A coalition of poultry and livestock groups led by the National Pork Producers Council (NPPC) filed comments with the U.S. Environmental Protection Agency (EPA) on Feb. 13 about its proposed regulation of rodenticides to control rodents on farms.
“Rodenticides are an important part of the agriculture industry. Uncontrolled mice and rats have a detrimental effect on the environment and farms and ranches. Along with crop destruction, rodents transmit bacteria and viruses that can infect and cause animal diseases. They also consume and spoil feed, which increases the environmental footprint of farms and food. Fewer rodents mean less fuel, fertilizer, and water are needed to raise animals and crops, reducing a farm’s environmental footprint and lowering costs for farmers,” NPPC wrote in Capital Update.
Although the groups strongly support improved rodenticide stewardship to reduce or eliminate rodenticides’ effects on non-target species, including threatened and endangered species under the Endangered Species Act, they urged EPA to “scrap” the proposed rule.
The groups urged EPA to conduct studies “needed to develop sound and appropriate mitigation measures that effectively and efficiently reduce the potential for harm for non-target species from unintended exposures to rodenticides.” The groups said that the draft rule not only likely fails to achieve that non-target species outcome, but it may also exacerbate the problem the EPA seeks to address.
EPA wants to limit the purchase and application of rodenticides to certified applicators and, in some states, individuals supervised by certified applicators. It also wants additional, detailed record keeping for rodenticide use on farms, NPPC wrote in Capital Update.
In their comments, the organizations pointed out that hiring certified applicators or training and certifying farm workers in rodenticide application will add costs to producers, won’t improve rodent control and likely would have no effect on “non-target species.” In addition, more record-keeping will add costs.
“The use of outside, contracted certified applicators … would for many producers present unacceptable levels of biosecurity risk, as well as a risk that the provision of essential rodent control services would be disrupted should there be disease outbreaks at other operations in the area,” the groups wrote.
The groups cited examples of how disease can spread easily once it reaches a farm or ranch and can lead to the loss of literally millions of animals and their owner’s livelihoods. For example, they explained how a 2018 outbreak of African swine fever (ASF) wiped out a third of the entire swine herd of China and how Highly Pathogenic Avian Influenza (HPAI) continues to result in major loss in the poultry industry.
“With respect to the potential for animal diseases that can be spread by rodents and related biosecurity breaches, farms and ranches face every day the catastrophic risk of an animal disease that could lead to the deaths of their entire herds or flocks,” the authors wrote.
The bottom line is critical, the authors explained.
“Higher costs and greater risks of incomplete, inadequate or less than optimal rodent control service will mean in many instances that
- less effective average levels of rodent control will be achieved on many farms and ranches
- booms and busts of rodent populations on farms and ranches will become more common
- greater average amounts of rodenticides needed to achieve control
- on average exposing more non-target animals to rodenticide-treated rodents or their carcasses.”
The authors of the letter include the American Farm Bureau Federation, American Horse Council, Association of California Egg Farmers, Dairy Producers of New Mexico, Florida Poultry Federation, Indiana State Poultry Association, Kentucky Poultry Federation, North Central Poultry Association, National Council of Farmer Cooperatives, National Milk Producers Federation, National Pork Producers Council, National Turkey Federation, Ohio Poultry Association, Pacific Egg and Poultry Association, Texas Poultry Federation and United Egg Producers.
Read More:
Why You Need to Pay Attention Now to EPA’s Proposed Rodenticide Mitigation Measures
