United States
                 Environmental Protection
                 Agency	
                      Prevention, Pesticides
                      And Toxic Substances
                      (7508W)	
EPA-738-F-98-004
July 1998
                  R.E.D.   FACTS
                  Rodenticide    Cluster
     Pesticide
Reregistration
     All pesticides sold or distributed in the United States must be
registered by EPA, based on scientific studies showing that they can be used
without posing unreasonable risks to people or the environment.  Because of
advances in scientific knowledge, the law requires that pesticides which
were first registered before November 1, 1984, be reregistered to ensure
that they  meet today's more stringent standards.
                      In evaluating pesticides for reregistration, EPA obtains and reviews a
                 complete set of studies from pesticide producers, describing the human
                 health and environmental effects of each pesticide. The Agency develops
                 any mitigation measures or regulatory controls needed to effectively reduce
                 each pesticide's risks. EPA then reregisters pesticides that can be used
                 without posing unreasonable risks to human health or the environment.
   Use Profile
     When a pesticide is eligible for reregistration, EPA explains the basis
for its decision in a Reregistration Eligibility Decision (RED) document.
This fact sheet summarizes the information in the RED document for
reregistration case 2755, brodifacoum; case 2760, bromadiolone; case 2765,
bromethalin; case 2100, chlorophacinone;  case 2205, diphacinone and its
sodium salt, and, case 2810, pival and its sodium salt.

     These chemicals are for the control of mammal pests, particularly
commensal rats and mice but also a variety of field rodents [note:
commensal rodents are Norway rat, roof rat, and house mouse.] Products
can be used in and around buildings, alleys, transport vehicles (trains, ships,
aircraft) and related port terminals, or in sewers.  A few diphacinone labels
allow applications in wet or damp sites such as dumps, irrigation ditches,
along fences, and in gullies.  Other products have limited uses.
Bromadiolone products can be applied only indoors in non-urban areas.
Diphacinone sodium salt liquid (i.e., drinking) bait can be applied only
indoors, and diphacinone and chlorophacinone tracking powders can only be
used indoors and in rodent burrows along the outside walls of buildings.

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                          Most rat and mouse products are formulated as pelletized baits. Some
                     products are sold in place packs (pellets contained in small plastic or paper
                     bags applied unopened) and others, especially those  for use in sewers, as
                     paraffinized bait blocks. Current labels for rat and mouse baits used
                     outdoors require that baits be applied in protective bait stations or placed in
                     areas inaccessible to nontarget wildlife (e.g., in burrows).

                          Both chlorophacinone and diphacinone have section 3 and Special
                     Local Needs (SLNs) registrations for field uses.  Each has one product for
                     hand-applied,  underground baiting of pocket gophers. Chlorophacinone has
                     one product for underground baiting of moles. Diphacinone  has  one
                     product for field control of ground squirrels.  Twenty states have one or
                     more SLNs for vole control, predominantly in dormant fruit  orchards, and
                     nine states have SLNs  for control of ground squirrels. Other SLNs target
                     various rat species (CA, FL), deer mice (CA), pocket gophers (CA), moles
                     (OR, WA), chipmunks (CA), muskrats (CA), woodrats (CA), jackrabbits
                     (CA, OR), and mongoose (HI).
    Regulatory
         History
     Most products are 0.005% active ingredient or 0.01% active
ingredient food pellets; others include treated whole grains, paraffinized
food blocks, a chlorophacinone  orchard spray for voles, meat bait for
mongoose, and treated artichoke bracts for voles in California artichoke
fields.  Many of the orchard applications for voles include aerial
broadcasting of food bait.

     The Agency's predecessor, the U.S. Department of Agriculture
(USDA), first regulated vertebrate control agents after Congress passed
FIFRA in 1947.  Since then, additional rodenticides have been registered
including diphacinone which was registered in 1960 followed by the
registration of its sodium salt in 1962. Chlorophacinone and brodifacoum
were registered in 1971 and 1979, respectively, followed by bromadiolone in
1980 and bromethalin in 1984. This  RED covers 243 of the currently
registered 406 products, including Section 3 and 24(c)  used to control
vertebrate pests by baits and tracking powders. The decisions made in this
RED will affect many of the remaining 182 vertebrate  controlled products,
which were the subject of past REDs as well as those subject to future
reregistration.
Human Health    Toxicity
  Assessment         In studies using laboratory animals, brodifacoum, bromadiolone,
                     bromethalin, chlorophacinone, and diphacinone and its sodium salt generally

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have been show to be highly acutely toxic. All chemicals, with the
exception of bromethalin, are in categories I  for oral, inhalation and dermal
exposure. Bromethalin is category II for dermal exposure.

