EPA737-N-94-OL1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SEP 161994
OFFICE OF.
PESTICIDES AND TOXIC
SUBSTANCES
Attention:
Subject:
PR Notice 94-7
NOTICE TO MANUFACTURERS, FORMULATORS
REGISTRANTS AND USERS OF PESTICIDES
Persons Responsible for Federal Registration of
Pesticides
Label Improvement Program for the Revision of Use
Directions for Commensal Rodenticides and Statement
of the Agency's Policies on the Use of Rodenticide
Bait Stations
This Notice requires registrants of certain pesticide
products claimed to control commensal rodents and registered
under the Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA) to revise the labeling of .such products to bear certain
statements concerning "tamper-resistant bait stations."
This Notice also informs rodenticide registrants, applicants,
and other interested persons of EPA's continued concern for the
safe use of rodenticides. This Notice outlines EPA's current
policies regarding the isolation of commensal rodenticides from
children, dogs, other pets, domestic animals, and nontarget
wildlife. For purposes of this Notice, product labels, and EPA's
policies, the term "commensal rodents" includes the following
species: Norway rats (Rattus norvegicus), roof rats (R. rattus),
and/or house mice (Mus musculus)~
To comply with this Notice, you must submit an application
for amended registration if you are a registrant of any of the
following types of products claimed to control commensal rodents:
1. ready-to-use solid bait formulations (e.g., pelleted,.
meal, paraffinized block, etc.);
2. liquid baits;
3. concentrates with labels bearing directions for
preparing and applying solid or liquid baits; and
Printed on Recycled Paper
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4. tracking powders- for'which, current labeling permits
use in -"tamper-proof bait boxes," other protective
structures, or other locations accessible to children
or nontarget animals.
Amended registration applications for such products must
include proposed amended labeling revised as indicated in this
Notice. Amendment applications are not required for products
for which current accepted labeling already includes the language
prescribed by this Notice.
Within 90 days of receipt of this Notice, all registrants
of products affected by this Notice must submit five (5) copies
of revised labeling for each affected product. The new labeling
requirements for baits and concentrates from which users prepare
baits are listed under the heading "Required Label Statements"
on pages 9 and 10 of this Notice. The types of label statements
that must be deleted from labels for tracking powders are
discussed on page 10 of this Notice. Any registrant who_wishes
to modify the labeling statements prescribed by this Notice
must include with the application for an amended registration a
statement of each specific modification sought and the reasons
why each modification is believed to be justified. Alternative
text will not be accepted if EPA determines that it is not
consistent with the intent of this Notice. All affected products
released for shipment after March 16, 1996, must bear labeling in
compliance with this Notice. ''
Background:
In PR Notice 83-5, EPA summarized its historical policy.
regarding the use of bait stations to isolate rodenticide baits
from nontarget animals. Part of this policy has been to require
that baits registered to control commensal rats and mice bear on
their labels a statement such as:
"Treated baits should be placed in locations not
accessible to children, pets, wildlife and domestic
animals, or in tamper-proof bait boxes."
PR Notice 83-5 listed the reasons for requiring this type
of label language and the eight "Proposed Criteria" which the
Agency had developed for "tamper-proof bait boxes". PR Notice
83-5 also listed five commercially marketed bait stations that
were believed at that time to provide adequate protection for
applications made in environmentally sensitive areas.
PR Notice 83-5 was issued because EPA had become aware that
bait protection practices directed by labels usually were not
being followed. Persons using rodent baits in areas where non-
target exposures might occur typically were protecting baits
inadequately or not at all.
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In PR Notice 83-5, the Agency also announced its plans
to hold public hearings. In a Federal Register Notice (43 FR,
48711), EPA stated that the purpose of the hearings would be to
obtain information in four areas:
"1. Practices and problems with the use of bait
stations.
2. Attitudes regarding EPA's "Proposed Criteria"
for tamper-proof bait boxes, including any
suggested changes in the criteria, terminology,
and/or rodenticide label language pertaining
to bait stations.
3. Ideas for developing standards and test
protocols through existing standards-setting
institutions. ' . ,
4. Accidents, illnesses, deaths, or nontarget
exposures resulting from the use of commensal
roden-ticides. "
Two sessions of public hearings were held: the first on
November 4, 1983, in. Arlington, VA; and the second on March 5,
1984, in Sacramento, CA. Participants represented commercial
pest control interests, rodenticide manufacturers, bait station
manufacturers, research institutions, and various government
agencies.
Since circulation of PR Notice 83-5, EPA has received and
answered more than 300 letters pertaining to the Notice and the
use of bait stations. EPA also has sought additional information
on these topics. Relevant information received by the Agency '
through these letters, the public hearings, and other sources, is
summarized in the report "Rodenticide Bait Stations" by William
W. Jacobs. This report is available upon request. The Agency's
major findings are summarized by topic below.
Rodenticide-Caused Accidents and Illnesses
Historically, more than 1000 incidents of human exposure to
rodent poisons have been reported annually in the U.S. Numbers
of human incidents reported have increased greatly in recent
years with the advent of a new reporting network. In 1988, more
than 10,000, rodenticide incidents were reported in the American
Association of Poison Control Center's National Data Collection
System. Nearly 90% of these cases involved children under six
years of age. Nearly all of such exposures are classed as
accidents. The human exposure incidents that are reported may
represent less than half of those which occur. Well over 80%
of reported human rodenticide exposures involve anticoagulant
compounds. ' .
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Young children thought to have been exposed to rodenticides
are often given some medical attention, although symptoms of
poisoning usually are not observed, especially in cases involving
anticoagulants which act very slowly. Although young children
have been killed by rodenticides, most rodenticide-related deaths
of humans result from intentional ingestions by persons much
older than five years of age.
Dog incidents account for more than 80% of the reported
exposures of nontarget animals to commensal rodenticides. Most
dog exposures are believed to be accidental. The annual number
of incidents of animals being exposed to rodenticides is not
known, but over 4,000 rodenticide-related inquiries were made
to the Illinois Animal Poison Information Center in each of the
years from 1986 to 1988, with a high of 6,272 inquiries having
been made in 1987 '.
'Symptoms of rodenticide poisoning are detected more
frequently in reported animal cases than in child cases. A
larger percentage of asymptomatic exposures of animals may go
undetected as pets and livestock generally are not watched as
closely as children. Dogs may die as a result of rodenticide
exposures, especially if acute poisons are involved. Extended
Vitamin K1 therapy may be needed for dogs that have been exposed
to certa'in anticoagulants, such as brodifacoum or diphacinone,
which are retained in the body for a relatively long time. For
animal exposures reported in 1987 (and probably in other years
as well), the animal's owner typically was the source of the
rodenticide. Most of these exposures were accidental and
occurred in or around human residences.
While reports summarizing incidents typically do not
indicate exactly how exposures have occurred, it is likely
that most accidents are related to improper use rather than to
improper storage. Accidents of both types are preventable. EPA
believes that the la-rge numbers of exposure incidents provide
evidence that current policies for promoting bait protection have
not been sufficient and, therefore, that tougher, more explicit
policies are needed. EPA has not been persuaded by contentions
that the relatively low incidences of serious human illnesses
caused by accidental exposures to compounds such as warfarin
justify selective relaxations of requirements for bait protection.
Warfarin has been implicated in many human and animal exposure
incidents and was one of the rodenticides considered when the
"tamper-proof bait boxes" statement originally was developed.
The Reregistration Eligibility Document (RED) issued for
warfarin on June 6, 1991, requires that the bait protection text
prescribed in this Notice be added to the labels for warfarin
ready-to-use baits and concentrates with labels which include
bait mixing and application directions, and that labels for
warfarin tracking powders be amended as prescribed in this Notice
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Practices and Problems with Use of Bait Stations
The major problem identified in this area was generally
inadequate protection of baits applied in areas accessible to
children or nontarget animals. According to available infor-
mation, pest control operators traditionally used stations of
the sorts which PR Notice 83-5 described as "inadequate." These
include weak stations made of cardboard or thin plastic, and
sturdier stations which do not inhibit spillage or reach-in
access to baits.
N
Nonprofessional users (i.e., the "general public") often
apply baits in open containers or in ready-to-use, non--protective,
packaging. Bait stations typically are not offered for sale
at the outlets where nonprofessional users buy rodenticides.
Attempts to market ready-to-use (bait-filled) protective
rodenticide bait stations to the general public have not been
reported as commercially successful ventures. Ready-to-use bait
stations that have been tested generally have been found not to
be completely "tamper-resistant". Improvements to such units
probably would add to their retail prices and put them at further
competitive disadvantages relative to baits sold "loose," in
cardboard boxes, or in plastic placepacks.
