CCWR ACTION ALERT: Your Help Needed to Prevent Secondary Poisoning of Wildlife

Dear Members,

We currently have chance to stop the poisoning of our nation's wildlife - by sending letters to the EPA.

Second generation ("single-feed") rodenticides are designed to provide a lethal dose to rodents in a single bite. However, because the poison takes up to a week to kill the rodents, they often feed multiple times. The result is that rodents become so toxic that they kill the wildlife that eat them.

The recent case of a Red-Shouldered Hawk that was poisoned in Golden Gate Park has brought much needed media attention to this issue. In San Francisco, media coverage about hawks dying from eating poisoned rodents brought about an immediate, but temporary ban on the use of the single-feed rodent poisons being used outdoors.

The EPA has laboratory documentation that eagles, hawks, falcons, fox, mountain lions, and all other species that eat rodents and carrion are dying from eating rodents poisoned with single-feed rodenticides. The EPA document (link here) lists a variety of endangered species that have died from eating rodents poisoned with these poisons.

However, with these facts before them, they are not proposing to do anything to protect our wildlife from secondary poisoning from eating poisoned rodents.

Please send the attached letter to the EPA, or write a letter of your own. Tell the EPA that killing endangered species and other non-target wildlife for the sake of killing rodents just doesn't make sense. Wildlife rehabilitators are in a unique position to be able to provide the EPA with numbers, statistics and stories of secondary poisoning cases in rehabilitation. Please be sure to include in your letter any information about poisoned wildlife you have received.

Urge the EPA to protect our wildlife from secondary poisoning by prohibiting "single-feed" rodenticides from being used outdoors where wildlife are at risk of eating poisoned rodents.

We have included a sample letter below that you can customize as you like. Please visit our website for more information on this topic, sample letters (in Word and PDF format), and a links to the EPA document.

The public comment period ends May 18,2007, so please act quickly!

Thank you for making your voice heard for wildlife!

The CCWR Board

Sample Letter

Dear EPA,

Thank you for this opportunity to submit comments on the critical issue of reducing the negative impact that rodenticides have on our wildlife and children.

Removing cardboard boxes of colored poison pellets from the shelves of supermarkets and hardware stores is necessary to prevent small children from eating these pellets. Thank you for working with industry to design tamper-resistant bait boxes that hold an affixed solid block of poison inside.

I hope that you will also require that second generation rodenticides be labeled for use only in solid block form, affixed within a tamper resistant bait box. This is not currently stated. Primary poisoning of non-target wildlife and children can occur if pellets are spilled from containers either during placement or if disturbed by people or animals.

Thank you also for implementing programs to assist people in low-income housing complexes identify and close rodent entries into buildings, and identify and remove open food sources. More of these programs are needed.

What has not been addressed is the loss of endangered species and the multitude of other non-target species that are dying from secondary poisoning after eating rodents poisoned with second generation "single -feed" rodenticides. This critical problem must be addressed in a substantive manner.

Killing bald eagles, peregrine falcons, endangered California kit foxes, and all other wildlife species that eat rodents or carrion, for the sake of killing rodents just does not make sense, and must not be allowed to continue.

These rodenticides must not be allowed for outdoor use where wildlife are at risk of eating the poisoned rodents. Labeling second generation rodenticides for indoor use only would limit wildlife exposure to only those rodents that are poisoned indoors and die outdoors. This measure is necessary to reduce the terrible problem of secondary poisoning.

Industry will still sell first generation rodenticides for outdoor use. These rodenticides have considerably less negative impact on wildlife and the environment.

The EPA states that poisoning outdoors around open food sources is not an effective means of reducing rodents congregating to eat food left out at night. Closing an open food source is the only solution to removing rodents from the area. Most restaurants and food markets are unaware of the effect the poison they pay to have placed is having on the environment. They rely on the EPA to dictate to industry what products are appropriate to use.

Pest Control Operators/Applicators will continue to refill poison bait boxes with second generation rodenticides around nearly every dumpster across our country unless these rodenticides are restricted to indoor use. Our environment will continue to be littered with the bodies of rodents toxic enough to kill the animals that eat rodents and carrion unless these rodenticides are restricted to indoor use.

Wildlife rehabilitators were not notified that there was an EPA hotline to report wildlife poisoning incidents. Wildlife rehabilitation centers across the country receive poisoned raptors and mammals. While the symptoms and blood work easily confirms poisoning, some animals that have died have been tested. Brodificoum, difetialone, and bromodiolone are the poisons reported consistently by the labs.

While the vast body of evidence cited in the EPA documents of secondary poisoning of wildlife is surely enough to warrant action to reduce secondary poisoning, it is important to note that the poisoning data of thousands of wildlife rehabilitation centers across our country that receive injured sick and orphaned wildlife has not been included. The problem is of a much greater magnitude.

Thank you for labeling second generation anti-coagulant rodenticides for indoor use only, to save thousands of non-target wild animals lives annually.

Sincerely,

Your Name
Your Address

Deadline for letters is May 18, 2007

Submit your comments, identified by docket identification number EPA-HQ-OPP-2006-0955, by mail to:

Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P)
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, D.C. 20460-0001
Attn: Kelly Sherman

Or visit the Federal eRulemaking Portal: www.regulations.gov. Follow the on-line instructions for submitting comments.
The EPA's policy is that comments received will be included in the docket without change and may be made available online at http://www.regulations.gov.

Your voice is needed to save wildlife across our country. Thank you!