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.

To make all bulk rodenticides RESTRICTED USE PRODUCTS (RUP)

• 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
• 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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