Like a rapid response team, representatives of the pest control industry came together in October to successfully present its case for not restricting second-generation anticoagulant rodenticides (SGARs) in the state of New York.
A petition to make second-generation rodenticides restricted-use products had been filed earlier with New York's Department of Environmental Conservation (NYDEC) by a coalition of wildlife and conservation groups, concerned about accidental poisonings, particularly among wildlife, from second-generation rodenticides.
Alerted to the impending petition, an industry group - representing the National Pest Management Association (NPMA), the New York Pest Management Association, Bell Laboratories, Inc., Lipha Tech and Standard Pest Management - met in Albany, New York, in mid-October to present the industry's concerns about the potential ban to a panel of commissioners.
Besides addressing issues, such as the negative impact and unintended consequences when effective control measures are restricted, the group discussed the measures already in place from the 2008 "Risk Mitigation Decision" issued by the Environmental Protection Agency (EPA).
Those measures are designed to reduce exposure of SGARs to children and wildlife by, among other requirements, preventing or substantially limiting general consumer access to those products.
Risk Mitigation Measures
A follow-up letter to the Department of Environmental Conservation, supported by Bell's Research and Development Department under the direction of Peter Martin and sent from the NPMA and NYPMA, spelled out in greater detail, along with supportive data, the Risk Mitigation measures already in place and expected to take full effect by March 31, 2015.
Among measures directed at residential consumer rodenticide products, the letter pointed out, are:
Solid bait forms are required, and loose bait is prohibited.
SGARs are not permitted.
Bait sold in typical retail outlets need to be in packages of 1 lb. or less and must be sold with a bait station.
"We believe this development achieves NYDEC objectives to mitigate the broad availability of SGARs, but without limiting or restricting this important tool for the professional pest control industry," the letter stated.
"We also believe these changes will result in a lower incidence of wildlife exposures to these actives which can be monitored and documented over time," it concluded.
The effort paid off. On November 5, the NY Department of Environmental Conservation essentially agreed, taking a wait and see attitude, by denying the petition.
In their response to the petition request, the Department wrote, "Once the impacts of the 2008 Decision are fully realized, the Department should be in a better position to determine whether additional regulatory action on SGARs is necessary to prevent impacts to non-target species."
Industry response was one of relief as a similar request had been approved in California in July 2014, which now limits SGARs to use by licensed professionals in that state.
Bell's Western Regional Manager, Patrick Lynch, who participated in the October meeting, afterwards said, "Everyone who approached me at NPMA PestWorld thanked us for participating in the meeting and said how wonderful it was that we worked together and sent representatives to that meeting."
To that, Martin added, "The industry came together, and we provided the necessary supporting data. We have the mechanism to assess the impact of the Risk Mitigation Decision on children and pets but how do we assess the impact on wildlife? If there is less brodifacoum, for example, in the hands of consumers, what effect will that have on raptors? Now it's a matter of surveillance."