Impact on Vertebrate IPM Practices from Impact on Vertebrate IPM Practices from EPAEPA’’s Rodenticide Risk Mitigation s Rodenticide Risk Mitigation

DecisionsDecisions

Victoria L. HornbakerVictoria L. HornbakerSenior Agricultural BiologistSenior Agricultural Biologist

California Department of Food and California Department of Food and AgricultureAgriculture

Rodent IPM ComponentsRodent IPM ComponentsControl methodsControl methods–– toxic baits (diphacinone, chlorophacinone, zinc toxic baits (diphacinone, chlorophacinone, zinc

phosphide only!) phosphide only!) –– fumigationfumigation

gas cartridges or aluminum phosphide gas cartridges or aluminum phosphide (phostoxin/fumatoxin) (phostoxin/fumatoxin)

–– trapping trapping –– shootingshooting–– culturalcultural–– predators predators

Baiting

Fumigation

Repellants

Trapping

Shooting

Environmental Modifications

Exclusion

Biological

AnticoagulantsAnticoagulants

A group of rodenticides which have the A group of rodenticides which have the same mode of action.same mode of action.Widely used for commensal rodent control.Widely used for commensal rodent control.Also used for the control of field rodents. Also used for the control of field rodents. Can be separated into two distinct groups:Can be separated into two distinct groups:–– first generation anticoagulantsfirst generation anticoagulants

(warfarin, chlorophacinone,(warfarin, chlorophacinone, diphacinone)diphacinone)–– second generation anticoagulantssecond generation anticoagulants

(brodifacoum, bromadiolone, difenacoum, (brodifacoum, bromadiolone, difenacoum, difethialone)difethialone)

Acute ToxicantsAcute ToxicantsAcrolein, Aluminum Phosphide, Gas Cartridges,& Acrolein, Aluminum Phosphide, Gas Cartridges,& StrychnineStrychnine -- Registered for controlling burrowing Registered for controlling burrowing rodents (i.e. California ground squirrels and pocket rodents (i.e. California ground squirrels and pocket gophers). gophers). AvitrolAvitrol®® -- Bird management chemical registered for Bird management chemical registered for blackbirds, cowbirds, starlings, grackles, house blackbirds, cowbirds, starlings, grackles, house sparrows, and feral pigeons as a flocksparrows, and feral pigeons as a flock--frightening frightening repellent. repellent. -- Zinc PhosphideZinc Phosphide -- Used on grain baits and bait Used on grain baits and bait blocks to successfully control meadow voles, pocket blocks to successfully control meadow voles, pocket gophers, ground squirrels, Norway rats, Polynesian gophers, ground squirrels, Norway rats, Polynesian rats, cotton rats, and nutria. rats, cotton rats, and nutria.

Dangers Associated with Dangers Associated with RodenticidesRodenticides

Children may have access to baits in Children may have access to baits in domestic settings.domestic settings.Potential primary and secondary risks to Potential primary and secondary risks to birds and nonbirds and non-- target mammals.target mammals.

Reregistration Reregistration

Rodenticides first regulated in 1947 under the Rodenticides first regulated in 1947 under the Federal Insecticide, Fungicide, Rodenticide Act Federal Insecticide, Fungicide, Rodenticide Act (FIFRA).(FIFRA).Reregistration was initiated for the Rodenticide Reregistration was initiated for the Rodenticide Cluster for pesticides registered prior to 1984.Cluster for pesticides registered prior to 1984.

üüWarfarin 1948 Warfarin 1948 üüDiphacinone 1960Diphacinone 1960üüChlorophacinone 1971Chlorophacinone 1971

üüBrodifacoum 1979Brodifacoum 1979üüBromadiolone 1980Bromadiolone 1980üüBromethalin 1984Bromethalin 1984

2007 Proposed Mitigation 2007 Proposed Mitigation Major ChangesMajor Changes

Make 2Make 2ndnd generation anticoagulants, including generation anticoagulants, including brodifacoum, bromadiolone, and difethialone brodifacoum, bromadiolone, and difethialone restricted use materials for use by certified restricted use materials for use by certified applicators.applicators.Formulation and package restrictions for 1Formulation and package restrictions for 1stst

generation anticoagulants (chlorophacinone, generation anticoagulants (chlorophacinone, diphacinone, and warfarin) and nondiphacinone, and warfarin) and non--anticoagulants anticoagulants (zinc phosphide, bromethalin, and cholecalciferol), (zinc phosphide, bromethalin, and cholecalciferol), available to homeowners.available to homeowners.

2008 Final Mitigation2008 Final Mitigation

““The risk mitigation decision described The risk mitigation decision described in this document does not apply to in this document does not apply to rodenticide field uses or to tracking rodenticide field uses or to tracking powder products. Risks associated with powder products. Risks associated with field uses and tracking powders were field uses and tracking powders were addressed in the 1998 Zinc Phosphide addressed in the 1998 Zinc Phosphide and Rodenticide Cluster Reregistration and Rodenticide Cluster Reregistration Eligibility Decision (RED) documents.Eligibility Decision (RED) documents.””

