	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

	WASHINGTON, D.C.  20460

                                                                        
                 

									          August 3, 2005

OFFICE OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES

MEMORANDUM										

SUBJECT:	Response to Comments from Stakeholders on Analysis of
Rodenticide Bait Use

FROM:	Angel A. Chiri, Entomologist			

Biological Analysis Branch

THRU:	Arnet Jones, Chief

Biological Analysis Branch

TO:		Kelly White, Chemical Review Manager

		Laura Parsons, Team Leader

Reregistration Branch I

Special Review and Reregistration Division 

PRP Date:	06/19/05

Introduction 

The Agency received comments from numerous sources on its Analysis of
Rodenticide Bait Use posted in EPA’s EDOKET on September 02, 2004. 
Many stakeholders provide useful critique and/or data that could be used
in the preparation of a benefits assessment of rodenticide bait use. 
Some of the comments, while not specifically addressing the Rodenticide
Bait Use document, discuss the benefits of rodenticide bait use in
rodent control.  Numerous letters from pest control operators (PCOs),
growers, and other stakeholders encourage the Agency to retain the uses
of rodenticide baits, but do not provide data that can be used in the
preparation of a benefit assessment.  General comments and testimonials
that did not contribute specific rodenticide bait use information are
addressed as a group (see 1. below).

1.  General Comments and Testimonials

Comment: Over one hundred stakeholders (Docket number #OPP-2004-0033,
response numbers #0023-0038, #0040-0054, #0056, #0058, #0060-0078,
#0080-0090, #0093-0098, #0100-0103, #0107-0116, #0118, #0119-0120,
#0122, #0125-0129, #0131-0133, #0138-0140, #0142, #0144-0148, #0152, and
#0159) submitted short testimonials highlighting the value of
rodenticides for controlling rodents that affect humans, their
structures, and crops.  These stakeholders urge the Agency to
realistically consider the many benefits of rodenticide baits when
considering mitigation measures.  While the vast majority of these
generic comments were filed by pest control professionals, a few were
contributed by rodenticide manufacturers, growers, and private citizens.
 Most of these comments provided limited information on types of
products used and species of rodents controlled.                

Response:  The Agency does weigh the risks and benefits of pesticides
when considering any potential regulatory action that may affect its
use.  As a first step in this process, the Agency posted its Analysis of
Rodenticide Use Baits in EPA’s EDOCKET, along with the ecological risk
assessment.  This bait use analysis document describes in some detail
the various ways in which rodents may endanger humans and damage their
crops and belongings.  The document also discusses how the nine
rodenticides currently being reviewed by the Agency are used to manage
rodent pests.      

2.  Use Information and/or Critique Provided to the Agency

Comment: As requested by the Agency, information and comments on a wide
range of bait use issues were submitted by numerous stakeholders,
including: the Contra Costa Mosquito and Vector Control District
(OPP-2004-0033-0079), Schramm, Williams & Associates, Inc. in behalf of
the California Pistachio Commission (No. OPP-2004-0033-0100) and the
Fresh Carrot Advisory Board of California (No. OPP-2004-0033-0105), The
Central Oregon Hay Grower’s Association (OPP-2004-0033-0118), the San
Francisco Department  of the Environment (OPP-2004-0033-0123), the
California Department of Food and Agriculture (OPP-2004-0033-0136 and
-0137), the Animal Protection Institute  (OPP-2004-0033-0141), the
California Alfalfa and Forage Association (OPP-2004-0033-0143), Bill
Lowe, Organization of Kittitas County Timothy Hay Growers & Suppliers
(OPP-2004-0033-0151), the Virginia Polytechnic Institute, Defenders of
Wildlife, American Bird Conservancy, TEDX, Inc., Beyond
Pesticides/NCAMP, Northwest Coalition for Alternatives to Pesticides,
Californians for Alternatives to Toxics, and Rachel Carson Council, Inc.
(OPP-2004-0033-0155), the California Farm Bureau Federation
(OPP-2004-0033-0156), Global Environmental Options (OPP-2004-0033-0158),
Reckitt Benckiser Inc. (OPP-2004-0033-0160). 

 

Response: The Agency appreciates receiving the comments and information
provided by these stakeholders.  We will take them into consideration
when we refine the rodenticide bait use analysis.

3.  The Agency’s Benefits Assessment is Weak or Lacking   

Comment:  Several stakeholders, including Syngenta 
(OPP-2004-0033-0091), Ronald D. Grant D. V. M. on behalf of PM
Resources, Inc. (OPP-2004-0033-0101, OPP-2004-0033-0121), and HACCO,
Inc. (OPP-2004-0033-0124), remarked that an in-depth benefits assessment
for rodenticides was either deficient or lacking altogether.  Examples
of such comments are: “EPA’s benefits analysis does not fully
address the many public health, welfare, and economic benefits that
rodenticides make possible.” and “EPA’s summary of the benefits
offered by these nine rodenticides is entirely lacking and fails to
summarize accurately the enormous public health benefits offered by
these rodenticides.”  Some stakeholders provided suggestions on
specific rodenticide benefits that, in their view, an EPA benefit
assessment should address.   

Response: The Agency has not completed its benefits analysis for
rodenticide baits.  The summary of benefits found in the ecological risk
assessment document was not intended to be a benefits assessment. 
However, a related document, Analysis of Rodenticide Bait Use, posted in
the electronic docket along with the ecological risk assessment, does
discuss at some length the many benefits of rodenticide bait use, thus
addressing most of the benefits-related issues and concerns expressed by
these stakeholders.  As this analysis is refined, the benefits aspect of
rodenticide baits will be addressed in greater detail by the Agency.  If
any quantitative data on benefits was submitted by stakeholders, that
information will be taken into consideration in the refined document.   
  

4.  Integrated Pest Management (IPM)

Comment: the San Francisco Department of the Environment (Docket No.
OPP-2004-0033-0123) felt that the IPM approach to rodent control is not
discussed in sufficient detail and that non-chemical approaches are not
given the importance that they deserve in the Agency’s bait use
assessment.  According to this stakeholder, over-emphasizing chemical
control while downplaying IPM and non-chemical control alternatives is
an Agency policy shortcoming.  The Rodenticide Registrants Task Force
(RRTF) (Docket No. OPP-2004-0033-0157) and Reckitt Benckiser Inc.
(OPP-2004-0033-0160) question the accuracy and validity of  the
IPM-compatibility characterization for rodenticide baits that appears in
the use matrix (Table 1) of the bait use analysis.  

Response: EPA acknowledges that, under an IPM approach, pesticides
represent one of several measures available for managing pests in
general, including small mammals.  IPM and the numerous nonchemical
management techniques available to manage rodents were indeed discussed
in the use analysis document.  However, since this analysis attempted to
characterize the use of the nine rodenticide baits that are at present
undergoing review by EPA, rather than rodent management in general, the
emphasis of the analysis was on bait use.  As this analysis is refined,
these comments will be taken into consideration, and the discussion of
IPM and nonchemical approaches to rodent control will likely be
expanded.  As explained in page 32 of the use analysis, the IPM
characterization column was included in Table 1 to stimulate public
comments and further discussion.  At this time, the Agency has not made
any determinations regarding IPM compatibility issues for rodenticide
baits.  

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