EPA RMD Update

by jteaton

By now, most of us are familiar with the EPA’s Risk Mitigation Decision that was released in 2008. This post is to remind everyone that the deadline for bait changes is June 4. Before reminding everyone what that means, here is a recap of what the RMD entails for professionals and consumers. (This information is taken from the RMD publication. A link to the official document is below.)

Consumer Bait:
• Bait products must be sold with ready-to-use (one-time use or refillable) bait stations, except for products that are labeled solely for use outdoors, below-ground for control of moles and pocket gophers.
• Bait products may contain one or more of the following active ingredients: chlorophacinone, diphacinone, warfarin, bromethalin, cholecalciferol, and zinc phosphide.
• Meal, treated whole-grain, or pelleted forms of bait (whether packaged in placepacks or not) are prohibited, except for products that are labeled solely for use outdoors, below-ground for control of moles and pocket gophers.
• A retail package containing a bait station may contain up to a maximum of 1 pound of bait for either mouse or rat control (the 1 pound limit includes the initial bait placement inside the bait station, plus any bait refills).

Second Generation Bait:
• Second Generation bait for professional and agricultural use need not be sold in bait stations, but labels must require use of bait stations for indoor applications where children, domesticated animals, or non-target wildlife may be exposed.
• Product labels must require use of bait stations for all outdoor, aboveground placements.

Agricultural Use
• Any form of bait is acceptable, including meal, pelleted, and block forms.
• Product labels must state, “For use in and around agricultural buildings only. Do not apply further than 50 feet from agricultural buildings.”
• Product labels must state, “Do not use in homes or other human residences.”
• Products must contain at least 8 pounds of bait.

Professional Use
• Product labels must state “Do not apply further than 50 feet from buildings.”
• Bait stations used in residential and institutional settings must meet the standards set forth in Section V.C, below, for ability to isolate bait from children.
• Any form of bait except liquid is acceptable, including meal, pelleted, block, and paste forms.
• Products must contain at least 16 pounds of bait.

EPA believes that these size limits will effectively discourage residential users from obtaining second generation anticoagulants for their own use.

First Generation and Nonanticoagulant Bait:
• Other Bait for professional or agricultural use need not be sold in or with bait stations, but labels must require use of bait stations where children, domesticated animals, or non-target wildlife may be exposed (this is not a new requirement).
• Any form of bait is acceptable, including meal, pelleted, or block forms.
• Products must contain at least 4 pounds of bait.

**For products in packages with at least 8 but not more than 16 pounds of bait, labels must state that products may only be used in and around (within 50 feet) of agricultural buildings (e.g., barns, hen houses), and bear the statement “Do not use this product in homes or other human residences.”**

What does this mean? According to the EPA, June 4 is the last turning point for bait changes.
• Last day for voluntarily complying registrants to release into commerce a product not complying with the risk mitigation decision.
• Products requesting voluntarily cancellation have until this date to release into commerce.
• Existing stocks of non-compliant products released for shipment by the registrant on or before this date can be sold until stocks are exhausted.
• Non-conforming products released to retailers on or before June 4, 2011 may be sold until exhaustion.
• Products released to distributors or retailers post June 4, 2011 must include mitigation measures.

For more information and to view the complete RMD document, go to: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2006-0955-0764

Advertisements

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google+ photo

You are commenting using your Google+ account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: