RRodenticide Registrants Task Force (RRTF) and EPA Meeting

January February 4th, 2008/10:30 am to 12 pm

South Potomac Yard, 9th Floor

Attendees

Lynn Bergeson, Bergeson and Campbell, P.C.

Eileen Moyer, Reckitt Benckiser

David Fischer, Bergeson and Campbell, P.C.

Larry Culleen, Arnold and Porter (for Reckitt Benckiser)

Meredith Laws, EPA/OPP/Registration Division

Bill Jacobs, EPA/OPP/Registration Division

Dan Peacock, EPA/OPP/Registration Division

John Hebert, EPA/OPP/Registration Division

Steve Bradbury, EPA/OPP/Director, Special Review and Reregistration
Division

Susan Lewis, EPA/OPP/Special Review and Reregistration Division

Kelly Sherman, EPA/OPP/Special Review and Reregistration Division

Jennifer Howenstine, EPA/OPP/Special Review and Reregistration Division

Scott Garrison, EPA/Office of General Council

Via Speaker Phone

Jim Aidala, Bergeson and Campbell, P.C. 

El Ray Roper, Syngenta Crop Protection, Inc.

Tom Parshley, Syngenta Crop Protection, Inc.

Tom Schmit, Liphatech

Steven R. Spaulding, Central Life Sciences-Wellmark International

Summary of Meeting

	This meeting was requested by the Rodenticide Registrants Task Force to
discuss the information the RRTF submitted to EPA on January 25, 2008. 
This information (available in the docket at
EPA-HQ-OPP-2006-0955-0719)-xxxx) included the following:

data documenting the extent of rodent infestation in the United States;

scientific literature on resistance;

information about behavioral patterns of house mice;

draft consumer label;

draft label for use in and adjacent to agricultural buildings; and

proposed performance-based standard for rodenticide bait product
packaging.

The proposed labels were not formally submitted to the Agency as label
amendment requests.  The labels were provided as an example of how the
RRTF believes that rodenticide labels should be revised to decrease
secondary exposures to non-target wildlife.  These changes include
adding precautionary language, use limitations, and warnings to raise
awareness about the potential risks.  The RRTF also proposed reducing
the amount of bait in each bait placement and also labeling all
residential use products intended for “over-the-counter” sale as
indoor-use-only. 

 

	The RRTF used the resistance data to argue that homeowners need access
to second-generation anticoagulant rodenticide baits because of their
ability to kill in a  single night’s feeding, and that
first-generation products would not provide sufficient control.  

The RRTF discussed market research (focus groups or attitude and usage
studies) as a possible metric for evaluating the effectiveness of new
labeling in changing consumer behavior in such a way as to minimize the
effects on using rodenticides on non-target wildlife.

During the meeting, EPA outlined its current thinking regarding bait
stations for products sold “over the counter.”  EPA also reiterated
its interest in proposals for research or monitoring that would measure
the success of mitigation measures in reducing secondary wildlife
exposure to rodenticides.  

	

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