2008 Final Mitigation2008 Final MitigationActual ChangesActual Changes

22ndnd generation anticoagulants (brodifacoum, generation anticoagulants (brodifacoum, bromadiolone, difenacoum, and difethialone) not bromadiolone, difenacoum, and difethialone) not restricted use materials, however not available to restricted use materials, however not available to homeowners. homeowners. 11stst generation anticoagulants (chlorophacinone, generation anticoagulants (chlorophacinone, diphacinone, and warfarin) and nondiphacinone, and warfarin) and non--anticoagulants anticoagulants (zinc phosphide, bromethalin, and cholecalciferol) (zinc phosphide, bromethalin, and cholecalciferol) available to homeowners.available to homeowners.11stst generation anticoagulants field uses generation anticoagulants field uses -- Restricted Use!Restricted Use!

11stst Generation AnticoagulantsGeneration Anticoagulants

Field Uses will become restricted.Field Uses will become restricted.Consumer size Consumer size ≤≤ 1pound of bait above ground in 1pound of bait above ground in a bait stations.a bait stations.Underground baiting for moles and pocket Underground baiting for moles and pocket gophers exempt, can use grain or pellets for gophers exempt, can use grain or pellets for manual underground baiting.manual underground baiting.Agricultural use or professional applicators:Agricultural use or professional applicators:–– Does not have to be sold in a bait station, but Does not have to be sold in a bait station, but

label must require if children or nonlabel must require if children or non--target target animals have access.animals have access.

–– Any form of bait acceptable.Any form of bait acceptable.–– Must contain more than 4 pounds of product. Must contain more than 4 pounds of product.

22ndnd Generation AnticoagulantsGeneration Anticoagulants

Includes active ingredients: brodifacoum, bromadiolone, Includes active ingredients: brodifacoum, bromadiolone, difenacoum, and difethialone.difenacoum, and difethialone.

Not Federally Restricted.Not Federally Restricted.

No No ““HomeownerHomeowner”” uses.uses.

Sold in quantities greater than 8 lbs for ag use.Sold in quantities greater than 8 lbs for ag use.

For use in and around agricultural buildings in bait stations.For use in and around agricultural buildings in bait stations.

Sold in quantities greater than 16 lbs for professional use.Sold in quantities greater than 16 lbs for professional use.

For use by professional applicators (all uses except field use)For use by professional applicators (all uses except field use)

Acute ToxicantsAcute Toxicants

NonNon--anticoagulant rodenticides include: zinc phosphide, anticoagulant rodenticides include: zinc phosphide, bromethalin, and cholecalciferol.bromethalin, and cholecalciferol.Refer back to 1998 RED.Refer back to 1998 RED.Consumer size Consumer size ≤≤ 1pound of bait above ground in a bait 1pound of bait above ground in a bait stations.stations.Underground baiting for moles and pocket gophers Underground baiting for moles and pocket gophers exempt, can use grain or pellets for manual underground exempt, can use grain or pellets for manual underground baiting.baiting.Agricultural use or professional applicators:Agricultural use or professional applicators:–– Does not have to be sold in a bait station, but label Does not have to be sold in a bait station, but label

must require if children or nonmust require if children or non--target animals have target animals have access.access.

–– Any form of bait acceptable.Any form of bait acceptable.–– Must contain more than 4 pounds of product. Must contain more than 4 pounds of product.

Number of Products Number of Products Registered In CaliforniaRegistered In California

TotalTotal HomeHomeWarfarinWarfarin 1717 1010DiphacinoneDiphacinone 5454 3131ChlorophacinoneChlorophacinone 1717 1010

DifenacoumDifenacoum 11DifethialoneDifethialone 2525 2222BrodifacoumBrodifacoum 2323 2323BromadioloneBromadiolone 5454 5050

BromethalinBromethalin 3434 3030CholecalciferolCholecalciferol 66 66Zinc PhosphideZinc Phosphide 2727 77

2nd Generation Anticoagulant homeowner uses will no longer be available in California

2011 Products Available to 2011 Products Available to HomeownersHomeowners

Solid bait blocks, sold in packages containing 1lb of Solid bait blocks, sold in packages containing 1lb of bait, would be the only form of rodenticide bait bait, would be the only form of rodenticide bait approved for the consumer market (No 2approved for the consumer market (No 2ndnd Gen).Gen).

TamperTamper--resistant bait stations sold preresistant bait stations sold pre--loaded with loaded with bait blocks. bait blocks.

–– Refills can be packaged for sale with at least one preRefills can be packaged for sale with at least one pre--loaded bait station.loaded bait station.