Dietary Exposure
     The Agency considers the uses of brodifacoum, bromadiolone,
bromethalin, chlorophacinone, and diphacinone and its sodium salt to be
nonfood.  Based on current use patterns and exposure profiles, residues in
and on food and/or  feed are not expected to occur.  Therefore,  a dietary
risk assessment is not required.

Occupational and Residential Exposure
     EPA is concerned about the likelihood  of risk of human exposure,
resulting from continued use of rodenticides in residential settings.  The
number of human incidents reported has 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.  About 90%  of these
cases involved children under six years of age. Nearly all of such exposure
incidents are classed as accidents. The human exposure incidents that are
reported may represent less than half of those which actually  occur. Well
over 80% of reported human rodenticide exposures involve anticoagulant
compounds.

     The Agency has determined that there is potential exposure to
applicators and/or other handlers during  typical use patterns associated with
these chemicals.  Specifically, the Agency is concerned about potential
dermal and inhalation exposures to handlers during the loading and
application of these chemicals. Based  on the use patterns and potential
exposures, major handler scenarios were identified such as (1) placing  bait
packs;  (2) loading bait boxes or bait stations with meal bait, grain bait, bait
pellets, or other food-based bait from larger containers; (3) breaking
parafinized blocks into pieces and placing the pieces in bait stations; (4)
securing large paraffin blocks in bait stations used in sewers;  (5) applying
bait by hand;  and (6) applying bait, e.g.  pellets in broadcast treatments
using ground and (6) spray.

Human Risk Assessment
     Rodenticides are acutely toxic to humans.  Margins of Exposure
(MOEs), when bait is ingested, are less than  one.  Generally, the Agency

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                          considers a MOE of 100 or above to be protective of the public's health.
                          The Agency, for example, has calculated the dose a  10 kg child receives
                          from a 43 gram packet (standard commercial package).  The Agency's
                          calculation resulted in a MOE of 0.5.. Because of improved data collection,
                          it appears that the high number of human unintentional or accidental
                          exposures to rodenticides remain constant each year, or may be increasing.
                          From the number of exposures to children, it is clear that children under six
                          years-old are disproportionately more at risk to the continued use of these
                          products in and around the home. EPA  is therefore  concerned about the
                          risk from accidental exposures to these chemicals from residential users,
                          particularly  children.
Environmental
Assessment
Environmental Fate
     While generally the rodenticides are very similar in their
environmental fate characteristics, there are a few exceptions.  The
rodenticides are generally stable to hydrolysis, except for diphacinone at pH
5 (which has a half-life of 44 days),  moderately persistent to persistent to
aerobic soil degradation (half-lives of 26 to  178 days) and, except for
bromethalin can generally be considered to be immobile in the soil (Kds =
5.4 to  1000, and found in the upper  soil layer of column leaching studies).
                                Generally the potential for these chemicals to reach ground water is
                          low.  They probably reach surface waters through adsorption to eroding
                          soil, as opposed to dissolution in runoff water. Because of their generally
                          high adsorption coefficients and/or demonstrated lack of movement in soil
                          leaching columns they would have a good probability of partitioning into the
                          suspended and bottom sediments instead of the water column after reaching
                          surface waters.

                                Based on the available data, little if any contamination of surface and
                          ground waters is expected for brodifacoum, bromadiolone, chlorophacinone
                          and diphacinone.  These chemicals, although persistent, tend to be relatively
                          immobile in soil and fairly insoluble in water. Most are applied as a
                          pelleted bait in and around buildings and mostly in protective bait stations
                          when used outdoors. Because of the lack of leaching data, the
                          environmental fate of bromethalin is uncertain at this time.  Leaching data is
                          being requested for bromethalin in the RED.
                          Ecological Effects
                                Primary toxicity to mammals is very high for all five of these
                          products.  Primary toxicity to birds is mostly high to very high for the
                          single-feeding compounds (brodifacoum, bromadiolone, bromethalin),but

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                      mostly moderate for the multiple-feeding compounds (diphacinone,
                      chlorophacinone).  Toxicity to aquatic organisms ranges from moderate to
                      very high.

