume the carcasses.

In addition, the 2022 PID proposed that all products, excluding those registered solely for use by homeowners, include label language directing users to access the web-based Bulletins Live! Two, and follow the measures contained in any Endangered Species Protection Bulletin(s) for the area in which the user is applying the product.

EPA received more than 22,000 comments on the PIDs, and one year later (November 2023) EPA released its draft Biological Evaluation (BE) for the rodenticides and the draft Rodenticide Strategy.

In November 2024, EPA released the final BE for rodenticides. This document includes a few changes that Darr sees as positive from the perspective of the structural pest control industry:

• The mandatory carcass removal requirements for SGARs and zinc phosphate were downgraded. “What EPA noted in the final biological evaluation is that those mandatory carcass searches for SGARs and zinc phosphate are expected to be uncommon and seen as a last resort requirement when no other mitigation measures are available to the applicator,” Darr said.

• A previous proposal to limit bait station placement to within five feet of man-made structures in areas with endangered or threatened mammals was revised. Exemptions were granted for highly regulated facilities (e.g., food processing facilities), where this restriction could have hindered effective rodent control.

The new requirements, such as carcass removal and bait station placement restrictions, are expected to be implemented through changes to pesticide product labels, specifically through Bulletins Live 2.

The final BE heads to the Fish and Wildlife Service, which is assessing the proposed mitigations to determine if modifications are needed. “The Rodenticide Strategy is more or less in place right now, but they are continuing to iterate on it and build out the strategy this year or next,” said Darr.

EPA is expected to propose changes to the Restricted Use Pesticide (RUP) classification for rodenticides in early 2025. Discussions with stakeholders, including PMPs and state lead agencies, are ongoing, with a potential modification to the proposed classification being considered.

Darr added that a public comment period is expected for future proposals related to rodenticides, offering stakeholders a chance to provide input on proposed changes to the regulations.