Municipal Services
Convention centers, sewage treatment plants, parks, landfills, subways, public spaces
Below is a summary of the EPA’s proposed mitigation measures that would affect this sector.
For more details, read the EPA’s Proposed Interim Decisions (PIDs) and Supporting Documents.
| Acute Compounds | First Generation Anticoagulants (FGARs) | Second Generation Anticoagulants (SGARs) | |||||||||||
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EPA Proposed Mitigation Category |
EPA Proposed Mitigation |
Definition |
Additional Information |
Zinc Phosphide (Case No. 0026) |
Bromethalin (Case No. 2765) |
Cholecalciferol (Case No. 7600) |
Chlorophacinone (Case No. 2100) |
Diphacinone (Case No. 2205) |
Warfarin (Case No. 0011) |
Brodifacoum (Case No. 2755) |
Bromadiolone (Case No. 2760) |
Difethialone (Case No. 7603) |
Difenacoum (Case No. 7630) |
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Restricted Use Pesticide (RUP) Classification |
RUP classification for all FGAR, SGAR, Bromethalin, and Cholecalciferol products sold in packages ≥ 4lbs. All Zinc Phosphide products classified RUP |
All commercial/professional structural products become Restricted Use Pesticides (RUPs). Cancellation of all General Use Pesticides (GUPs) for control of field pests, except for bromethalin worms for moles |
RUP classification regardless of bait type |
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Personal Protective Equipment (PPE) – Respirator |
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 |
Applicator requirement to wear a respirator for loose bait formulations |
Most tracking powders have respirator requirement currently. New requirement for loose formulations |
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Personal Protective Equipment (PPE) – Gloves |
Chemical-resistant gloves required for applications of products that are meal baits, tracking powders, grain meals, and waxy/paraffinized or non-paraffinized pellets
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Chemical-resistant glove requirement |
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). |
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Mandatory or advisory statements regarding post-application follow-up |
Mandatory statements for post-application follow-up: 1) carcass search, collection, and disposal, 2) spilled/ kick 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
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For field rodent and non-structural use site applications, mandatory carcass searches and reporting requirement. For all other professional use applications, carcass search will be advisory |
Structural use site applications will not require carcass searches or reporting of dead/dying non-target animals |
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Application Method Prohibitions |
Prohibition of spot- and broadcast- applications to turf, lawns, parks, golf courses, campsites, and other recreation areas |
Cancellation of surface applications of FGARs and zinc phosphide on turf, lawns, recreation areas, other public sites |
All applications to control burrowing rats (within 100 ft of a structure), moles, and field rodents, must be in tamper-resistant bait stations within those particular use sites |
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