U.S. EPA Advisory to Federal Agencies Regarding Revised Requirements for Use of Sodium Cyanide Devices
On 4 December 2019, EPA published its Sodium Cyanide Interim Registration Review Decision ("Interim Decision"). The Interim Decision established necessary label changes under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) for sodium cyanide devices, also known as M-44s, which are restricted-use pesticides used for controlling coyotes and other wild predators. FIFRA requires applicators of restricted-use pesticides to be trained and certified. Only the U.S. Department of Agriculture and the state agriculture departments of South Dakota, Texas, Montana, Wyoming, and New Mexico hold registrations for sodium cyanide products. In addition to registration and applicator certification requirements, federal agencies are reminded that they--as with all M-44 users--must follow EPA's revised requirements for the use of sodium cyanide devices as directed by the product labels. Revisions to the label include requirements that sodium cyanide devices not be placed within 600 feet of residences unless specific criteria are met and that the applicator notify occupants of all residences within a 0.5-mile radius prior to device placement. The revised labels also include several modified use restrictions, which now require that devices be placed at least 300 feet from public roads and pathways and that two elevated signs facing the most likely directions of approach be erected within 15 feet of the device.