Date of this Version
On December 1, 1976, the Environmental Protection Agency applied Section 6 of the Federal Insecticide, Fungicide, and Rodenticide Act, "Administrative Review", in determining that the use of products containing strychnine, for above ground application to control several rodent species, met specific cancellation criteria outlined in 40 CFR 162.11. Position Document 4 (the final Agency decision), published on September 30, 1983, proposed to cancel registrations of strychnine products for above ground use to control prairie dogs and required label modification for confined use on ground squirrels. The final decision was challenged by several parties who requested a formal hearing which was granted by the EPA. This request temporarily stayed the EPA decision to cancel registrations. A formal hearing has not yet been held, pending negotiations for a settlement agreement by the parties to this action. The use of Compound 1080 for rodent control has undergone the same administrative review as strychnine with similar conclusions drawn. Position Document 4, published in July of 1985, proposed to cancel current intrastate registrations by December 31, 1985. However, current application and bait concentrations may continue for use in ground squirrel control while Section 3 registration data are being developed. Bait treatment levels may not exceed 0.02% 1080 in the California Condor Range: if the 0.02% concentration is not effective, data must be submitted to establish the lowest effective concentration.