Rodenticides, proposed rules, and raptors

The US Environmental Protection Agency is seeking input on new rules restricting rodenticides. As points out, wildlife and pets are in daily danger of being poisoned when homeowners, businesses, and exterminators use anticoagulant rodenticides, aka rat poisons, to control rodents. This puts many birds of prey at high risk for secondary poisoning, including California condors, turkey vultures, great horned owls, barn owls, red-tailed hawks, and American kestrels. While bald eagles don’t eat many small rodents, we’ve seen our eagles take a mouse or two and rodenticides are sometimes used to kill prairie dogs, which are frequently taken by bald eagles that nest near prairie dog towns. Curious about what we know about anticoagulant rodenticide incidents in birds? Keep in mind that most incidents aren’t reported when you look at this table. Yikes!

Can rodenticides be severely restricted or banned without adverse effects on human health and life? California began prohibiting the use of second-generation anticoagulants (with some exceptions, including medical and food production facilities) on January 1 of 2021. Note: they had a little push from Raptors are the Solution:

This is something we could do nationwide: second-generation anticoagulants aren’t safe and we have a lot of options for rodent control in our homes and businesses. Even better, raptors can be an important part of the solution. lays some control ideas out for us here: and tells us how raptors help here:

Provide input to the EPA here: I encourage everyone to read through this blog for more information prior to commenting. 

Back to the EPA! Their proposed changes include:

  • Classifying more rodenticides as restricted use (RUP) pesticides, which means that the public and non-certified applicators won’t be able to buy them. This includes all second-generation anti-coagulant rodenticides (SGARs), strychnine, and zinc phosphide, and all first-generation anti-coagulant rodenticides (FGARs), bromethalin, and cholecalciferol products sold in packages ≥ 4 pounds. Brands include D-Con, Mouser, Ratak, Talon, Final Blox, Havoc, Contrac, Maki Mini Bloc, DeciMax, First Strike, Hombre, Wilco Zinc Phosphide Gopher Bait, ZP Tracking Powder, ZP Mouse, Prozap, and D-Kill Rat Bait Blocks.
  • Requiring mandatory carcass search, collection, and removal for restricted use products used outdoors. Brands include those listed above, plus Kaput Rat & Mouse Bait, Rodex, Got Pests, Get Revenge Refillable Mouse Bait Station, Rozol Pocket Gopher Bait, Ratol, Ground Force, DITRAC All-Weather BLOX; D-Con Bait Station, Ramik Mouser RF Kills Mice, Rodentex, Wilco Ground Squirrel Bait, Ramik, Tomcat, Eratication, and JT Eaton Bait Block. Amy’s note: I don’t know why search, collection, and disposal aren’t required period. Several of the listed rodenticides remain in dead tissue, which endangers scavengers, and dead animals would seem to me to represent a human health hazard. 
  • Requiring mandatory reporting for dead and dying non-target organisms. Amy’s note: like a great horned owl family, a red-tailed hawk, or a family pet. The Tier I Update Review of Human Incidents is pretty interesting reading, if by interesting you mean ‘awful’. Although human incidents tend to get reported. 
  • Requiring mandatory carcass search, collection, and removal in the ranges of three endangered species: the California Condor (the condor is protected from lead and rodenticide in California, but there are a few small populations outside of California), Attwater’s Prairie Chicken, and the Stephen’s Kangaroo Rat.
  • Prohibiting spot and broadcast use of FGARs and non-anticoagulant rodenticides in turf, lawns, golf courses, parks, campsites, and other recreation areas. Limit site managers to bait station and below-ground rodenticide applications and mechanical traps. Amy’s note: Not sure if or how this applies to SGARs. Again, check out the Tier I Update Review of Human Incidents!
  • Restricting use of FGARs in spot, broadcast, and burrow applications in and around bearing orchards, vineyards, and other cropped land, as well as in pastureland and rangeland.
  • Requiring elastomeric half mask respirator (PF10) for products that are granules, tracking powders, grain meals, and waxy/paraffinized and non-paraffinized pellets.
You can help the proposed changes become rules by submitting a formal comment in the Federal Register by February 13, 2023: (and click the green ‘submit a formal comment’ button on the right-hand side of the page). We could do even more – California set a great example! – but this is a start. 

You can help raptors and pets by using control methods that aren’t rodenticides: and insisting that any rodent control company you, your business, or your HOA hire uses non-toxic methods: And you can learn more about all of it here: Thanks to Karla Bloem of the International Owl Center for the excellent resource!