BACKGROUND
U.S. Environmental Protection Agency is considering a number of changes to its regulation of rodenticides that will jeopardize access to this critical rodent control tool.

WHAT IS BEING PROPOSED?
To make all bulk rodenticides RESTRICTED USE PRODUCTS (RUP)

WHAT WILL THIS MEAN FOR AGRICULTURAL PRODUCERS?
• Application of rodenticides must only be done by a licensed professional
o “Do you have enough licensed staff to deploy for rodent control applications… along with the additional requirements listed in the next bullet point?”
• Use of RUP’s by producers would be subject to an array of labor-intensive requirements that vary by state (and sometimes county)
o Usage reports
o Data collection
o Specialized disposal requirements
o Carcass removal
o Comprehensive documentation
• Due to labor, product costs or both, this will effectively eliminate ability of producers to control rodent populations (i.e. – you will have no practical access to rodenticides)
o Traps, exclusion, other mitigation cannot control overall populations in this environment
• These changes will necessarily jeopardize an already tenuous food supply chain
WHAT SHOULD I DO?
• Reach out to the EPA contacts below to provide feedback on the magnitude of the ramifications of this misguided regulatory initiative
• Reiterate:
o The jeopardy this will create for those charged with efficient, safe production of our food supply
 Inability for producers to provide necessary protection
 Likelihood of huge increases in food-borne rodent disease (salmonella, leptospirosis) and other rodent disease (hantavirus, plague, typhus and a litany of others)
 Likelihood of supply disruption due to shutdowns
 Structural damage to agricultural buildings caused by increased rodent activity will be massive, and unsafe for animals and humans
 Large, additional loss in food supply due to contamination from MORE rodents
 Massive increases in production costs due to all of the above
• Include any pictures or videos of rodent problems or damage in your production setting helping to clarify the types of challenges you face
• We recommend that you send communications directly to Steven R. Peterson and copy the other EPA representatives
• We also recommend that you copy your senate and/or congressional representatives as the EPA is very sensitive to their inputs
• *** Comments sent after 2/4/22 WILL NOT be considered by EPA. PLEASE RESPOND BEFORE 2/4/22.

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