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Hey, welcome back. Welcome back to another edition of the Pest Geek Podcast. I am your host, Frank Hernandez. Hey, we’re gonna be discussing proper selection of exterior tier one, tamper resistant rodent bait stations. And we’re going to be tackling the law and some myth and facts on this podcast. So this is one of those that is a thorn in the side of a lot of people, both in the professional pest control industry and also those of us who are looking out for our customers, looking out for the environment, looking out to do what is right. And the things that are going on in our industry are unprecedented, like any other time in history of the amount of problems that we have to encounter as professionals and a lot of it that is caused not by us, that we have nothing to do with lot of regulation coming out of California, that they’re wanting to get rid of the use of second generation rodenticides. And a lot of it has to do with the misuse and misapplication of a lot of these products. It has nothing really to do with a lot of professionals. Yes, there are professionals that we’re encountering that are doing things that are wrong, that are doing things that aren’t legal. There aren’t kosher, there aren’t ethical. They aren’t moral because they’re trying to cut costs or they’re trying to cheat. But that is not the majority of the industry. That is just a couple of people.
Top 3 Myths About Exterior Rodent Stations
Myth #1 Exterior Bait Stations Must Contain A Weight!
Fact No,
Myth #2 it must be of a certain weight like 8 lb
Fact, No
Myth #3 There are standards for testing Tamper Resistant Station
Fact, No
The biggest problems I have with rodenticides
has to do that. They’re being sold over the counter to individuals, homeowners. You know, managers, anybody who wants to get a rodenticide get it without having to comply with the federal requirements and the label. I mean, I’ve seen this in apartment buildings where apartment managers are giving their staff rodenticides to go put out and put out rodent station and put out bait packs and throw them in homes, in storage units, storage facilities where managers are going out and putting bait packs out in the open.
And the corners of storage facility, storage rooms, with no regard to what the fact that that label says that it must be kept out of reach of children. My biggest scare is the use of and a non anticoagulant, which is actually a neurotoxin being used and being available too non-professional when there is no antidote for this product, and you can easily buy it, you can’t buy it in stores, but you can buy it online. And that is a major concern.
One of the biggest myths that I’ve challenged people on this week and all groups I’ve been out there and I said, you know, what is the weight requirement for a tier one station outside? So that a child can not get into it.
And the reality is there’s mixing answers. Nobody has the real answer, but the answer is actually in the EPA, its own Web site. Here’s the myth, number one. An exterior bait station must contain a wait. No, it doesn’t. There is nothing on the law that says it must contain a weight. I can’t find it. I’ve asked people who are professionals that deal their distributors in manufacturers. This question. Nobody has the answer. There isn’t any. Myth number two, it must weigh at least eight pounds. No, it’s nowhere. Myth number three. There are standards for testing tamper resistant stations. And what is the standard and what is considered tamper resistant? And the fact is that there is no standard for testing. There are only guidelines to follow in the manufacturing of stations. But there is no standard for testing them. So now we get into what is the law?
What does the law actually say?
Well, who is the law? Well, it’s under the FIFRA act.
And in in, in, in in September 16 of 1994, Article PRN 94-7:, which says the label improvement program for the revision of use Directions for commercial rodenticide and statements of the agency’s policy on the use of rodenticide bait stations. And what does it say? I’m reading this is all I’m getting is directly from the EPA and the law. This is not from any manufacturer. This is not from a university. This is directly from the horse’s mouth. And here’s what the law says.
Notice requires registrants of certain pesticide products claim to control commercial rodents and registered under the federal insecticide fungus, fungicide and rodenticide act. To revise the labeling of such products, to bear certain statements concerning tamper resistant stations.
Let me give you a little bit of background on on statistics of what is happening with rodenticides and why the danger?
More than a thousand incidents of human exposure to rodent poisons have been reported annually in the U.S.. This is from the EPA.
In 1988, more than 10000 roadside incidents were reported in the American Association of Poison Control Centers. National data collection system. 90 percent. Of these cases involve children under the age of six. Nearly all such exposures are classed as accidents, meaning they weren’t trying to commit suicide.
That’s what they’re they’re referring. The human exposure incidents that are reported in may represent less than half of those which occur, meaning there are more, but they don’t go on to report it.
Over 80 percent of reported human or identified exposure involves anticoagulant compounds. Either neither one or two.
Dog incidents account for more than 80 percent of the reported exposures of non target animals to commercial readiness sites.
So children under six. And pets.
Are about 80 percent to 90 percent of all the reported cases.