The rodenticide brand names mentioned in the incidents
reported-prior to 1983 (summarized by the National Clearinghouse.-
for Poison Control Centers) and the "source" information from
reports of animal incidents suggest that private users have
accounted for most of the nontarget exposure incidents involving
rodenticides. Available data do not indicate whether this trend
reflects an effect other than a greater likelihood for non-
professional users to apply rodenticide baits in areas where .
incidents are most likely to occur and to be reported.
. Bait protection requirements are the same for similar
products, whether they are marketed to professional users or to
the general public. However, professional applicators are more
easily reached by EP'A's policy statements than are nonprofessional
users. Many pest control firms have contacted EPA directly. Many
more have been reached through professional publ ications. and
associations. Some firms have improved their bait protection
practices in response to PR Notice 83-5. If the numbers of
rodenticide exposure incidents occurring are to be minimized,
however, all users of rodenticides must protect baits adequately.
Several, hearing participants suggested approaches for
insuring better bait protection by nonprofessional users. Many
of these involved reclassification of products and/or special
packaging requirements. EPA might pursue these options for
some rodenticide compounds. As such actions could not be taken
rapidly, there is need for more immediate action.. This Notice'
requires label changes designed to draw, attention to. bait
protection statements and to clarify users' responsibilities.
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Criteria, Labeling, and Terminology
This Notice directs that the term "tamper-proof" be replaced
on rodenticide labels by "tamper-resistant". This change was
requested by most who contacted the Agency on matters relating to
bait stations. The most persuasive argument on this'issue was
that "tamper-proof" implies absolute bait protection, performance
beyond that which could be guaranteed even if units meeting all
of EPA's "proposed criteria" were used. "Tamper-proof" also
was thought to put applicators on very tenuous legal grounds
in instances in which nontarget exposures might occur, due to
unusual and unpredictable events beyond the applicator's control,
despite use of the best practical efforts to protect baits. EPA
recognizes that this change results in substitution of a broader
term for the virtually self-defining "tamper-proof." Accordingly;
EPA has expanded the required label text pertaining to bait
protection and the criteria for "tamper-resistant" bait stations.
In response to concerns of hearing participants, the
expression "not accessible" (or "inaccessible") has been replaced
by wording which informs the user of the degree of bait protection
needed.
For complete text of new bait station label language, see
"Required Label Statements for Commensal Rodenticide Baits" on
pages 9 and 10 of this Notice.
EPA concurs-with those who stated that the Agency's eight
criteria for "tamper-proof" bait stations would not guarantee
that the units would be absolutely impervious to all forms of
tampering imaginable. EPA agrees that these criteria are better
suited to describing "tamper-resistant" stations.
EPA also concurs with those who stated that the criterion
that stations be capable of being secured should be waived
for designs which prevent the shaking of bait from a station
after it has been moved. The criterion that bait stations be
"resistant to weather" should be applied only when baits are used
in areas where weather could be a factor (e.g., when water from
rain or run-off could enter the unit).
The revised criteria for tamper-resistant bait stations are
as follows:
1. resistant to destruction or weakening by elements
of typical non-catastrophic weather (e.g., snow,
rain, extremes of temperature and humidity, direct
sunshine, etc.);
2. strong enough to prohibit entry or destruction by
dogs and by children under six'years of age using
their hands, their feet, or objects commonly found
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7
in the "use environment (e.g., sticks, stpnes, broken
glass, etc. stations stronger than "tamper-
resistant" are needed in areas frequented by hoofed
livestock, raccoons,.bears, other potentially
destructive animals, or in areas prone to vandalism);
3. capable of being locked or sealed so that children
and nontarget animals cannot gain access through .
the opening or procedures used to fill the bait
compartment(s);
4. equipped with rodent entrances which a) readily
allow target animals access to baits, b) deny such
access to other animals larger than adults of the
target species, and c) discourage entry by birds.
Means for achieving these ends might include use
of baffles, mazes, or small entrances;
5. capable of being anchored securely to resist
efforts to move the station or to displace its'
contents, or equipped with a mechanism which
virtually prevents bait from being shaken out of
the station after it has been moved;
6. equipped with internal structures for containing
baits and minimizing spillage and tracking of bait
outside of the station or into readily accessible
parts of the station;
7. made of a design and color that is not especially.
attractive to children; and
8. capable of displaying precautionary statements in
a prominent location.
