STEWARDSHIP: THE CAREFUL AND RESPONSIBLE MANAGEMENT OF SOMETHING ENTRUSTED TO ONE’S CARE
No one understands and appreciates the meaning behind stewardship of the land more than those in agriculture. With 60+ years of agricultural experience, the Scimetrics team continues to provide effective baits that help protect crops, offer a reduced risk to non-target species and help maintain your bottom line. Our Prairie Dog Stewardship program is to assist the users of prairie dog baits to do so effectively and efficiently with minimal impact to the environment.
- READ THE LABEL!!! The label is the law. It is the responsibility of the applicator to read and follow all label directions. Failure to do so is a violation of federal law.
- Keep proper records for possible inspection by state and/or federal agencies, including copies of bulletins even if there are no restrictions for the application area.
Restricted-Use Pesticide (RUP) Classification
- Kaput-D Prairie Dog Baits are restricted-use pesticides due to hazard to non-target organisms.
- For retail sale to and use only by certified applicators or persons under their direct supervision and only for those uses covered by the Certified Applicator’s Certificate.
- Restricted-use pesticide statement is clearly marked on the product label.
- Requires a valid commercial or private applicator license to purchase the product.
- Can only be applied by a certified applicator or persons under the direct supervision of a certified applicator, and only for those uses (pests) covered by the certified applicator’s license.
- For prairie dog bait, your license must cover Outdoor Vertebrate Pest Control.
- The United States Environmental Protection Agency classifies products as RUP for various reasons including, but not limited to:
- Required level of expertise for bait application
- Toxicity of bait
- Hazards to non-target organisms
- Threatened and endangered species concerns
- Ground water contamination concerns
Endangered Species Act (ESA) Federal Law
- The purpose of this act is to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved (ESA, Section 2b).
- Administered by U.S. Fish and Wildlife Service and the National Oceanic and Atmospheric Association.
Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Federal Law
- Regulates the manufacture, distribution, sale, and use of pesticides.
- Ensures that using the pesticide according to the product label will not cause unreasonable adverse effects to humans, non-target species, and/or the environment.
- Dictates that the product label, including all materials referenced on it (e.g., endangered species protection bulletins), is the LAW.
- Administered by U.S. Environmental Protection Agency (EPA). The EPA is required to abide by regulations outlined by the Endangered Species Act (ESA).
- The ESA directs all federal agencies to work to conserve endangered and threatened species.
- Section 7(a)(2) of ESA requires federal agencies (“action agencies”) in consultation with the Service to ensure that any action they authorize, fund or carry out is not likely to jeopardize the continued existence of a listed species or result in the destruction or adverse modification of habitat designated by the Service as critical.
- Under FIFRA, the “action” subject to the consultation provisions of the ESA is the federal registration of a pesticide.
Pesticide Misuse is Illegal
- It is a violation of federal law to use a pesticide product in a manner inconsistent with its labeling.
- If label directions are followed and there is “take” (i.e., an animal is injured or killed) of a listed species, then it is not a violation of FIFRA and the ESA.
- If label directions are NOT followed and there is “take” of a listed species, then it is a violation of FIFRA and the ESA and civil penalties may apply.
Examples of misuse:
- Increasing dosage rates
- Violating specific safety instructions
- Selling a restricted use pesticide to an uncertified applicator
- Baiting outside the baiting season
- Not performing line-transect carcass searches
- Failing to report dead or dying non-target wildlife to the National Pesticide Information Center
- Failing to dispose of dead or dying black-tailed prairie dogs
Primary, Secondary & Tertiary Poisoning
- Direct consumption of bait.
- Example: Prairie dog bait was spilled on the ground and not cleaned up. A songbird (non-target animal) eats the spilled bait and gets sick or dies.
- Consumption of poisoned carcass by predators or scavengers.
- Example: Eagle eats dead or dying black-tailed prairie dog with enough poison residue in tissue to sicken or kill the eagle.
- Consumption of a dying or dead animal that was poisoned by secondary poisoning.
- Example: Black-tailed prairie dog eats prairie dog bait and dies above ground. Coyote then eats poisoned black-tailed prairie dog with enough residual poison in its tissue to kill the coyote. Eagle then eats dead coyote with enough residual poison in its tissue to sicken or kill the eagle.
Endangered Species Protection Bulletins are part of the EPA’s Endangered Species Protection Program.
- Sets forth geographically specific pesticide-use limitations for the protection of listed species and their designated critical habitat.
- Bulletins are an extension of the product label. Non-compliance is a violation of federal law.
- Before applying bait, you MUST obtain the proper bulletin for the application area and month in which you are applying the product.
- It is mandatory to access bulletins no more than six months prior to application.
- Bulletins can be obtained online at http://www.epa.gov/espp/bulletins.htm or by phone at 1-844-447-3813.
- It is strongly recommended to have a printed bulletin with you during application for the intended application area and month of your application. It is recommended you keep a copy of the bulletin for your files even if there are no restrictions in your area. It is proof you checked the website.