–– Bait stations must meet one of four categories Bait stations must meet one of four categories of specificationsof specifications

Tiered Bait Station Requirements Tiered Bait Station Requirements for Consumerfor Consumer--Use ProductsUse Products

Tier 1Tier 1 –– TamperTamper--resistant for children and dogs; resistant for children and dogs; weather resistant; indoor and outdoor use; weather resistant; indoor and outdoor use; Tier 2Tier 2 –– TamperTamper--resistant for children and dogs; resistant for children and dogs; indoor use only; indoor use only; Tier 3Tier 3 –– TamperTamper--resistant for children; indoor use resistant for children; indoor use only; and, only; and, Tier 4Tier 4 –– SelfSelf--certification; packaging not reasonably certification; packaging not reasonably anticipated to release other than small quantities of anticipated to release other than small quantities of bait; resistant to opening by a child less than six bait; resistant to opening by a child less than six years old; indoor use only; nonyears old; indoor use only; non--refillable.refillable.

Impacts to Agriculture Impacts to Agriculture From 1998 REDFrom 1998 RED

Current field uses (e.g. in orchards and Current field uses (e.g. in orchards and rangelands) include products containing rangelands) include products containing chlorophacinone, diphacinone, and zinc chlorophacinone, diphacinone, and zinc phosphidephosphide22..–– Federal Restricted Materials.Federal Restricted Materials.–– Remove Remove ““commensalcommensal”” rodents.rodents.

22ndnd generation anticoagulants for nongeneration anticoagulants for non--field uses.field uses.–– However, above ground placements must be in a However, above ground placements must be in a

tampertamper--resistant bait station.resistant bait station.–– Within 50 feet of agricultural structureWithin 50 feet of agricultural structure

22Zinc phosphide is currently a Federal Restricted MaterialZinc phosphide is currently a Federal Restricted Material

What Does This All Mean?What Does This All Mean?

Pest Control Advisors need to know which Pest Control Advisors need to know which rodenticides can be used in each area.rodenticides can be used in each area.IPM programs will need to be adjusted due IPM programs will need to be adjusted due to removal of several species from the to removal of several species from the field use labels.field use labels.The grower must ensure that rodenticides The grower must ensure that rodenticides are being used per the revised labels. are being used per the revised labels.

Carefully read labels before handling, mixing, applying, storing, and disposing

of pesticides.

Using RodenticidesUsing Rodenticides

Reading a Reading a PesticidePesticide LabelLabel

1

1. Ingredients– by activity and weight.

The chemical name of the product as well as common name may also be included.

2. Directions for use

2

3. Signal word: Danger and Poison (a highly toxic substance), Danger (a substance a danger to health or an environmental hazard), Warning (moderate toxicity), Caution (low toxicity).

3Common rodenticides

• Aluminum phosphide (Danger and Poison)

• Strychnine (Danger and Poison)

• Anticoagulants (Caution)

• Smoke cartridge (Warning)

• Zinc Phosphide (Caution)

• Acrolein (Danger)

4. Storage and Disposal Directions

4

5. Precautionary Statements And First Aid

5

6. Statements of Use–

Pesticides are classified as general or restricted use.

6

Who Can Use Restricted Use Who Can Use Restricted Use PesticidesPesticides

40 CFR 171.7(b)(1)(iii)(D) FAC 40 CFR 171.7(b)(1)(iii)(D) FAC 14015. 14015. Except as provided by regulation adopted Except as provided by regulation adopted by the director, a restricted material shall by the director, a restricted material shall only be possessed or used by, or under only be possessed or used by, or under the direct supervision of, a private the direct supervision of, a private applicator, who is certified pursuant to applicator, who is certified pursuant to Section 14093, or a certified commercial Section 14093, or a certified commercial applicator, as defined by Section 6000 of applicator, as defined by Section 6000 of Title 3 of the California Code of Title 3 of the California Code of Regulations.Regulations.

CertificationCertification

All field use rodenticides will become All field use rodenticides will become restricted use.restricted use.Only certified applicators will have access Only certified applicators will have access to the restricted use products.to the restricted use products.Commercial production agricultural Commercial production agricultural properties generally have staff that are properties generally have staff that are certified.certified.Concern is for the smaller Concern is for the smaller ““RanchetteRanchette””properties.properties.

How Does a How Does a ““RanchetteRanchette”” Owner Owner Use Restricted Use Products? Use Restricted Use Products?

Take the private applicator exam.Take the private applicator exam.Certified to use any restricted use material.Certified to use any restricted use material.Use per the label directions.Use per the label directions.

*The problem is that many of the *The problem is that many of the ““RanchettesRanchettes””do not use any other products that are, or do not use any other products that are, or may become restricted. may become restricted.

““RanchetteRanchette””

Small Agricultural Property

ProductionAgriculture

What do We Propose?What do We Propose?

Create a Private Applicator exam Create a Private Applicator exam specifically for field use rodenticide specifically for field use rodenticide products. products. Use a Kiosk exam delivery system to Use a Kiosk exam delivery system to minimize impact to County staff.minimize impact to County staff.Allow Allow ““RanchetteRanchette”” owner/operators to owner/operators to become certified private applicators.become certified private applicators.

Where Can I go for More Information?

http://vpcrac.org/

http://www.ipm.ucdavis.edu/PMG/menu.vertebrate.html

Thank you!Thank you!