These criteria'for "tamper-resistant" bait stations identify
the performance features required of bait stations by labeling
when commensal rodenticide baits are applied in areas accessible
to children and nontarget animals. Note that label requirements
for using tamper-resistant bait stations apply to those who place
bait, not to bait station manufacturers. EPA has no direct
regulatory authority over the production and sale of bait
stations unless they are sold with rodenticide baits.
Standards and Protocols for Testing Bait Stations
EPA has received .relatively little information regarding the
elements to be included in protocols for testing bait stations or
on performance standards for bait stations. Several bait station
manufacturers have consulted with EPA staff regarding tests for
evaluating protective qualities of bait .stations. These tests
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8
have dealt primarily with young children and dogs, the nontarget
organisms for which the largest numbers of rodenticide exposure
incidents have been reported. In tests done to date, children
or dogs have been given incentives to enter bait stations sealed
and secured as they should be in rodent control operations.
With children,, Child-resistant Packaging (CRP) test protocols
may be modified for use in screening bait stations. Several
manufacturers have had their stations evaluated according to
adapted CRP testing procedures.
EPA has concluded that its staff should draft standards and
protocols for bait stations, but that testing according to these
methods should be performed in the private sector at the expense
of bait station manufacturers. Through cooperation with these
manufacturers and other interested parties, EPA believes that
the protocols can be refined and that agreements on appropriate
adjustments to test procedures and performance standards for
"tamper-resistant bait stations" can be reached.
EPA concurs with those who testified at the hearings
that all stations, including those identified as "adequate" in
PR Notice 83-5, ultimately should be tested according to the
same set of standards. Under such standards, stations could be
rated according to their performances in various aspects of bait
protection. Station users then would be able to select units.
appropriate for specific applications.
Until protocols and standards are developed, EPA will
continue to provide lists of "adequately protective" bait
stations. These units are considered to provide adequate bait
protection when use is consistent with directions for the bait
and the station, common sense, EPA's criteria for "tamper-
resistant bait stations", principles of safe and effective
rodent control, and any stipulations noted on the lists.
Since PR Notice 83-5 was issued, the number of adequately
protective bait station designs available commercially has
increased. A current list is appended to this notice. Lists
of "adequate" units are current as of the dates noted on them
and are "historical" in that stations are listed even if they no
longer are commecially available.. In the future, lists will be
updated as new units are added but will not be circulated each
time that a change is made. Updated lists may be obtained by
contacting William W. Jacobs (see information on page 12 of this
notice).
The.list refers to the specific designs evaluated by EPA.
If manufacturers modify stations after EPA has examined them,
their protective qualities might be compromised in the process.
The stations are considered to be "adequately protective" only
when they are used properly. In most cases, "proper use" means
that units must be immobilized and locked.
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Units are listed to provide guidance to rodenticide users
concerning the degree of protection that must be provided when
rodenticide baits are used in areas accessible to children,
pets, domestic animals, and nontarget wildlife. Other adequate
stations may be available now or may become available in the
future. Users may build stations consistent with'the criteria
listed in this notice instead of purchasing, commercial units.
EPA does not endorse bait stations. While they-may note whether
their specific models are on the Agency's list of adequately
protective bait stations, advertisers may not imply that their
units are endorsed by the U.S. Government, the U.S. Environmental
Protection Agency,, or any employee thereof.
Required Label Statements for Commensal Rodenticide Baits
The statements below must be added to labels which bear
directions for applying solid or liquid baits to control commensal
rodents: Norway rats, roof rats, or house mice. Statements now
on labels which address use of "tamper-proof bait boxes" must
be deleted. On many labels, such text is found in the second
paragraph under "USE RESTRICTIONS".
The following language must appear on the label directly
below the heading "DIRECTIONS FOR USE".
"It is a violation of Federal law to use this
product in a manner inconsistent with its labeling.
READ THIS_LABEL: Read this entire label and follow
all use directions and use precautions.
IMPORTANT: Do not expose children, pets, or other
nontarget animals to rodenticides. To help to
prevent accidents:
1. Store product not in use in a location out of
reach' of children and pets.
2. Apply bait in locations out .of reach of
children, pets, domestic animals and nontarget
wildlife, or in tamper-resistant bait stations.
These stations must be resistant to destruction
by dogs and by children under six years of age,
and must be used in a manner that prevents such
children from reaching into bait compartments
and obtaining bait. If bait can be shaken
from stations when they are lifted, units must
be secured or otherwise immobilized. Even
stronger bait stations are needed in areas
open to hoofed livestock, raccoons, bears,
other potentially destructive animals, or in
areas prone to vandalism.. - ',
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10
3. Dispose of product container, and unused,
spoiled, and unconsumed bait as specified
on this label."
