Formal title: Docket Number [EPA-HQ-OPP-2009-0815; FRL-8802-3] Receipt of Petition Requesting EPA to Classify all Rodenticide Products Containing Strychnine as Restricted Use Pesticides
Notice of Comment Period
The EPA has published for public comment a July 9, 2009 petition from the State FIFRA Issues Research and Evaluation Group (SFIREG), available in docket number EPA-HQ-OPP-2009-0815, requesting that the Agency classify all rodenticide products containing strychnine as Restricted Use Pesticides.
The AVMA supports environmental responsibility including understanding control and prevention of the environmental impacts of chemicals and products that may negatively effect the environment, which includes animals and humans. Similarly, the AVMA supports education, legislation, regulations, research, and other actions that prevent toxicoses in wildlife, domestic animal, and human populations. Strychnine is highly toxic and nonselective, an extremely dangerous combination to non-targeted species (including humans and family pets) when used inappropriately, whether inadvertently or maliciously.
While acknowledging the current need to keep these products available for their intended purposes, the AVMA agreed that individuals who utilize these rodenticides should have specific training or education to do so. The classification of strychnine-containing rodenticides as Restricted Use Pesticides (RUPs) would help ensure the appropriate applications of these products and the accountability of those who use them while maintaining product availability for approved purposes. In summary, the AVMA supports the petition made to the EPA by the State FIFRA (Federal Insecticide, Fungicide, and Rodenticide Act) Issues Research and Evaluation Group (SFIREG) "to classify all strychnine-containing rodenticides as Restricted Use Pesticides (RUPs)."