Using Unregistered Carbon Dioxide (CO2)/Dry Ice Violates FIFRA
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In September, national media outlets reported that several cities, specifically Chicago, have been using carbon dioxide (CO2)/dry ice to treat for rodent infestations, which NPMA understood to be in violation of the Federal Insecticide Fungicide and Rodenticide Act (FIFRA). NPMA reached out to the U.S. Environmental Protection Agency (EPA) and the Illinois Department of Public Health to clarify our concerns.
As suspected, EPA informed NPMA that using CO2/dry ice was a violation of FIFRA because CO2/dry ice is not registered with EPA to control rodents. Pursuant to FIFRA, any product used to control, kill, repel or otherwise mitigate pests is required to be registered for that specific use, with very narrow exceptions. CO2/dry ice is not registered nor does it fall into one of the limited exceptions, and therefore any use of CO2/dry ice to control rodents would be a violation of federal law.
NPMA will continue to inform our member companies concerning the illegal nature of using prohibited unregistered products like CO2/dry ice to treat for pests. We remind you that this prohibition is not NPMA’s policy but federal law under FIFRA and enforced by EPA and state pesticide regulatory officials.
If you have further questions please contact Jim Fredericks jfredericks@pestworld.org or Andrew Bray abray@pestworld.org.
