Active ingredients in APHIS's vertebrate pesticides - use and registration data
The Environmental Protection Agency's (EPA) reregistration process has had an extensive impact on the Animal Damage Control Program administered by the Animal and Plant Health Inspection Service (APHIS) of USDA. Specifically, the 1988 Amendment to the Federal Insecticide, Fungicide, and Rodenticide Act required a comprehensive reevaluation of pesticide safety; nearly 500 data submissions have been requested by EPA from APHIS to maintain its federal (Section 3) and state (Section 24(c)) low volume minor use vertebrate pesticide registrations. These registrations are used to control damage to American agricultural resources, mitigate losses to selected wildlife species, and reduce threats to public health and safety. A primary function of both APHIS's Denver Wildlife Research Center (DWRC) and Technical and Scientific Services (TSS) office is the maintenance of these registrations containing carbon, sodium nitrate, Compound 1080, sodium cyanide, DRC-1339, PA-14, zinc phosphide, and/or strychnine. APHIS has responded to EPA's data requests in a variety of ways including: requesting waivers, negotiating data requirements, proposing less costly alternatives, monitoring data contracts, and conducting the necessary studies. Since 1989, DWRC and its cooperators have submitted over 250 studies in support of these registrations. This paper will: 1) discuss the active ingredients in APHIS's vertebrate pesticides and their reregistration status; 2) evaluate the effectiveness and cost of each type of response; and 3) provide lessons for the future.