This is the reality of why these went into place.
Who are the greatest violators of this? Well, the reality is that the greatest violators of this is people. Buying rodenticides in their home, using them. And not knowing how to use them. Having no training in what an anticoagulant does to a child when it eats it, where where the person starts bleeding internally, causes internal bleeding. And then not to mention that even if you are able to reverse and stop the internal bleeding. We still don’t understand what the damage to organs are when this happens. Yet I find it all the time where I go into homes and I find loose bait everywhere. And I asked them where they got it. Well, a friend of mine gave it to me. I bought it over the counter. Worst yet. My pest control guy gave it to me. That is what’s happening with rodenticides.
And the danger that people have that they don’t understand, throwing loose rodenticide in attics, throwing loose rodenticide out in the yard, throwing loose rodenticide inside the home. Where I go in and I’ll see it, and they think that because they’re able to buy it over the counter, here is the thinking.
That because they’re able to buy it over the counter, It can’t really be that dangerous. That is the number one fallacy that we have. We’re now where you have DIY stores appearing everywhere and people can buy this. And this is where we as professional pest control people.
Ok.
That have to go through training, that have to go through certification, that have to go through these classes to know how to properly apply them. All that three training gets thrown out the door and laws get passed because people have access to it, and that should have never had access to them.
And the problem isn’t every manufacturer in the world sells to these online distributors where homeowners are the primary target of being sold to these products.
But the reality is that the law doesn’t affect them because the law only affects the application of the product, not the sale and distribution to a certain extent.
So what is the criteria? For these stations. What is it? Well, here here is the criteria.
Here is what the EPA says I’m reading directly from their site, I got links to all of this guys that I’m gonna give you so that you can see it.
The revised criteria for tamper resistant bait stations are as follows.
Resistant to destruction or weakening by elements of typical non catastrophic weather, i.e. rain, snow, extremes of temperatures, humidity and direct sunshine.
Number two, strong enough to prohibit the entry or destruction by dogs and by children under 6 years of age using their hands, feet or other objects commonly found.
In the environment, i.e., sticks, stones, broken glass, etc.. Stations stronger than tamper resistance are needed in areas frequented by hoofed livestock, raccoons, bears and other potentially destructive animals.
Or in areas prone to vandalism.
This is what’s commonly known right now as a tier one station.
Now, number three, capable of being locked or sealed so that the children and non target animals can not gain access through the opening. Or procedures used to fill base compartments.
Number four, equipped with rodent entrance, which a readily allows target animals access to the bait, deny such access to other animals larger than half.
I’m sorry. Then adult of the target species and discourage entry by birds means for achieving these ends might include the use of baffles, mazes or small entrances.
Number five, capable of being anchored securely to resist effort to move the station. Or to displaces contents or equipped with a mechanism such which virtually prevents bate from being taken out of the station after it has been moved. All right.
Let’s stop there for a minute. Because it doesn’t stay. It needs to be anchored. It says capable of being anchored to resist the effort to move the station or to displace its content.
In other words, if a child that is 6 years old can pick up that station and shake it and get the bait out because the bait can break. How many of you know that if that bait is in sunlight. If you’ve got a wax bait? And it’s in direct sunlight. And it’s on the cross bars of a metal rod and it gets hot. That bait going to cut that metal rod is going to get hot enough for that bait going to melt cut right through and the bait is going to be loose in their. And now a child can come and shake it and get the bait out who is six year old.
So it needs to have the capability of being anchored. The question now becomes, here’s the question, what defines anchoring? Because there is no definition of anchoring. In other words, if a bait station comes with an eight pound weight. And you have a bunch of Rottweilers in that backyard. Is that enough to anchor that station so that Rottweiler can not toss that station around and remove the content that is inside? Second of all, is eight pounds enough for a child not to be able to lift it up while my son at four years old could carry a gallon of milk, which is eight pounds. So it is now. Is that adequately anchored so that the child cannot move it? Second of all, if you use like I’ve seen in a lot of places where people use basically, you know, contractors, cement, glue to glue the station to the concrete and now it went through a season of heat and cold and it gets kicked. And it easily becomes unanchored and you’re on a quarterly service. How long does that station stay unanchored before anybody notices it? And now you have a you have a liability problem. Let’s say the like I have here many pictures and videos of.
Pest control guys making their own stations because they don’t want to spend the money. On a professionally weighted station that has been manufactured by a professional company. He’s making his own and he will put a brick underneath it with weighs less than a pound. It is not adequately anchored. You now have exposed yourself to a liability. Now you violated the law. You have a liability potentially. A child can get injured or die. And let’s say he did use. A product that does not have an antidote.