                           Available laboratory and/or field data indicate that rodents poisoned
                      with brodifacoum and bromadiolone baits can kill avian and mammalian
                      secondary consumers.  Sufficient data also exists to indicate that 0.01% a.i.
                      diphacinone bait is secondarily hazardous to birds and mammals and that
                      0.01% a.i. chlorophacinone bait is hazardous to mammalian predators.

                      Ecological Effects Risk Assessment
                           The Agency believes that there  is a high risk of secondary poisoning,
                      especially to mammals, from the use of these rodenticides outdoors (i.e.,
                      "around" buildings) in rural and suburban areas. The available data
                      indicate that brodifacoum, bromadiolone, and 0.01% a.i. chlorophacinone
                      and diphacinone baits may pose a secondary hazard to avian and/or
                      mammalian predators that feed on poisoned rodents.  Brodifacoum and
                      bromadiolone likely pose  the greatest secondary risks, because they are
                      more acutely toxic, especially to birds, more persistent in animal tissues,
                      and can be lethal in a single feeding.  In contrast, chlorophacinone and
                      diphacinone tend to be less toxic to  birds, less persistent in the tissues  of
                      primary consumers, and must be eaten over a period of several days to
                      cause  mortality.  Therefore, a predator feeding  only once on a poisoned
                      carcass may not die if the the rodent was poisoned with diphacinone or
                      chlorophacinone, but is more likely to die if the rodent was poisoned with
                      brodifacoum or bromadiolone.  Data  is being requested in the RED for
                      bromethalin in order to determine secondary risks.

                           The Agency recently became aware of incident data which suggests
                      that there may be a potential incident problem specifically involving the
                      active ingredient brodifacoum.  At this time the Agency is reviewing the
                      data; no final conclusions have been reached. Additionally, through the
                      "Notice of Availability" for this document, the  Agency requests state
                      incident data for all rodenticides to better understand the extent of this
                      potential problem.  After  review, the Agency may impose additional
                      restrictions on the use of brodifacoum and/or other active ingredients.

Risk Mitigation         To address the risks posed by the rodenticides bromadiolone,
                      bromethalin, brodifacoum, chlorophacinone, diphacinone and its sodium
                      salt, EPA has developed a two-phased approach to minimize exposure
                      particularly to infants and children.

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Additional Data
        Required
     During Phase I the Agency will require the products covered in the
rodenticide cluster to incorporate an indicator dye (to help identify whether
a child or pet has actually consumed the pesticide) and  a bittering agent into
the formulations.  The Agency is aware that all mitigation measures
required during Phase I may not be feasible within the  8-month time frame
usually accorded by the RED process to submit labeling changes. While
registrants will still be required to submit revised labeling within the 8-
month time frame, the Agency recognizes that the formulation changes
required by the add-on of the indicator dye and bittering agent may take
longer.  The timing for the incorporation of the dye and bittering agent in
rodenticide products will be an outcome of the initial stakeholder meeting.
In Phase  II, EPA will form a stakeholder group that will include
representatives from industry, states, various poison  control centers, rodent
control experts, the medical community and other interested parties to
develop additional means of significantly reducing exposures to children and
pets.

     In addition to the mitigation measures discussed above, EPA is
requiring a number of label revisions to rodenticides used  in and around the
home as well as requiring registrants, under the authority of FIFRA, section
3(c)(2)(B), to submit data from the American Association  of Poison Control
Center.  The data will be for the years 1999 through 2009.  Restricted  Use
classifications will also continue to be maintained.

     EPA is requiring the following additional generic studies to confirm
its regulatory assessments and conclusions:
                      Brodifacoum
                                 21-Day Dermal - rabbit/rat [82-2)
                                 Estimation of Dermal Exposure at Outdoor Sites [231]
                                 Estimation of Inhalation Exposure at Outdoor Sites [232]
                                 Estimation of Dermal Exposure at Indoor Sites [233]
                                 Estimation of Inhalation Exposure at Indoor Sites [234]
                      Bromadiolone
                                 Leaching/Adsorption/Desorption [163-1]
                                 Estimation of Dermal Exposure at Outdoor Sites [231]
                                 Estimation of Inhalation Exposure at Outdoor Sites [232]
                                 Estimation of Dermal Exposure at Indoor Sites [233]
                                 Estimation of Inhalation Exposure at Indoor Sites [234]

