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Location
Corpus Christi, TX
Start Date
9-4-2007 12:00 AM
Description
In the Environmental Protection Agency's proposed mitigation measures (published 1/17/07, Federal Register), we can see the precautionary principle in action: "When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically" (Ashford 1998). EPA's proposed measures would classify all second-generation anticoagulant rodenticides as "restricted use," so that they cannot be sold to the general public. This proposed restriction will diminish the ability of consumers to control rodents in their own residence, and will disproportionately affect minority and low-income citizens in the large cities of America. EPA's analysis fails to properly account for the potential impact on public health and other social costs of their mitigation proposal. The EPA's analysis does not show that second-generation anticoagulant rodenticides present a significant hazard to non-target wildlife. At best, it simply makes a case that primary and secondary hazards are possible. It does not allow any conclusions about the actual risk posed to wildlife. Liphatech (and other manufacturers, through the Rodenticide Registrants' Task Force, RRTF) have proposed alternative mitigation measures to address both risks to wildlife and risks to children, while preserving the public's access to the most effective rodent control pesticides. The proposed alternatives include: limiting consumer rodenticide use to inside of buildings, using bittering agents in consumer products, directing consumers to use smaller bait placements, using label language that is more clear and understandable to the consumer, providing consumer education through internet sites and point-of-sale signs/brochures.
Recommended Citation
Schmit, T. (2007). Rodenticide restrictions: The precautionary principle in action. In Nolte, D.L., Arjo, W.M., & Stalman, D. (Eds.), The Twelfth Wildlife Damage Management Conference (134-138). Corpus Christi, TX: National Wildlife Research Center.
Included in
Rodenticide Restrictions: The Precautionary Principle in Action
Corpus Christi, TX
In the Environmental Protection Agency's proposed mitigation measures (published 1/17/07, Federal Register), we can see the precautionary principle in action: "When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically" (Ashford 1998). EPA's proposed measures would classify all second-generation anticoagulant rodenticides as "restricted use," so that they cannot be sold to the general public. This proposed restriction will diminish the ability of consumers to control rodents in their own residence, and will disproportionately affect minority and low-income citizens in the large cities of America. EPA's analysis fails to properly account for the potential impact on public health and other social costs of their mitigation proposal. The EPA's analysis does not show that second-generation anticoagulant rodenticides present a significant hazard to non-target wildlife. At best, it simply makes a case that primary and secondary hazards are possible. It does not allow any conclusions about the actual risk posed to wildlife. Liphatech (and other manufacturers, through the Rodenticide Registrants' Task Force, RRTF) have proposed alternative mitigation measures to address both risks to wildlife and risks to children, while preserving the public's access to the most effective rodent control pesticides. The proposed alternatives include: limiting consumer rodenticide use to inside of buildings, using bittering agents in consumer products, directing consumers to use smaller bait placements, using label language that is more clear and understandable to the consumer, providing consumer education through internet sites and point-of-sale signs/brochures.