Now you have the potential property owner exposed also to a lawsuit. Because of this and this is the problem that we’re having, this stuff is being sold everywhere to anybody, whoever can buy it with no training and no knowledge.
I don’t have a problem with a lot of the products being sold.
I have a problem with when an a product is under such contention. In a state like California where they’re wanting to get rid of second generation anticoagulants. That all these products are still being sold and easily access by people who do not read labels.
When it clearly states on the label keep out of reach of children. It’s on every label. Children are not supposed to have access is access to it when you buy a Tier 2 or a Tier 3 station for indoor and you put it in a corner and there’s bait inside and you can clearly see the bait and then you drop the station and accidentally shatters the bait and the child is able to shake the bait out of there.
This is what people aren’t considering. This is what adults aren’t considering the cut the term common sense is not common when it comes to pest control. You can not apply common sense to common sense has been through it everywhere. Apply it anywhere. Do anything you want with it. Because if it’s sold over the counter, it cannot be dangerous.
Here’s number 6, equipped with an internal structure for containing bait and minimizing spillage. Tracking of bait outside of the station and into readily accessible parts of the station.
Now you have stations that have rods that if you push the beat down in there, it cracks the bait open. You can’t do it.
Made up a number seven made of a design and color that is not especially attractive to children, most of them are black or grey or white, and they’re capable of displaying precautionary statements in a predominant location.
These criteria for tamper resistant base stations identify the performance features required of a base station by labeling when commercial or comments or roadside baits are applied. An area is accessible to children and non target animals. No label requirements for using tamper resistant base stations apply to those who place bait.
Not to bait station manufacturers. Note read this again. Note The label requires for using tamper, which resistant base stations apply to those who place bait, not to bait station manufacturers. EPA has no direct regulation authority over the production and the sale of bait stations unless they are sold with a rodenticide bait.
In other words, if somebody orders a bait station now from China. Which are not tested or approved. And the bait goes inside, you violate the label because it isn’t. Regulate the manufacturing of the station is not regulated, but the bait. But if the person does not read, the label doesn’t know, they can’t just put it in there. They violate the label. They violate federal law. That’s a problem.
OK, so now it says, here’s what the label said. I mean, what the law says according to this document.
Of what must be done. To apply a bait correctly. It is a polite bait in locations out of reach of children. In locations out of reach of children, pets, domestic animals and non target wildlife or in tamper resistant base stations, so in other words, you can put it behind a wall. That’s out of reach of children. What happens if you forget that that baby is back there? And what happens if somebody opens up the wall or opens that area where it was out of reach of children? A year from now, two years from now. And a child thinking that bag. Of bait pellets is pop rocks, and he sits there and eat them. Because you forgot.
See the problem?
Who is going to come here at this location and mess with my station?
These stations must be resistant to destruction by dogs and children under the age of six. Destruction by dogs. I mean, I’ve seen dogs that can eat through through an aluminum wheel.
You have to then use judgment and say, I can’t put this station if I have a pair of pit bulls. That chew through everything because eventually they’re going to chew through the station or damage it in a way where I can. It can be opened.
It says must be used in a manner that prevents such children from reaching into bait compartments and obtaining the bait. If bait can be shaken from stations when they are lifted, unit must be secured or otherwise immobilized. Even stronger baits. Stations are needed in areas open to hoofed livestock, raccoons, bears and other potentially destruct. So now you’ve got raccoons in your area. You might need a stronger station than a Tier 1.
What happens? If maybe you have a property. Where there’s a mentally. Challenged person who can’t understand what that is. Grandpa has dementia.
Grandpa decides he’s going to play with the rodent bait station. See, as a professional pest control guy. We got to think of all these things. Who is going to come here at this location and mess with my station? If, if, if if it can be moved by the end, then it has to be anchored. See if the weight isn’t enough. Then you have to anchor it.
So now let’s talk about different tiers. Which are the teirs allowed? Well, according to this document, ready to use bait stations, Tier 1. Ready to use bases now? You got to define what ready to use is.
Have been shown to be resistant tampering efforts by young children and dogs and are considered to be weather resistant may be used indoors and outdoors within 50 feet of the building.
That’s what’s on their website right now. In some other site, another page you’re going to read, it’s one hundred feet. But 50 feet right now is what’s on their Web site. You can’t put a rodenticide a hundred feet from that house. One hundred and fifty feet are two hundred because the rodents are in that area.