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Bromethalin

•          General Metabolism [85-1]
•          Leaching/Adsorption/Desorption [163-1]
•          Estimation of Dermal Exposure at Outdoor Sites [231]
•          Estimation of Inhalation Exposure at Outdoor Sites [232]
•          Estimation of Dermal Exposure at Indoor Sites  [233]
•          Estimation of Dermal Exposure at Outdoor Sites [234]
•          Secondary Poisoning, Mammal [70-A-SS]*
•          Protocol
•          Secondary Poisoning, Bird  [70-B-SS]*
•          Protocol
•          Whole Body Residue, Target Species [70-C-S]*
•          Protocol
* Studies are not required for "indoors and along the outside walls of
buildings", but are required for any other uses.

Chlorophacinone

•          Avian Reproduction, Quail  [71-4(a)]*
•          Avian Reproduction Duck [71-4(b)]*
•          Estimation of Dermal Exposure at Outdoor Sites [231]
•          Estimation of Inhalation Exposure at Outdoor Sites [232]
•          Estimation of Dermal Exposure at Indoor Sites  [233]
•          Estimation of Dermal Exposure at Outdoor Sites [234]
•          Secondary Poisoning, Mammal [70-A-SS]**
•          Protocol
•          Secondary Poisoning, Bird  [70-B-SS]**
•          Protocol
•          Whole Body Residue, Target Species [70-C-S]**
•          Protocol
*Required to support Product CAS 90023.
**Studies are not required for "indoors and along the outside walls of
buildings", but are required for any other uses.

Diphacinone, and Salt

•          General Metabolism[85-l]

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                          •          Hydrolysis [161-1]
                          •          Leaching/Adsorption/Desorption [163-1]
                          •          Estimation of Dermal Exposure at Outdoor Sites [231]
                          •          Estimation of Inhalation Exposure at Outdoor Sites [232]
                          •          Estimation of Dermal Exposure at Indoor Sites [233]
                          •          Estimation of Dermal Exposure at Outdoor Sites [234]
                          •          Secondary Poisoning, Mammal [70-A-SS]*
                          •          Protocol
                          •          Secondary Poisoning, Bird [70-B-SS]*
                          •          Protocol
                          •          Whole Body Residue, Target Species [70-C-S]*
                          •          Protocol
                          * Studies are  not required for "indoors and along the outside walls of
                          buildings", but are required for any other uses.
                               The Agency also is requiring product-specific data including product
                          chemistry and acute toxicity studies, revised Confidential Statements of
                          Formula (CSFs), and revised labeling for reregistration.

 Product LabGling        All brodifacoum, bromadiolone, bromethalin, chlorophacinone and
            ChanQGS   diphacinone  and its sodium salt end-use products must comply with EPA's
RpnnirpH               current pesticide product labeling requirements and with the following.  For
                          a comprehensive list of labeling requirements, please  see the Rodenticide
                          Cluster RED document.

                          Labeling Requirements:

                          1.    Incorporate the word "POISON" (in Spanish and English),  and skull
                          and cross bones icon on the labels.

                          2     The section on labels for pets must include a  hazard to pet statement,
                          first aid treatment for pets, and a note to  veterinarians.

                          3.    To clarify that bait can be applied only as specified on the label the
                          following must be added: "Do not apply this product by any method not
                          specified on  this label".
                          4.    Specific information regarding use sites and use directions should be
                          included on SLN labels to help avoid inappropriate use of these products.

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5    Dust masks/respirators and water-proof gloves are required for
commercial handlers  (Mixer/loader/applicator) when handling rodenticide
chemicals not already in place packs.

6    All products intended primarily for occupational use must contain the
following statement:   "Do not contaminate water, food, feedstuffs, food or
feed handling equipment, or milk or meat handling equipment".

7.   Products intended primarily for consumer use (OTC) must contain the
following stat:  "Do not apply this product in a way that will contact any
person or pet.  Keep people and pets out of the area during application.

8.   All products must contain an environmental hazard statement stating:
"Do not apply directly to water or to areas where surface water is present or
to intertidal areas below the mean high-water mark. Do not contaminate
water when disposing of equipment, wash water,  or rinsate".