Conservation Measures for Species Potentially Affected by Black-Tailed Prairie Dog Control
- Black-Footed Ferret
- Habitat: Central North America.
- Do not apply bait within black-footed ferret reintroduction sites.
- Do not apply bait if live/dead black-footed ferrets are found outside reintroduction sites in a black-tailed prairie dog colony and immediately report it to the Black-Footed Ferret Coordinator at 970-897-2730 ext.224. Allow sufficient time for Fish and Wildlife Service to capture and relocate black-footed ferrets before applying bait.
- Contact Black-footed Ferret Coordinator if black-footed ferrets are found anytime before, during or after application, or during carcass searches.
- Grizzly Bear
- Habitat: Northwest United States (Idaho, Montana, Washington, Wyoming) and Alaska.
- In 13 counties in Montana, delay bait application by two months until December 1, and shorten the application period in the spring by two weeks to end by March 1.
- Chiricahua Leopard Frog
- Habitat: Desert grasslands of Southwestern United States, primarily Arizona and New Mexico.
- Do not apply bait within the five southwestern New Mexico counties of Catron, Grant, Hidalgo, Sierra and Socorro to avoid impacts to the Chiricahua leopard frog and its critical habitat.
- Habitat: Southern United States, primarily Arizona and New Mexico.
- Do not apply bait within the southwestern New Mexico county of Hidalgo to reduce the risk of impacts to the jaguar.
- New Mexican Ridge-Nosed Rattlesnake
- Habitat: Southwestern United States, primarily New Mexico.
- Do not apply bait within the southwestern New Mexico County of Hidalgo to avoid impacts to the New Mexican Ridge-Nosed Rattlesnake and its designated habitat.
- Mexican Gray Wolf
- Habitat: Southwestern United States, primarily Arizona and New Mexico.
- Do not apply bait within the four southwestern New Mexico counties of Catron, Grant, Hidalgo and Sierra to reduce the risk of impacts to the Mexican Gray Wolf.
- Mexican Spotted Owl
- Habitat: Canyons and mountain forests in Southwestern United States (Southern Colorado, Southern Utah, Arizona, New Mexico, West Texas)
- Do not apply bait within five southwestern New Mexico counties (Catron, Grant, Hidalgo, Sierra and Socorro) to reduce the risk of impacts to the Mexican Spotted Owl and its designated critical habitat.
- Preble’s Meadow Jumping Mouse
- Habitat: Colorado and Wyoming.
- In seven counties in Colorado (Larimer, Boulder, Weld, Jefferson, Douglas , Elbert and El Paso) and four counties in Wyoming (Converse, Platte, Albany and Laramie), delay bait application in the fall by one month, until November 1.
- Northern Aplomado Falcon
- Habitat: Southwestern United States, primarily Southern New Mexico and South Texas.
- Black-tailed prairie dog colonies in six counties in New Mexico and 35 counties in Texas may be occupied by the federally endangered Northern Aplomado Falcon.
- Prairie dog bait application may be harmful to the Northern Aplomado Falcon.
- Contact U.S. Fish and Wildlife Service before application.
- New Mexico: 505-346-2525
- Texas: 817-277-1100
- Note: If you have to leave a voicemail message, Fish and Wildlife Service should respond within three business days. If you do not receive a response back within three business days, you may apply the bait.
Use Restrictions for Prairie Dog Bait
- For use only to control black-tailed prairie dogs.
- For use only in the 10 states where the bait is registered.
- For use only in underground applications.
- Apply six inches down active black-tailed prairie dog burrows.
- Leave no bait on soil surface.
- Apply only between October 1 and March 15 of the following year, unless stated otherwise in the respective bulletin.
- Do not allow non-applicators in the area during application.
- Do not allow livestock to graze on treated areas for 14 days after treatment.
- Do not use KAPUT-D PRAIRIE DOG BAIT, KAPUT COMBO PRAIRIE DOG BAIT, or ROZOL PRAIRIE DOG BAIT with any other anticoagulant bait.
- Do not apply black-tailed prairie dog bait within black-footed ferret reintroduction sites or within the following Indian Reservations:
- South Dakota: Cheyenne River, Lower Brule, Rosebud
- Montana: Ft. Belknap and Northern Cheyenne (as specified in Endangered Species Protection Bulletins)
- Other black-footed ferret reintroduction sites include:
- Wyoming: Shirley Basin
- South Dakota: Badlands National Park, Conata Basin, Wind Cave National Park
- Montana: UL Bend National Wildlife Refuge, Bureau of Land Management-40 Complex
- Colorado: Wolf Creek
- Kansas: Logan County
- New Mexico: Vermejo Park Ranch
- Use of black-tailed prairie dog bait is also prohibited within two additional Indian reservations in Montana: Blackfeet and Crow. These areas are not black-footed ferret reintroduction sites, but the tribes do not want anticoagulant rodenticide products used within the boundaries of the reservation (as specified on federal label).
