"John Lublinkhof" <jlublinkhof@belllabs.com> 

02/07/2008 12:56 PM	

To

Kelly Sherman/DC/USEPA/US@EPA

cc

Subject

Rodenticide Mitigation

 



Dear Kelly,

Pete Martin and I much appreciated our meeting and discussion with you 

and the other EPA personnel present at the meeting. We are in the 

process  of completing a letter with attachments which will clarify some


of the points, especially market information, which required input from 

our sales/marketing group.

I reviewed the summary of our meeting which appeared in the docket.  

There are a couple of items I wish to clarify.  You indicated that our 

strategy is to have restricted use classification for brodifacoum. This 

is definitely not our preferred way. As discussed, we believe that 

brodifacoum should remain a general use product but be restricted by 

package size sales.  i.e. not allowed to be sold below a predetermined 

size(eg. 10 lb.)so that it is kept out of the hands of retail consumers.

Also, when we spoke about reducing the amount of active ingredient per 

bait placement, we referred to brodifacoum since it has been used 

successfully in Canada at 25 ppm and in the Island Conservation projects


at 25 ppm. Additionally, we have laboratory data supporting the 25 ppm 

dose. New Zealand is successfully using brodifacoum at 20 ppm.

Please contact me if you have any questions.

Best regards,

John Lublinkhof, Ph.D.

Director of Regulatory Affairs

Bell Laboratories, Inc.

608-241-0202 Ext. 3138

