The Environmental Protection Agency (EPA) is providing an opportunity for public comment on a petition received from the World Wildlife Fund (WWF) that requests both the suspension of the registration for Rozol Prairie Dog Bait and cancellation of certain application sites for this product. The three main concerns of WWF and basis for the petition are; (1) the potential adverse affect this product will have on non-target species, including certain predators and scavengers; (2) ask the EPA to initiate formal consultation, under section 7 of the Endangered Species Act, with the U.S. Fish and Wildlife Service (FWS) regarding the registration of this product; and (3) request that the EPA develop a memorandum of understanding with the FWS to show how EPA will promote the conservation of birds under the Migratory Bird Treaty Act. The EPA regulates non-food use pesticides, such as Rozol Prairie Dog Bait, under the Federal Insecticide, Fungicide, and Rodenticide Act (FIRFA).
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The AVMA supports the WWF's June 5, 2009 petition requesting that the EPA suspend the registration of Rozol Prairie Dog Bait based on the AVMA policies regarding Toxicoses and the Conservation of Wild and Exotic Animals. The AVMA is concerned about the use of anticoagulants for this purpose because of the unintended consequences associated with them. The AVMA provides the following grounds for support of WWF's petition:
- There are numerous data gaps and unanswered questions which need to be addressed regarding the use of Rozol for this application.
- There are other prairie dog control options with are safer and effective.
- The use of Rozol for this application is associated with deleterious effects on non-target species, including federally listed species.
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