- NOTE: Other tribes may have specific ordinances against the use of anticoagulant bait, for example, the Pine Ridge Indian Reservation in South Dakota.
- It is recommended to check specific ordinances before applying bait within Indian Reservations.
- Check Bulletins Live Two! for your specific application area and month in which you intend to apply prairie dog bait to determine if there are any geographical pesticide use limitations.
- Access bulletins no more than six months prior to application to make sure you will have up to date information.
- KAPUT-D PRAIRIE DOG BAIT, KAPUT COMBO PRAIRIE DOG BAIT, and ROZOL PRAIRIE DOG BAIT are all Restricted-Use Pesticides; therefore, you must have a valid applicator’s license.
- Make sure you have valid applicator’s license for the state in which you are baiting.
- Identify active black-tailed prairie dog burrows.
- Indications of active black-tailed prairie dog burrows are:
- Openings with freshly turned earth that are free of leaves, seeds, spider webs and other debris.
- Black-tailed prairie dog feces and tracks.
- Treat only active black-tailed prairie dog burrows.
- By hand scoop.
- By mechanical placement machine with calibration capability.
- Apply ¼ cup of bait at least six inches down active prairie dog burrows.
- Make sure no bait is left on the soil surface.
- Applicator must retrieve and dispose of any bait spilled above ground or placed less than six inches down burrow entrance.
Carcass Search and Removal
- Applicator must return to site within four days after bait application and at one- to two-day intervals thereafter for AT LEAST TWO WEEKS to collect and properly dispose of any bait or dead or dying black-tailed prairie dogs found on surface.
- Collect and dispose of dead or dying black-tailed prairie dogs and search for non-target animals for at least two weeks BUT LONGER if carcasses are still being found at that time.
- Carcass collection should occur by late afternoon to reduce the chances of nocturnal animals finding carcasses of dead or dying animals.
- Although not required by the label, the following actions will help minimize risks of secondary poisoning to predators and scavengers:
- Longer duration of the search (beyond two weeks)
- More frequent carcass searches and collections, such as once early in the morning to reduce exposure to daytime sight predators such as hawks and eagles, and another late in the afternoon to reduce the potential of nocturnal animals finding carcasses.
Carcass Search Requirement
- Must be performed using a line-transect method that completely covers the baited area.
- Transect center lines must not be more than 200 feet apart.
- Transect center lines may be traveled on foot or by vehicle at a rate of four miles per hour or less.
- Start by dividing the area into straight, parallel lines to define width and ends of the area.
- Use natural landmarks, stakes, GPS or other tools to easily identify the line and return to it for future carcass searches.
- Set transect lines at a distance which will allow for unobstructed view, which may mean using natural breaks and creating a new transect line at a fence, hedge row, ditch, crest, etc.
- To evaluate proper distance, put a small brown object (e.g., glove) on the ground and walk away to a distance where the object still can be easily seen. Use that as a benchmark for your spacing. Remember: Maximum spacing is 200 feet, but it may have to be less depending on density of vegetation and/or other geographic properties.
- Consider time of day and position of sun when establishing transect layout for maximum visibility (e.g., looking into the sun when searching decreases visibility).
- When a dead/sick animal or bait is detected, address it immediately before continuing to traverse the line and visually scan as before.
- Bait: Remove from surface area.
- Non-targets (including live black-footed ferrets): Report them.
- Targets: Collect for proper disposal.
- Report any apparently sick, dying or dead non-target animals, including federally listed species, that are found during carcass searches.
- Report any sightings of live or dead black-footed ferrets to the Black-Footed Ferret Coordinator. (Coordinator has to be contacted if black-footed ferrets are found any time, i.e., before, during, or after application or during carcass searches).
- Bury carcasses on site in holes at least 18 inches deep or in inactive burrow to avoid non-target animal scavenging.
- Burial includes covering and packing the hole or burrow with soil.
- If burial is not practical (frozen ground), check with your state or local authorities regarding other disposal methods allowed.
- Although not required by the label, the most effective method for disposing of carcasses and avoiding risk of secondary poisoning is to dispose of carcasses by state-approved methods that ensure inaccessibility of carcasses to scavengers and predators.
Re-application of Prairie Dog Bait
- A second application of bait may be made if black-tailed prairie dog activity persists several weeks or months after the first application of bait.
- NOTE: The same anticoagulant bait has to be used as in the first application.
- Follow all the Use Restrictions, Site Assessment, Application and Follow-Up Directions as with the first application.
Summary of Key Points
- Follow all label directions.
- Consult EPA’s Bulletins Live! website.
- Use only one anticoagulant prairie dog bait per treatment area (diphacinone or chlorophacinone).
- Use transect-line method for carcass searches.
- Conduct carcass searches for at least two weeks or longer if carcasses are still being found at this time.
- Reporting Responsibilities
- Dead/dying non-target animals
- Injured or sick federally listed species
- Live or dead black-footed ferrets