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DC 20460
540/FS-88-129
• &EPA Pesticide
Fact Sheet
Name of Chemical: STRYCHNINE UPDATE
Reason for Issuance: 5ff§ORARY CANCELLATION ABOVE GROUND
Date Issued: SEPTEMBER 28, 1988
Fact Sheet Number:
178
1. DESCRIPTION OF CHEMICAL
Ge-neric Name: Strychnine Alkaloid C2iH22N2^2
(chemical) Strychnine Sulfate C2 i H22N2°2 ^H2 S04"I"SH2°
Common Name: Strychnine
Trade
Other
and
Names
Nux Vomica
EPA Shaughnessy Code:
Strychnine Alkaloid - 076901-8
Strychnine Sulfate 076902-6
Chemical Abstracts Service (CAS) Number:
Strychnine Alkaloid 57-24-0
Pesticide Type: Vertebrate pesticide.
U.S. and Foreign Producers: All manufacturers import the technical
grade material. Importers include H. Interdonati, Inc.; H. R. Harkins,
Inc.; Noris Chemical Co.; and the U.S. Department of Agriculture (USDA),
There are approximately 100 registrants of end-use products (37 regis-
trants include the California Department of Food and Agriculture, and
California counties).
2. USE PATTERNS AND FORMULATIONS;
There are 383 products; 194 are registered for use above ground and
189 are registered for use below ground. The approximately 200 use
sites include rangelands, pastures, many crops, forests, and below
ground application for pocket gophers and moles.
Formulation Types: Strychnine is usually formulated in grain baits
at 0.2% to 0.5% but is also incorporated into a salt block at 5.79%
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3. AGENCY ACTION:
On August 23, 1988, the Eighth Circuit Court of Appeals denied
EPA's motion for a stay of an April 11, 1988, order of the U.S.
District Court for the District of Minnesota requiring EPA to
temporarily cancel all strychnine registrations for above-ground
use to protect non-target species. Accordingly, the Agency is
issuing a Federal Register (FR) notice to implement the court's
order. Since temporary cancellation is not a remedy available
under FIFRA, the FR notice identifies the court as the authority
for the temporary cancellation action. The District Court has
reviewed the FR Notice and has no objection to the issuance of
the notice. The FR notice was signed on September 28, 1988 by the
Aministrator and it is to be issued in the Federal Register on
Wednesday, October 5, 1988.
4. BACKGROUND
In 1976, EPA initiated a Special Review [formerly Rebuttable
Presumption Against Registration (RPAR)] of the above-ground uses
of the pesticide strychnine in which the risks and benefits of
strychnine use were examined in detail. This review process was
concluded on October 19, 1983, with the publication of a Notice
of Intent to Cancel. That Notice allowed for continued registration
of certain above-ground uses of strychnine with certain label modifi-j
cations and required full cancellation of other uses. The primary
concern of the Agency in making its risk/benefit determinations
was risk to non-target, endangered, and threatened species. Prior
to issuance of the Notice, EPA had consulted with the Fish and
Wildlife Service under section 7 of the Endangered Species Act.
An administrative hearing was requested for the uses to control
prairie do-gs, ground squirrels and meadow mice. The remaining uses
addressed in the Notice of Intent to Cancel were either•amended to
comply with the terms of the Notice or were cancelled by operation
of law. The cancellations did not become effective for the three
uses involved in the hearing.
After the administrative hearing began, settlement discussions
occurred. In the summer of 1986, a settlement was reached allowing
for the continued (with certain label modifications to protect
non-target species) registration of strychnine for above-ground use
to control prairie dogs, ground squirrels and meadow mice. All
parties agreed to the settlement except the Defenders of Wildlife
and the Sierra Club. The settlement was based on a new (1984)
biological opinion issued by the Fish and Wildlife Service in which
it was determined that aboveground strychnine use could continue
without jeopardizing the blackfooted ferret if certain protective
measures were taken. The blackfooted ferret was the species of most
concern in regard to strychnine use.
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In August 1986, the Defenders of Wildlife and the Sierra Club
filed suit against EPA in the United States District Court for the
District of Minnesota. In the suit they alleged that continued
registration of strychnine for above-ground use would result in
takings of protected wildlife under the Endangered Species Act, the
Migratory Bird Treaty Act, and the Bald and Golden Eagle Protection
Act. In January 1987, Defenders of Wildlife provided certain
information to the Agency regarding deaths of non-target wildlife
from strychnine use (the "non-target kill book"). In March 1987,
EPA issued a new Notice of Intent to Cancel which reflected the
terms of the settlement agreement and allowed the continued use of
strychnine to control prairie dogs, ground squirrels, and meadow
mice under specific terms and conditions. The Agency informed the
Defenders of Wildlife that it would review the information regarding
non-target deaths, but did not want to hold up the issuance of the
March 1987 Notice because it contained significant measures to
protect non-target species.
The "non-target kill book" information was referred to the Fish
and Wildlife Service and EPA requested a new biological opinion re-
garding the above-ground use of strychnine. In May and June, 1988
the Fish and Wildlife Service issued new biological opinions on
above-ground use of strychn-ine. These opinions currently are being
reviewed by EPA as part of a reassessment of the risks and benefits
posed by above-ground use of strychnine.
In 1984, 1986 and 1987 the Agency sent Data Call-in (DCI) notices
to the registrants of strychnine. The information required to be
submitted to the Agency includes residue chemistry, toxicology,
environmental fate, environmental safety, and efficacy data. The
deadlines were extended in December, 1987. The Agency is reviewing
progress made toward fulfilling the DCI requirements to determine
what future regulatory action may be appropriate.
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