Posts tagged ‘risk mitigation decision’

November 1, 2011

A Simple Change for Pest Control Professionals

by jteaton

“Change is inevitable” as the quote goes, but in the Pest Control industry adapting to the changes that are caused by new laws and label changes seems to be a slower process for some.

Examples of recent changes: the limitations and required documentation to use Fumitoxin (and its 100 ft. rule) and the Risk Mitigation Decision which limits your baiting programs to within 50 feet of a structure.  Both are drastic changes that have greatly affected our industry.

Creating change in your company should be a step-by-step process and be easy to duplicate.   Manufacturers’ labels change all the time; having a current label and MSDS sheet and creating a fast and simple process to keep your label books current is one of the first steps to a successful program.  Other ways to learn more about upcoming changes and keeping in compliance are;

  •  Attending Pest Control Industry-related meetings and join AZPPO; this is how Manufacturers get out their information quickly.
  •  Subscribe to Industry-related email, newsletters, blogs and pest control magazines.
  •  When purchasing products, or when seeing your distributors, ask them about any changes that may be coming.
  •  Mark your calendar to dedicate several days (or more) for training. Rain-days, in-house training or last day of the month training work well.
  •  Schedule visits with your distributors or manufacturers’ representatives to ask “what’s new” and are there “any changes” is as simple as an email or phone call these days.

Knowing what alternatives are available when a product becomes too restrictive to use (or when one is banned from use altogether) will keep your company flowing with uninterrupted business.   The step-by-step process always starts off the same: knowing what you’re up against, keeping informed, implementing change, and making sure you meet or exceed all legal requirements.

James Rodriguez
Territory Manager, J.T. Eaton
Direct (818) 640-4587

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May 20, 2011

EPA 50 Foot Rule

by jteaton

With Risk Mitigation protocol descending upon us, changing our baiting application to less than 50 feet away from the structure will be the “new” baiting procedure.
Having an action plan in place to begin the conversion, and being aware of the various trapping stations, can save you money and may fit into your current program to maintain and service your accounts.

Devices to consider for Rats:

Hard Plastic Bait Stations
• J.T. Eaton #903TP Rat Fortress™: Holds 2 mouse glue boards or 2 Jawz™ rat size snap traps (item 410B)

Trapping Stations
• J.T. Eaton #401STS Snap Trap Station: Made of metal and can hold 2 wood snap traps or 2 Jawz™ rat size snap traps

Disposable Stations
• J.T. Eaton #901 Safe-Tee™ Plastic Bait Station: Thin plastic station made to hold a J.T. Eaton #177 glue board and fits a single Jawz™ rat size snap trap.

Increasing the frequency of visits when trapping more than 50 feet away from a structure will increase your cost, so start considering pricing adjustments, and plan on notifying your customers of this change soon.

James Rodriguez
Territory Manager
J.T. Eaton Co., Inc
(818) 640-4587

May 20, 2011

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