EPA’s Office of Pesticides is reviewing the allowable uses of one of the most important class of pesticides used to control rodent pests, anticoagulant rodenticides. These rodenticides are critically crucial for controlling mice and rats around layer houses to protect egg safety under FDA rules.

EPA pesticide reviews are required approximately every five years under federal law to evaluate the latest science and determine if, when and how a pesticide gets used. EPA has not publicly announced its intent regarding a change in how it classifies rodenticides. Still, EPA and some in the science community are concerned about overuse, leading to avoidable deaths of wildlife predators and scavengers that feed on rodents poisoned with anticoagulants.

Private conversations indicate that these concerns have led EPA to intend to make the anticoagulants “Restricted Use” products under the law. This means that every application of these rodenticides would have to be logged in a written or electronic record kept for three years, the products could only be applied by a “certified pesticide applicator” or someone under their direct supervision and the products could only be purchased by a certified applicator.

As part of its decision-making process, EPA has released a series of questions about how rodenticides are used and managed in agricultural operations.  Answers to these questions are due on February 4. UEP is working with the Environment and Sustainability Committee and others in agriculture to submit informed comments in response to EPA’s request.  EPA is expected in March 2022 to issue for formal comment a Proposed Interim Decision (PID) on the allowable uses of the anticoagulants. UEP will also be commenting on that PID. Please contact Tom Hebert (tom.hebert@bayardridge.com) if you or members of your rodent control team can assist with answers to the questions that EPA has posted about the use of anticoagulants