The captions "READ THIS LABEL" and "IMPORTANT" must be
printed in conspicuous type, preferably in a color which
contrasts with the remainder of the text in this section and
with the background. A sample format label for anticoagulant
commensal rodenticide solid baits is appended to this notice
to provide an example of how new labels should appear. If you
have any questions concerning the labeling, please contact
William W. Jacobs (see information on page 12 of this notice).
EPA will consider modifying this language appropriately for
products sold in structures that meet the criteria for tamper-
resistant bait stations.
Labeling for Tracking Powders
Statements implying that tracking powders registered to
control- Norway rats, roof rats, and/or house mice may be used
in bait stations or in.other locations to which children or
nontarget animals might have access must be.deleted from product
labels.' The parts of bait stations to which tracking powders
would be applied are the areas through which target rodents
travel. Such areas generally are accessible to children and to
certain species of nontarget animals.
Implementation of Policy ,
The policies set forth in this notice are effective
immediately. Deadlines for bringing labels into compliance are
indicated below and on page 11.
Compliance Procedures
1. Bait Products and Concentrates with End-Use Directions
Within 90 days of receipt of this Notice,'you must submit
applications for amended registrations for any commensal
rodenticide products which are sojLid baits, liquid baits, or
concentrate products with labels which bear directions for
preparing and applying baits. At the beginning of the
"DIRECTIONS FOR USE" section, amended labels should include the
text identified on pages 9 and 10 of this Notice. The attached
format label for "dry" anticoagulant baits indicates appropriate
placement for the new text. , Five (5) copies of proposed
amended labels must be submitted along with the Application for
Pesticide: Registration Amendment (EPA Form 8570-1).
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11 .
Registrants need not submit revised labels for products with
accepted labels which already bear the language required by this
Notice. ~~~ " ';' !
Registrants who wish to modify the labeling statements
contained in this Notice must submit .an Application .for Amended
Registration (EPA Form 8570-1), five (5) copies of revised draft
labeling, and a document which notes each specific modification
and states why each modification is believed to be justified.
2. Compliance Procedures for Tracking Powders
Within 90 days of receipt of this Notice, registrants of
tracking powder products must submit an Application for Amended
Registration (EPA Form 8570-1) and five (5) copies of revised
draft^labeling, if current labeling language permits use of
tracking powders in bait stations or other locations accessible
to children, pets or other nontarget animals. The new labeling
must^delete all references to use of tracking powders in bait
stations or other places accessible to children or nontarget
animals.
Required Labeling- - Timetable for Compliance
No product subject to the labeling requirements of this
Notice may be released for shipment by the registrant after
March 16, 1996, unless the product bears amended labeling that
complies with the requirements of this notice.
No product subject to the labeling requirements of this
Notice may be distributed, sold, offered for sale, held, for sale,
shipped, delivered: for shipment, or received and (having been
so received) delivered or offered to be delivered by any person
after September 16, 1996 unless the product bears amended
labeling which complies with the requirements of this Notice.
Consequences of Failure to Comply
Products affected by this Notice that' are not labeled
appropriately on or before the above compliance dates will be
deemed "misbranded" under FIFRA section 2(q)(l).
>
Failure to revise the product labeling to include the
requirements of this notice may also result in initiation of
cancellation proceedings under FIFRA section 6(b).
Where to Submit Labeling
All labeling submissions in response to this notice should
be sent to the following address:
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12
Document Processing Desk (BBOX-14)
Office of Pesticide Programs (7504C)
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460-0001
Further Information
Persons interested in specific details regarding the
content of this notice should contact:
Dr. William W. Jacobs
Registration Division (7505C)
U.S. Environmental Protection
401 M Street, SW
Washington, D.C. 20460
Telephone: 703-305-6406
Agency
son, Director
Division (7505C)
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[FORMAT LABEL - READY-TO-USE ANTICOAGULANT]
[Front Panel]
[PRODUCT NAME]
Kills Norway Rats, Roof Rats, and House Mice
ACTIVE INGREDIENTS
INERT INGREDIENTS
TOTAL
100.0%
KEEP OUT OF REACH OF CHILDREN [12 pt1]
CAUTION [18 pt1]
SEE RIGHT PANEL FOR ADDITIONAL PRECAUTIONARY
STATEMENTS
[Company Name and Address]
EPA Reg.tNo. '
'EPA Est. No. '
NET CONTENTS
1 Assumes a front panel of over 30 sq. in.
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[Left Panel]
DIRECTIONS FOR USE
It is a violation of Federal law to use this product in a manner inconsistent
with its labeling.