9.   All tracking powders must limit treatment areas to concealed,
inaccessible places such as spaces between floors  and walls. Powder may
not be applied along walls, in corners or in open floor areas of rooms in
which food or feed is handled or stored.

10   All rodenticide products labeled for field use, except those limited to
manual underground baiting for pocket gophers and moles, will be restricted
use.

11.  Where applications for the control  of mice and rats in non-urban and
rural settings are not limited indoors and against the outside walls of
buildings, labels shall state to place baits:
"indoors and along the outside walls of buildings."

12.  The second sentence of the "Environmental Hazards" precautionary
labeling on all food bait products should read as follows:  "Predatory and
scavenging mammals  and birds might be poisoned if they feed upon animals
that have eaten the bait."

13.  For chlorophacinone orchard spray products,  the statement should be
modified to read:
"Predatory and scavenging mammals and birds might be poisoned if they
feed upon animals that have been poisoned by this product.

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 Regulatory         With the exception of pival and its sodium salt, the Agency has
Conclusion   concluded that the uses, as prescribed in the RED document, with additional
                 labeling requirements and a number of risk mitigation measures, will not
                 cause unreasonable risks to humans or the environment.

                       The Agency has determined that all uses of brodifacoum, bromethalin,
                 and bromadiolone are eligible for reregistration.

                       The Agency has determined that all uses of chlorophacinone and
                 diphacionone and its sodium salt are eligible for reregistration, with the
                 exception of certain field bait uses.  The Agency has determined that field-
                 bait uses containing .005% chlorophacinone and diphacionone and its
                 sodium salt are eligible for reregistration.

                       The Agency has determined that field-bait uses containing more than
                 .005% chlorophacinone and diphacionone and its sodium salt are ineligible
                 for reregistration.  Field tests have adequately demonstrated that products
                 with lower-concentrations of these active ingredients are sufficiently
                 efficacious for target pest species, and that the uses with higher
                 concentrations have the potential to cause unnecessary secondary poisonings
                 to avian and mammalian consumers.
   For More
Information
     The EPA has determined that all uses of pival and its sodium salts are
ineligible for reregistration.  Pival and its sodium salt was suspended by the
Agency in December 1994 for failure of the registrant, Motomco,
Incorporated,  to respond to the Agency's Data Call-in Notice (DCI) and
submit the required data to support the continued registration.  In the future,
EPA may seek cancellation of the registration for pival and its sodium salt.

     EPA is requesting public comments on the Reregistration Eligibility
Decision (RED) document for brodifacoum, bromadiolone, bromethalin,
chlorophacinone and diphacinone and its sodium salt, during a 60-day time
period, as announced in a Notice of Availability published in the Federal
Register.  To obtain a copy of the RED document or to submit written
comments, please contact the  Pesticide Docket, Public Response  and
Program Resources Branch, Field Operations Division (7506C),  Office of
Pesticide Programs (OPP), US EPA, Washington, DC 20460, telephone
703-305-5805.
                       Electronic copies of the RED and this fact sheet can be downloaded
                 from the Pesticide Special Review and Reregistration Information System at
                                         10

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703-308-7224. They also are available on the Internet using ftp on
FTP.EPA.GOV, or using WWW (World Wide Web) on WWW.EPA.GOV.

     Printed copies of the RED and fact sheet can be obtained from EPA's
National Center for Environmental Publications and Information
(EPA/NCEPI), PO Box 42419, Cincinnati, OH  45242-0419, telephone
513-489-8190, fax 513-489-8695.

     Following the comment period, the Rodenticide Cluster RED
document also will be available from the National Technical Information
Service (NTIS), 5285 Port Royal Road, Springfield,  VA 22161, telephone
703-487-4650.

     For more information about EPA's pesticide reregistration program,
the brodifacoum, bromadiolone, bromethalin, chlorophacinone, and
diphacinone  and its sodium salt RED, or reregistration of individual
products containing brodifacoum,  bromadiolone, bromethalin,
chlorophacinone, and diphacinone, please contact the Special Review and
Reregistration Division  (7508W),  OPP, US EPA, Washington, DC 20460,
telephone 703-308-8000.

     For information about the health effects of pesticides, or for assistance
in recognizing and managing pesticide poisoning symptoms,  please contact
the National  Pesticides Telecommunications Network (NPTN).  Call toll-
free 1-800-858-7378, between 9:30 am and 7:30 pm  Eastern Standard
Time, Monday through  Friday.
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