Sample letter to the EPA: to reduce wildlife deaths from
secondary poisoning (eating poisoned rodents)
Office of Pesticide Programs (OPP) Regulatory Public Docket
(7502P), Environmental Protection Agency, 1200 Pennsylvania
Ave. NW., Washington, D.C. 20460-0001.
Attn: Kelly Sherman
Re: "Rodenticides; Proposed Risk Mitigation Decision; Notice of
Availability"docket number EPA-HQ-OPP-2006-0955
Dear EPA, OPP staff and directors,
Thank you for this opportunity to submit comments on the
critical issue of reducing the negative impact that 2nd generation
poisons have on our wildlife and children.
Thank you for requiring that all rodenticides be applied in solid
block form, and affixed within tamper resistant bait boxes to
reduce the 20,000 annual reported incidents of child poisoning
from eating rodent poison pellets, and reduce the poisoning of
birds that eat poison pellets, thinking it is food.
Thank you also for implementing programs that assist people in
low- income housing complexes identify and close rodent entries
into buildings, and identify and remove open food sources. More
of these programs are needed!
As reported in the EPA document open for public comment - the
only effective way to reduce rodent poison use is to remove open
food sources and rodent harborage. The loss of endangered species
and the multitude of other species documented in the EPA
document open for comment, from consuming rodents poisoned
with 2nd generation rodenticides necessitates that these poisons be
restricted to indoor use, and not be permitted to be used outdoors.
Killing bald eagles, peregrine falcons, endangered California kit
foxes, and all the other wildlife species that eat rodents or carrion,
for the sake of killing rodents just does not make sense, and must
not be allowed to continue. In light of the fact that poisoning
rodents outside, around open food sources, has been proven to be
ineffective in stopping rodents from congregating, the loss of these
species is even more iniquitous.
Pest Control Operators will continue to refill the poison bait boxes
they place next to nearly every garbage dumpster across our
country unless 2nd generation rodenticides are restricted to indoor
use. This practice results in our environment being littered with
poisoned rodent bodies – that are poisonous enough to kill the
animals that are natural predators of rodents.
Limiting wildlife exposure to only those rodents that are poisoned
indoors and die outdoors is the only way to significantly reduce
non-target wildlife deaths from secondary poisoning.
The EPA document available for comment gives only cursory
consideration to the proposed mitigation measure of limiting the
2nd generation rodenticides to indoor use. The document states that
this proposed measure is of no value because rodents that are
poisoned indoors may still die outdoors. This does not take into
consideration the fact that Pest Control Operators fill bait boxes
monthly around nearly every open food source across the country.
The EPA document states that 1st generation rodenticides are
effective for killing rodents, and that bait and switch (to non-toxic
blocks) prevents bait shyness and resistance build up. PCO’s use
2nd generation rodenticides simply because they are available.
It is clear that PCO’s do not expect rodenticides to stop rodent
congregation around dumpsters. They sign annual contracts to
refill bait boxes monthly, and renew these contracts annually.
While this practice is not likely to be discontinued, the use of 2nd
generation poisons that kill the animals that eat rodents and carrion
must not be allowed to continue.
Ideally these poisons should be placed on the severely restricted
poison compound list, limiting their use to government employees
and protection of national food storage and processing. However
limiting the 2nd generation rodenticides to indoor use will save
hundreds of thousands of lives nation wide annually.
Thank you sincerely for revisiting this mitigation measure to
protect wildlife, and doing all that is needed to implement this
measure.
Sincerely,
Name
Address