Hi! I’m Mark Schocken.

I’m an environmental
chemist and a wildlife photographer, and I spent four
years photographing the great horned owls of
Philippe Park.

I’m going to discuss:

1. The anticoagulant rodenticides and the so-called
Introduction “safer alternatives”.
2. EPA’s recent review of the anticoagulant
rodenticides
3. How you can write to EPA to tell them what you
think about their proposed actions.
Anticoagulant Rodenticides
• First-generation anticoagulant rodenticides (FGARs)
Warfarin, diphacinone and chlorophacinone
Warfarin developed in 1940s; others came later. Causes internal bleeding.
Takes multiple feedings to cause death. Rodents develop resistance over time.
• Second-generation anticoagulant rodenticides (SGARs)
Brodifacoum, bromadiolone, difenacoum and difethialone
First developed in 1970s. Much more potent than FGARs. Lethal dose in a
single feeding. Very persistent in rodent tissues and organs.
Non-Anticoagulant Rodenticides
• Bromethalin (1985)
• A neurotoxicant that causes paralysis and convulsions.
• Lethal dose achieved with a single feeding. Death within 24 – 36 hours.

• Cholecalciferol (Vitamin D3 [1984])

• Produces elevated calcium levels which results in kidney failure.
• Lethal dose achieved with a single feeding. Death within 3 – 4 days.
Anticoagulants versus Non-anticoagulants
• The anticoagulant rodenticides, both the FGARs and SGARs, cause secondary poisoning
of owls, other raptors and non-target mammals.
• Antidote is Vitamin K1.

• Non-anticoagulants (bromethalin and vitamin D3) do not appear to cause secondary

poisoning but are very toxic on direct exposure.
• No antidote.
Environmental Protection Agency (EPA)
Registration Review of Anticoagulant Rodenticides
• Every 15 years, the EPA is required to review the registrations of all pesticides.

• EPA has recently published (November 29, 2022) their Proposed Interim Decision (PID)
for the anticoagulant rodenticides, both FGARs and SGARs.
• There is a 75-day public comment period which expires on February 13, 2023.
Key Aspects of Anticoagulant PID
• EPA concludes that the benefits of the FGARs and the SGARs outweigh the risks.
• Restricted Use Pesticide Classification
• EPA proposes that all SGARs and some FGARs to be classified as Restricted Use
Products (RUPs).
• EPA proposes to restrict the size of FGARs for consumer use to ≤ 1 lb.
• The bait needs to be contained in single-use, non-refillable plastic bait stations.
This should reduce risk to small children and pets but do nothing to protect
wildlife from secondary poisoning.
Key Aspects of Anticoagulant PID – 2

• Prohibition of Spot and Broadcast Applications of FGARs to lawns, parks, golf courses,
campsites and other recreational areas where children and pets may be exposed.
• Post-Application Follow-Up
• Carcass search, collection and disposal label statements
• Reporting Statements
• All dead or dying non-target animals should be reported to
https://www.epa.gov/pesticide-incidents
• Registrant Stewardship
• Registrants to develop, implement and maintain stewardship plans that include
development of education and outreach materials for product users.
Key Aspects of Bromethalin and Cholecalciferol
Proposed Interim Decision
• EPA proposes all bromethalin and cholecalciferol products packaged in quantities ≥ 4 lbs
of bait be classified as RUP.
• For consumer-sized packages, EPA is proposing that all applications must be made in
ready-to-use, non-refillable bait stations (except for below-grown mole control).
• Post-Application Follow-Up
• Similar to anticoagulant rodenticide proposal
• Registrant Stewardship
• Similar to anticoagulant rodenticide proposal
Suggestions for Public
Comments to EPA
Currently, the SGARs can be
purchased online from
Amazon.com. However, the SGARs
are only for commercial markets,
not the consumer market. Selling
SGARs to general consumers may
even be unlawful.

Please alert EPA so that this

oversight can be corrected.
Suggestions for Public
Comments to EPA - 2
Restricting the size of FGARs
for consumer purchase and
requiring a single-use, non-
refillable bait station will help
to reduce direct exposure risk
to small children and pets but
will do little to reduce
secondary poisoning to
wildlife.
Please point this out to EPA.
Suggestions for Public
Comments to EPA - 3
EPA proposes to prohibit FGARs as spot and
broadcast treatments on recreational areas
to protect direct exposure to children and
pets. That’s helpful.
Post application carcass search, collection
and disposal are helpful if complied with by
applicators.
The mandatory reporting requirement for all
dead or dying non-target animals is very
good as it will make incident reporting more
accurate.
Product stewardship is also good.
You should tell EPA that these are good
actions although they need to do more.
Suggestions for Public
Comments to EPA - 4
Still, in our opinion, EPA’s
mitigations did not go nearly
far enough. We believe that
EPA should CANCEL the
anticoagulant rodenticides or
severely restrict their use.

Please tell them that.

Suggestions for Public
Comments to EPA - 5
You can also provide
comments about how you
personally feel towards the
poisoning of our beloved
Philippe Park great horned
owls and a plea to ban or
severely restrict these
harmful chemicals.
How to Submit a Comment to the EPA
Go to Regulations.gov and paste in the docket number of one of the anticoagulant rodenticides. In
this case, it’s brodifacoum. Press the SEARCH button.
Click on “Only show documents open for comments on the left.”
Then look for Pesticide Registration Review: Proposed Interim Decisions for the Rodenticides
Under that you’ll see a box for Comments. Click it and enter your comment.
Docket Numbers for all Anticoagulant Rodenticides
(Pinned to the Safety Harbor Facebook Group Site)
In Memory of Emily and
Oliver and their family.