READ THIS LABEL:
precautions.
Read this entire label and follow all use directions and use
IMPORTANT: Do not expose children, pets, or other nontarget 'animals to
rodenticides. To help to prevent accidents:
1. Store product not in use in a location out of reach of children and pets.
2. Apply bait in locations out of reach of children, pets, domestic animals
and nontarget wildlife, or in tamper-resistant bait stations. These
stations must be resistant to destruction by dogs and by children under
six years of age, and must be used in a manner that prevents such children
from reaching into bait compartments and obtaining bait. If bait can '
be shaken from stations when they are lifted, units must be secured or
otherwise immobilized. Even stronger bait stations are needed in areas
open to hoofed livestock, raccoons, bears, other potentially destructive
animals, or in areas prone to vandalism.
3. Dispose of product container, and unused, spoiled, and unconsumed bait as
specified on this label.
USE RESTRICTIONS - For control of Norway rats, roof rats, and house mice in and
around homes, industrial buildings, and similar man-made structures. Do not
place bait in areas where there is a possibility of contaminating food or
surfaces that come in direct contact with food. Do not broadcast bait.
SELECTION OF TREATMENT AREAS - Determine areas where rats or mice will most
likely find and consume the bait. Generally, these are along walls, by gnawed
openings/ in or beside burrows, in corners and concealed places, between.
floors and walls, or in locations where rodents or their signs have been seen.
Protect bait from rain or snow. Remove as much food as possible.
APPLICATION DIRECTIONS '
RATS: Apply 4, to 16 oz. of bait per placement. Maintain an uninterrupted
supply of fresh bait for at least 10 days.
MICE: Apply 1/4 to 1/2 oz. (1-2 level tablespoons) of bait at 8- to 12-foot
intervals. Larger placements (up to 2 oz.) may be needed at points of
very high mouse activity. Maintain an uninterrupted supply of fresh
bait for at least 15 days.
RATS/ Replace contaminated or spoiled bait immediately. Collect and dispose
MICE of all dead animals and leftover bait properly. To prevent reinfestation,
limit sources of rodent food, water, and harborage as much as possible.
If reinfestation does occur, repeat treatment. Where a continuous
source of infestation is present; establish permanent bait stations and
replenish as needed.
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[Right Panel]
[For Household Non-aerosol Products]
,STORAGE AND DISPOSAL [12 pt1]:
Storage: store only in original container, in a dry place
inaccessible to children and pets
Disposal: Do not reuse empty container,2 Securely wrap in
newspaper and discard in trash.
[For Non-Household Products]
Storage and Disposal [12 pt1]
Do not contaminate water, food or feed by storage or disposal.
STORAGE: [Develop statements based on "Storage Instructions"
factors 1-5 in PR Notice 83-3, pp 2-3.
PESTICIDE DISPOSAL: [Use 1 of 3 paragraphs on p. 4, PR Notice 83-3.]
Use i| 2 if product is "Acutely Hazardous" (RCRA E List).
Use 1| 4 if product is "Toxic" (RCRA F list).
Use 11 6 if product is neither "Acutely Hazardous" or "Toxic".
CONTAINER DISPOSAL: [See Appendix A on'p. 7 of PR Notice 83-3.]
PRECAUTIONARY STATEMENTS:
HAZARD TO HUMANS AND DOMESTIC ANIMALS ;
CAUTION: Keep away from humans, domestic animals and pets. If swallowed, this
material'may reduce the clotting ability of the blccdand cause bleeding!
NOTE TO PHYSICIAN - If ingested, administer Vitamin Ki intramuscularly or
orally,, as indicated in bishydroxycoumarin overdoses. Repeat as necessary
based on monitoring of prothrombin times.
ENVIRONMENTAL HAZARDS
This product is toxic to mammals and birds: Do not apply this product directly
to water, or to areas where surface water is present or to intertidal areas
below the mean high water mark.
Assumes a panel over 30 square inches in area.~'
If container is a bottle, can, or jar, add "Rinse container thorouqhly."
here. ^ J
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