Rodenticide manufacturer defies EPA, requests hearing on anticoagulant use

Pesticide manufacturer Reckitt Benckiser Inc., maker of the rodenticide d-Con, has reached a face-off with the U.S. Environmental Protection Agency (EPA) after defying new regulations that, according to veterinary toxicology experts, could prove harmful to pets.

Reckitt Benckiser has been noncompliant with the EPA’s 2008 risk mitigation reforms, enacted in 2011, which require manufacturers to stop using long-acting anticoagulants in products meant for residential environments. As a result, the EPA notified the company in mid-February that it intended to cancel 12 of its products.

On March 7, the day before the EPA ban on d-Con’s products was to take effect, the manufacturer requested a hearing before an EPA administrative law judge, effectively delaying the ban until the hearing is completed.

Conflicting safety concerns

While the EPA states that the anticoagulant products “pose unreasonable risks to children, pets and wildlife,” toxicology expert Ahna Brutlag, DVM, MS, a diplomate of the American Board of Toxicology and assistant director of veterinary services for Pet Poison Helpline, says she’d rather contend with d-Con, all things considered. “I’d like to see long-acting anticoagulants kept on the market for in-home use for consumers. I think that is the safest option in regards to pets and wildlife exposure,” Brutlag says.

The new breed of rodenticides spawned by the EPA prohibition use the neurotoxin bromethalin. The rapid onset of bromethalin gives veterinarians little time to intervene if a pet has ingested it. And unlike anticoagulants, which can be treated with vitamin K, bromethalin has no diagnostic test and no antidote.

D-Con says on its website that the use of more potent rodenticides such as bromethalin could “increase the risk of serious harm and potentially death if these products are used improperly.” The company also says using less-effective products would impact public health by making rodent infestations more difficult to control. “EPA’s actions would leave consumers with fewer alternatives which, ironically, puts the public health and environment at greater risk,” says Hal Ambuter, Reckitt Benckiser’s director of regulatory and governmental affairs for d-Con.

Reckitt Benckiser argues that residential consumers should have the choice to use anticoagulants if that’s the most effective way to control a rodent infestation. In fact, Ambuter says d-Con was granted registration for a tamper-proof bait station and hoped the EPA would continue to allow its products for residential use if the anticoagulant was contained. “We applied for an anticoagulant bait in a tamper-proof bait station but were surprised and disappointed that the EPA rejected that registration,” Ambuter says.

However, Reckitt Benckiser’s overarching position is that loose bait should be allowed, while the EPA reforms require that nearly all consumer products be tamper-resistant for children and dogs. “Use of a bait station that substantially reduces exposure to the bait plainly poses less risk to children, domestic animals and nontarget wildlife,” the EPA says. Reckitt Benckiser claims that bait stations are less effective in controlling rodent infestations. And Brutlag says they’re not even that effective in preventing poisonings. “We’ve been looking at that really closely,” she says. “We’ve found that when animals are exposed to new risk mitigation products, a large percent are getting into the bait itself.”

Dogs often chew through the bait stations or the plastic bags in which rodenticide blocks are packaged, Brutlag says--and these bags hold up to a pound of blocks. Also, she says consumers with a rodent problem often disregard safe practices; they set the bait station out but also set out loose blocks as well.

In addition, Brutlag says, many rodents are suspicious of bait stations--rats in particular. Dogs, however, seem to have no reservations. “When we see dogs get into it, they seem to eat as much as they can,” she says. “Would [bait stations] deter them? Dogs will eat anything. I honestly don’t know if that would change the outcome here.”

Brutlag also says that cats, while fairly tolerant of anticoagulants, are highly sensitive to bromethalin. “I’m glad not to see bromethalin pellets being sold for the home,” she says.

Products still available--for now

In the meantime, consumers will be able to continue buying anticoagulant rodenticides. The EPA expects the hearing requested by d-Con’s manufacturer to start later this year, “likely several months from now following prehearing proceedings such as prehearing conferences and discovery,” the agency said in a late March e-mail to dvm360.

Brutlag concedes that a return to preregulation standards may be impossible. If the EPA carries through with its cancellation of d-Con anticoagulant products, “almost all in-house container-based rodenticide will be bromethalin,” she says. Her solution for now is to continue to educate pet owners and veterinarians about the EPA’s changes and the dangers of rodenticide posioning.

The EPA says Reckitt Benckiser’s refusal to implement the 2008 reforms is the first time in more than 20 years that a company has declined to voluntarily implement EPA risk mitigation measures for a pesticide product and requested a cancellation hearing. It is also the only company--out of nearly 30 rodenticide producers--to refuse to adopt the measures.

To view a list of the d-Con products scheduled for cancellation, go to epa.gov.