IFB comments on EPA pesticide proposals


Illinois Farm Bureau was one of more than 10,000 contributors to formally comment on regulations related to pesticide use and labeling proposed by the U.S. Environmental Protection Agency (EPA).

In the first measure, EPA proposes to reclassify nine different rodenticides — bromadiolone, bromethalin, chlorophacinone, cholecalciferol, difenacoum, difethialone, diphacinone, warfarin and zinc phosphide — as “restricted use products (RUP).”

Pesticides carrying the RUP label mean they must be purchased and applied by only a state-licensed or certified applicator, or under the supervision of a certified applicator, a requirement IFB opposes.

“We take this position because certified applicators will end up being trained in and using the very same sound and effective rodent-control practices that are already in use today on animal operations, and therefore will result in no added benefits to non-target species,” IFB President Richard Guebert Jr. wrote in comments submitted to EPA in February.

A certified applicator requirement would also “certainly create considerable costs and inefficiencies for, and large gaps in, rodent control efforts” on livestock operations, he added.

Limiting producers’ ability to manage mouse and rat populations — their growth on livestock farms is inevitable given the surplus of water, feed and shelter found across them — is especially problematic because of the health and economic risks rodents carry.

“Rodents are vectors for transmission of bacterial and viral pathogens that can make farm animals sicken or die, compromise food safety, or sicken people on the farm or in the broader community,” Guebert wrote.

He noted how rodents “eat or spoil enormous quantities of animal feed, creating not only substantial economic losses for producers, but also increasing the size of operations’ life-cycle environmental footprint, including for greenhouse gas emissions.”

Policies that would significantly limit farmers and ranchers’ access to and use of rodenticides, Guebert concluded, would ultimately “lead to poorer rodent control performance and greater operational vulnerabilities that create substantial risks of negative if not in some instances even calamitous outcomes.”

On the second measure, EPA proposes an Endangered Species Act (ESA) Workplan that contains a series of changes to the way it reviews how a pesticide’s usage and labeling comply with terms of the ESA.

Within the ESA Workplan is a proposed “mitigation system” requirement, wherein a pesticide’s label would be mandated to include what measures should be taken to avoid or minimize that pesticide’s exposure to a species covered by the ESA.

According to Guebert, the system would impact how labels are constructed and how applicators are regulated and trained, as well as “drastically modify how voluntary agricultural best management practices are implemented with regards to regulated pesticide application label directions.”

He called on EPA to consider recommendations on the proposed changes made by EPA’s Farm, Ranch and Rural Communities Advisory Committee and to seek input from state pesticide control officials and the scientific community.

And Guebert wrote that EPA should reconsider its proposed interim ecological mitigations for pesticide applications near surface water.

Specifically, he said IFB supports making mitigations “more flexible” when the “benefit of the pesticide is higher than its potential impact to nontarget species,” and when there’s a lack of other products with the same efficacy or cost for a certain pest or crop.

Precipitation-related pesticide application restrictions should further be structured in a way that is feasible for farmers to achieve compliance, Guebert added, noting that precipitation forecasts remain unreliable.

And within those restrictions, IFB recommends adding mitigation measures to the options, because “the greater the options, the more likely a farmer will be able to find at least one practice they can use to meet mitigation requirements,” Guebert wrote.


This story was provided by FarmWeekNow.com.