The Environmental Protection Agency's (EPA) proposal to overturn decades-long policies governing farmers' and ranchers' use of rodenticides, their primary tools for controlling infestations of rats and mice, will do more harm than good. Comments are due on February 13, 2023, and we encourage farmers and ranchers to weigh in.  

EPA's choice to designate these vital tools as "Restricted Use Products" (RUPs) will undermine animal health and welfare, put food safety at risk, reduce environmental performance, and increase economic losses for hard-working farmers. Good, responsible rodent control practices developed between farmers and EPA are already in place, and if further refinements are needed, they can be more effectively achieved through guidance and education with significantly fewer bad outcomes than through EPA’s RUP designation.

Rats and mice have long been a problem on farms and ranches, and producers rely on tools like rodenticides to protect their crops and livestock. Rodents can cause severe problems to animal and farm workers’ health as well as food safety, as they carry and transmit many of the most serious bacterial and viral pathogens. Uncontrolled rodent populations create reservoirs of these pathogens which can result in cross contamination. Their control on egg laying farms is mandated by the Food and Drug Administration to protect egg safety. Rodents are also a leading vector in the transmission of bacteria and viruses that infect and cause animal diseases. Infections can range from the intestinal and digestive tract, heart, and reproductive diseases in swine and cattle to the highly pathogenic and fatal avian influenza outbreak. These diseases have contributed to skyrocketing food prices impacting consumers today. 

Rats and mice are prolific reproducers and voracious eaters, causing significant environmental concerns. Feed losses are not just of economic importance to livestock farmers. The tremendous amount consumed and spoiled by rats and mice causes substantial increases in environmental footprint of farms and the food we consume. For example, an uncontrolled population of 9000 mice can consume about 10 tons of feed a year and will spoil another 100 tons. Rats are even worse - a population of 3000 rats will eat about 34 tons of feed a year and spoil another 340. This drives up the cost of food through increased production costs and wastes the resources that went into growing the feed intended for livestock. Fewer rodents means less fuel, fertilizer and water needed to raise animals and crops, reducing a farm’s environmental footprint and lowering costs for farmers. Rodent control programs and the critical role rodenticides play in them have a net positive and meaningful benefit in reducing animal operations' environmental and GHG footprint.  

Having rodenticides designated as RUPs would require any commercial user of the products, including farmers or ranchers, to become a "certified applicator," essentially requiring state licensing for farmers to farm. This will also impose extensive and costly recordkeeping requirements. The certification, primarily targeted at individuals spraying pesticides, extends far beyond practical and sound rodenticide stewardship, making the costs of the study, training, and testing far greater than needed and raising the costs and burdens for small and medium sized farmers to farm. The extensive records required also serve no practical purpose relative to sound rodenticide stewardship.

We had hoped that EPA would see the big picture and recognize the unintended consequences of such a decision for our food supply and agriculture’s efforts to combat climate change. Instead, they made an arbitrary decision based on assumptions and extrapolations from highly questionable studies. 

Farmers share EPA's goal of good rodenticide stewardship and believe it can be achieved while avoiding harmful unintended consequences. We stand ready to work with EPA to make this possible, but we cannot support EPA's proposed RUP designations for all rodenticides. We call on EPA to withdraw this proposal and work with us, other stakeholders, and other federal and state agencies to take a better approach. The goal of good rodenticide stewardship can be achieved while ensuring we can still protect our animals’ health and welfare, produce safe and wholesome food for consumers, and do so sustainably. 

This piece is signed by the American Farm Bureau Federation, American Horse Council, National Cattlemen’s Beef Association, National Council of Farmer Cooperatives, National Milk Producers Federation, National Pork Producers Council, National Turkey Federation, United Egg Producers and US Poultry & Egg Association.

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