Livestock groups ask EPA to scrap proposed rodent rule

Coalition addressed spread of swine diseases; biosecurity risks of having outside, contracted certified applicators on farms.

Ann Hess, Content Director

February 20, 2024

3 Min Read
National Pork Board

Several livestock groups have filed comments with the U.S. Environmental Protection Agency regarding its proposed regulation of rodenticides to control vermin on farms. The organizations urged the agency to scrap the proposed rule and 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.”

To protect animals other than mice and rats, the 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.

In their letter, the livestock organizations noted the following reasons why the EPA's Draft Biological Evaluation for the Rodenticides should not move forward as proposed.

  • The restricted use product designation and proposed mitigation measures will lead to greater costs and inefficiencies for, and gaps in, the practice of good rodent control on farms and ranches.

  • The proposed interim decisions will create greater food safety risks and related regulatory compliance risks for farms and ranches.

  • The PIDs will create greater biosecurity risks and animal health risks for farms and ranches.

  • The PIDs will lead to greater animal feed losses and spoilage, increasing the lifecycle environmental footprint, including greenhouse gas emissions, of farms and ranches.

  • Questions about the science behind the agency’s assumptions about non-target species’ exposures to rodenticides.

The coalition also addressed several swine health disease risks from rodents.

"Rodents can be carriers of numerous pig pathogens including “Salmonella serovars, Leptospira, Yersinia pseudotuberculosis, Toxoplasma gondii, Campylobacter spp., Brachyspira spp, Lawsonia intracellularis or the encephalomyocarditis virus. While mice travel relatively short distances in an evening (150 meters) and, therefore, are more of a threat to biosecurity within a facility, rats can be vectors for transmission off-farm and to neighboring farms and ranches. Rats can travel up to 3 km in an evening."

While trichinosis is very rare and all but eliminated in farm raised pork, it remains an ongoing risk for swine operations, with the “rat is considered to be the most common vector for the Trichinella parasite."

The organizations also noted the spread of foreign animal diseases, such as African swine fever, by rodents.

"Since the onset of the latest outbreak, huge efforts have been made to prevent and control the rapid spread of the disease, including a strict stamping-out policy that involves delineating quarantine zones for infected areas and the rigorous culling of infected herds. These measures inevitably cause large economic losses and affect many people and related industries. While ASF has not yet been detected in North America, it was recently found in Haiti. The U.S. and Canadian swine farmers and the animal health agencies are on high alert."

Biosecurity risks of having outside, contracted certified applicators on farms is also a concern.

"The use of outside, contracted certified applicators who would make the rounds going from farm-to-farm to provide rodent control services 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. Many companies simply would not and could not accept these risks and would be forced to acquire, if they can, in-house certified rodenticide application personnel."

In their Capital Update, the National Pork Producers Council pointed out that requiring the hiring of 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.” Likewise, more record-keeping will add costs.

About the Author(s)

Ann Hess

Content Director, National Hog Farmer

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