Because it’s a Tier 1 station, tier two stations ready to use bait stations have been shown to be resistant tampering by young children and by dogs, but cannot be used outdoors because they are not considered to be weather resistant bait stations.
In other words, you can’t buy a small little station that says only to be used indoor and then throw them all over the yard because they’re inside a station. When a dog can bite through that plastic. Or water can get in.
Tier 3 ready to use bait stations have been shown to be resistant to tampering by young children and can be used indoors in areas which pets have no access. Just because it is in a station doesn’t mean you can still just throw it out there. Tier 3 ready to use bait stations either have been shown to be tamper resistance or two have not been tested in that regard. Therefore, Tier 4 stations meant or may only be used indoors in areas to which young children and pets have no access, including residences where no young children or pets live or visit.
What is the potential risk that we’re running by installing a bait station in a client’s
So now you’ve got to think about, well, they don’t have their old they don’t have children. Well, they have nieces and nephews and they have grandchildren that come over. And the customer told, oh, there’s no children in the house. I don’t have any children here. But they come over, see, we have to be able to think through all of this. And say what is the potential risk that we’re running by installing a bait station in a client’s home with. And then I find that I go into the client and the client moved my stations my way, did say because he decided he thought it would be better to put them over here or he took them inside the home.
And this is why I only use certain types of products in my station. Where I don’t run the risk of the client moving my stations because he thought he knows more about this than I do. When I have to sit here, read through all this legalese that he won’t do that, he wants to even if I send it to him on this podcast, he still will not listen to them.
Bait station tests have been dealt primarily with young children and dogs.
Under the standards and protocols for testing base stations. Here’s what the EPA says. The EPA has received relatively little information regarding the elements to be included in protocols for testing base stations or on performance standards for bait stations, several bait station manufacturers have consulted with EPA staff regarding tests for evaluating protective qualities of bait stations. These tests have been dealt primarily with young children and dogs. The non target arm organism for which the largest number of rodenticide exposure poisonings have been reported. In other words, children and dogs are the number one target of rodenticides where they have the most problems and tests done to date. Children and dogs have been given an incentive to enter. I’m sorry.
In tests done to date, children or dogs have been given incentive to enter bait stations sealed and secured as they should be in rodent control operation, in other words, they’ve given it to children and dogs to play with and said, get this thing open like you normally would. Several manufacturers have had their stations evaluated, according to an adapted CPR testing procedures, CRP testing procedures.
Epa has concluded that ist should draft standards and protocol for bait stations.
But that testing, according to these methods, should be performed in the private sector at the expense of the bait station manufacturers. Through cooperation with these manufacturers and other interested parties, EPA believes that the protocols can be refined that are agreements on appropriate adjustments to test procedures and performance standards for temporary assistance stations can be reached. In other words, right now there is no standard for testing by the EPA.
So now. They’re using judgment.
Is highly important in our industry. This is why we have such a difficult time hiring people that have a poor use of judgment because we got to entrust them. With the lives of our company, the lives of our client. Their pets, their children to do the right thing, even when the customer is telling them to do something contrary to what is legal, ethical, moral and allowed to be done by the label.
This is the problem when the information is out there and customers can interpret them. And this is the big beef I have when I’m consulting a client and he’s telling me up a, can you do this? Can you? This. No, we can’t. Because here’s the legal ramification, bromethalin 1 percent active ingredient. With no antidote. Is available to be bought over-the-counter. And what the customer reads that there is no antidote somewhere. It’s code word to an uneducated person that says this is the strongest.
How many times do you get that question asked to you by a client? I want the strongest thing. You have to get rid of this. I want a fumigation. I want a tent. The place. I want to burn it to the ground. And they will read this and say, ah ha, this must be the strongest thing available. And they won’t read the label and they’ll put it out. And there’ll be a poisoning and nobody can save the dog. This is why I don’t use bromethalin. In residential applications, only if I have to win a commercial, I still don’t use it. I’ve tried to use it. I’m very uncomfortable using it for these reasons.
It’s not stronger. It’s a different mode of action and you’re putting yourself at risk by using it incorrectly. You’re putting your customer, if the customer is putting his family at risk by him using it and not understanding what he needs to do.
What does the law say? Readiness sites and readiness side products for consumer use. Here’s the issue with eight pounds, 16 pounds. How much money? It has nothing to do. I can’t find it anywhere. Now, however. How they are sold is important.
