EPA Proposed Changes
The Agency has evaluated the risk to people, pets, and wildlife from the currently allowed uses as explained in the EPA’s Draft Risk Assessments and to endangered species and their critical habitats in the Final Biological Evaluation (BE), released on November 21, 2024.
They have identified a number of changes to rodenticide products, including canceling products and uses, adding requirements, and reclassifying some products to Restricted Use Pesticides, which can only be distributed, sold, and applied by those who are licensed under programs administered by the States.
The proposed changes are described in the 2022 Proposed Interim Decision (PID) documents for the Anticoagulant Rodenticides (chlorophacinone, diphacinone, warfarin, brodifacoum, bromadiolone, difenacoum, and difethialone), the Acute Rodenticides (bromethalin and cholecalciferol), and zinc phosphide, and in the Final Biological Evaluation, which contains the Rodenticide Strategy.
To settle litigation over compliance with the Endangered Species Act (Center for Biological Diversity (CBD) v. United States Environmental Protection Agency), EPA committed to comply with its obligations under the Endangered Species Act (ESA) by completing draft and final Biological Evaluations for the four rodenticides subject to the litigation (brodifacoum, bromadiolone, warfarin, and zinc phosphide). It also agreed to develop a Rodenticide Strategy of mitigation measures for ESA-listed species that could be affected by the use of any of the rodenticides.
The BE contains mitigation measures that are the Rodenticide Strategy. As the Agency’s Strategy document for the rodenticides, it will set the policy for how the Agency regulates rodenticides into the foreseeable future. Now that the Rodenticide Strategy is finalized, mitigation measures will be implemented through 1) label changes in the Interim Decision; and 2) geographically-specific and species-specific mitigations in Pesticide Use Limitation Areas (PULAs) on EPA’s Bulletins Live Two! website. The U.S. Fish and Wildlife Service will use the information in the BE during the formal Endangered Species Act consultation with EPA, which will result in a Biological Opinion.
After consideration of public comments received on the PIDs in 2023, the EPA plans to re-issue new PIDs with revised proposed mitigation measures for public comment in 2025. Following consideration of the new public comments, EPA will publish an Interim Decision (ID) for each rodenticide or group of rodenticides, which finalizes any risk mitigation measures they decide to require. Check EPA’s Registration Review Schedule for current information by entering the name of a rodenticide in the search box on the right side above the table.
Below are lists of the mitigation measures EPA has proposed in each PID.
Final Biological Evaluation:
The three PIDs from 2022 are summarized below:
First Generation Anticoagulants
Chlorophacinone, Diphacinone, Warfarin
All commercial/professional structural products become Restricted Use Pesticides (RUPs).
Cancellation of all General Use Pesticides (GUPs) for control of field pests.
Prohibit use in cropped areas including orchards, groves, vineyards, and alfalfa. Above ground applications: 1) cannot be made directly to food or feed crops, 2) can only be made during the non-growth (dormant) period of the crop, and 3) must be made along fence lines, border areas, and buffer strips adjacent to the crops. Below ground applications: 1) must be made directly into the main run of the burrow, and 2) can only be made during the non-growth (dormant) period of the crop. One year harvest interval required for applications made to non-bearing crops.
Prohibit spot/scatter and broadcast applications to rangeland, pastureland, and fallow land.
Prohibition of spot- and broadcast- applications to turf, lawns, parks, golf courses, campsites, and other recreation areas.
APF10 (half-face elastomeric respirators), along with any fit testing, training, and medical evaluations will be required for application of meal baits, tracking powders, grain meals, and waxy/paraffinized or non-paraffinized pellets.
Chemical-resistant gloves required for applications of products that are meal baits, tracking powders, grain meals, and waxy/paraffinized or non-paraffinized pellets.
The PPE label requirement for gloves for all products would be changed to chemical-resistant gloves, generally with a thickness ≥ 14 mils (thicker than the current standard).
Mandatory statements for post-application follow-up:
1) carcass search, collection, and disposal, 2) spilled/kicked out bait disposal, and 3) dead/dying non-target animal reporting requirements for RUP products packaged in > 4 lbs. of bait used in fields and other non-structural use sites. For all other commercial/professional use applications, carcass search will be advisory.
Cancellation of reusable consumer bait stations (1lb or less) and refills. The only products available as General Use Pesticides (GUPs) will be ready-to-use prefilled disposable bait stations.
Second Generation Anticoagulants
Brodifacoum, Bromadiolone, Difenacoum, Difethialone
All commercial/professional structural products become Restricted Use Pesticides (RUPs).
APF10 (half-face elastomeric respirators), along with any fit testing, training, and medical evaluations will be required for application of meal baits, tracking powders, grain meals, and waxy/paraffinized or non-paraffinized pellets.
Chemical-resistant gloves required for applications of products that are meal baits, tracking powders, grain meals, and waxy/paraffinized or non-paraffinized pellets.
The PPE label requirement for gloves for all products would be changed to chemical-resistant gloves, generally with a thickness ≥ 14 mils (thicker than the current standard).
Advisory statements for post-application follow-up:
1) carcass search, collection, and disposal, 2) spilled/ kicked out bait disposal, and 3) dead/dying non-target animal reporting requirements for RUP products packaged in > 4 lbs. of bait used in structural use.
Bromethalin and Cholecalciferol
Cancellation of all General Use Pesticides (GUPs) for control of field pests, except for bromethalin worms for moles.
APF10 (half-face elastomeric respirators), along with any fit testing, training, and medical evaluations will be required for application of meal baits, tracking powders, grain meals, and waxy/paraffinized or non-paraffinized pellets.
Chemical-resistant gloves required for applications of products that are meal baits, tracking powders, grain meals, and waxy/paraffinized or non-paraffinized pellets.
The PPE label requirement for gloves for all products would be changed to chemical-resistant gloves, generally with a thickness ≥ 14 mils (thicker than the current standard).
Advisory statements for post-application follow-up:
1) carcass search, collection, and disposal, 2) spilled/ kicked out bait disposal, and 3) dead/dying non-target animal reporting requirements for RUP products packaged in > 4 lbs. of bait used in structural use sites and for products packaged in sizes < 1lb. bait labeled for consumer/residential use.
Cancellation of reusable consumer bait stations (1lb or less) and refills. The only products available as General Use Pesticides (GUPs) will be ready-to-use prefilled disposable bait stations and bromethalin gummy worms for mole control.
Zinc Phosphide
All products become Restricted Use Pesticides (RUPs).
Cancellation of all General Use Pesticides (GUPs) for control of field pests.
Prohibition of spot- and broadcast- applications to turf, lawns, parks, golf courses, campsites, and other recreation areas.
APF10 (half-face elastomeric respirators), along with any fit testing, training, and medical evaluations will be required for application of meal baits, tracking powders, grain meals, and waxy/paraffinized or non-paraffinized pellets.