These products that I’m reading from the EPA Web site. These products include rodenticide bait registered for the use by professional applicators to control rats or mites in or near 100 feet of a building and other structures for the use in or near agricultural buildings, manmade agricultural structures. They may contain one or more of the active ingredients under the types of rodenticides mentioned under the types of worthiness sites.
Now, listen, products geared.
To these categories of users are not to be sold in consumer stores, including drugstores, grocery stores, hardware stores, club stores or similar retail outlets. However, it mentions nothing about being sold online.
We got a problem. Houston.
Products containing second generation anticoagulants must be sold in containers holding at least 16 pounds of bait. Second generation must be sold if they are labeled for use by professional applicators at at least eight pounds of bait. If they’re labeled for use near agricultural structures.
So now a homeowner goes online buys the cheaper product that contains bromethalin
In the eight pound container, because it has a label for agricultural use and applies it to their home, they’re in violation of federal law, putting their family at risk, putting everybody around them at risk. Yet they have no restriction to do this when it says, hey, it can’t be sold in stores, but you can buy it online. The bait products marketed. Listen to what it says professional agricultural use products containing first generation anticoagulant, bromethalin. And zink phosphide and also containers must contain at least four pounds of bait.
Oh, wait, bromethalin can be sold with no. antidote that people don’t know about. In a four pound bucket.
They products marketed to these categories may be in block paste, piloted form, piloted form. These products are not packaged. In with others and with stations, however, the label for these products may require the use of temporary assistance stations. If bait is to be placed in any indoor outdoor application location to which children under 6 years of age pets are not targeted, while I have access, all applications made outdoor and above ground base stations suitable for using these bait products in such areas are commercially available. Baiting of birds outdoors is permitted only for pellets baits that are placed at least six inches down.
In the active rat birds, this is all directly from the EPA.
These are the concerns that we as professionals who take the training, who have to have a lawyer draft up our documents, who have to read this stuff and interpret it.
And protect people. From pest. And being accidentally poisoned.
We are environmentalists
That’s our job. We are environmentalists. And nobody sees us as that. Yet you can go and buy it over the counter, pollute everything, contaminate everything. Don’t have any adherence to the label, which is a federal document. Get it sold to you, which is 80 percent of the pesticide applied, 80 percent of homeowners will do their own pest control, while only 20 percent hire a professional.
And this is where I have the problem. I don’t have the problem that most people have that they’re taking away or business. I don’t have an issue with that. I have an issue with the safety.
I have an issue with what is happening that nobody is talking about openly. This is the stuff that you’re not gonna publish in any industry magazine. It’s not going to be published by any of the associations, National Pest Management Association has not addressed this issue. Why? Because they have to take money from every manufacturer in the world.
PCT ime magazine isn’t gonna publish anything on this. Pest management professional isn’t gonna publish anything on this.
The ones that are talking about it in groups were kooks.
But yet here is the real problem. And a rodenticides are under fire and we’re going to use the availability to use a lot of them because a lot of these shenanigans yet.
You know, they’re still being sold. I don’t have a problem, like I said, and nobody and nobody is taking away by business. My customers are my customers.
we’re about protecting people. Property plants. And planet.
It is the problem that a homeowner trying to educate now. Homeowners trying to educate apartment managers, property managers, people who have access that are giving this product directly to their people, not understanding the liability they’re under. That when something happens, it’s not only going to be EPA up there, butt. It’s gonna be OSHA, Yeah, it’s gonna be everybody involved and somebody is gonna be made an example of. To stop this problem because somebody violated the law. And do you want it to be your business? Your company, you wanted to be your national retail chain. Do you wanted to be your apartment building, your HOA that gets, you know, in a lawsuit because of this? This is the question that I’m asking. This is the information that I’m trying to get out to people. To protect people. Forget about being self protectionist in the industry. That’s not even the case. It’s about protecting people. This is the business we’re in, we’re about protecting people. Property plants. And planet.
So I hope this makes sense to you guys. Until next time. Hey, have a pestacular day.
PRN 94-7: Label Improvement Program for the Revision of Use Directions for Commensal Rodenticides and Statement of the Agency’s Policies on the Use of Rodenticide Bait Stations.
The revised criteria for tamper-resistant bait stations are as follows:
Choosing a Bait Station Product for Household Use
https://www.epa.gov/rodenticides/choosing-bait-station-product-household-use
Restrictions on Rodenticide Products
https://www.epa.gov/rodenticides/restrictions-rodenticide-products
