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Why You Need to Pay Attention Now to EPA’s Proposed Rodenticide Mitigation Measures

Fri, 27 Sep 2024 01:18:52 GMT

Out of sight, out of mind. That theory works for a while until it doesn’t, especially when it comes to rodent control.

“Rodenticide use is like using insecticides. If you don’t see any cockroaches, you don’t worry about them. But once you see one, you throw the bomb at it,” says Larry Delozier, director of national poultry account sales for QC Supply.

Similarly, once you see a mouse or rat, it’s likely you have a big problem on your hands , explains Steve Von Haden, Midwest business manager for Motomco.

“Always assume you have rodents, and you should be putting bait out,” Von Haden says. “All agricultural buildings or structures will have rodents of some type. You just don’t want it to get to such high peaks it causes structural damage, diseases and contamination of food sources .”

Pending regulation could mean agriculture loses critically important tools to protect food security. EPA is proposing significant changes to rodenticides that would result in the canceling of products and uses, add more requirements to the labels, and reclassify some products to restricted use pesticides .

“Regardless of whether you are a livestock producer or citrus grower or manager of a golf course, this will have an impact on your ability to effectively manage a destructive farm pest,” says John Walt Boatright, director of government affairs at American Farm Bureau Federation (AFBF). “It’s one more challenge in a regulatory environment where challenges continue to grow for the American producer.”

What is EPA Proposing?

On Nov. 29, 2022, the EPA released for public comment new proposed mitigation measures for 11 rodenticides, which if implemented, will have a major impact on all currently available rodenticide products, the Agricultural Retailers Association (ARA) said on its website . The agency’s proposals are the most significant changes to rodenticides in 15 years that will result in the canceling of products and uses, add more requirements to the labels, and reclassify some products to restricted use pesticides, ARA noted.

EPA’s recommended changes are included in four Proposed Interim Decision documents (PIDs) that cover: 1) the seven anticoagulant rodenticides; 2) bromethalin and cholecalciferol; 3) strychnine; and 4) zinc phosphide.

“EPA’s proposal is quite wide-ranging, and it is going to impact any user of rodenticides and how rodenticides are applied,” Boatright explains. “The challenge is many of EPA’s proposed mitigation measures introduce additional challenges for on-farm application. I don’t know that they will have the intended effect that EPA thinks they’ll have.”

Boatright says this should be very concerning for everyone in the agricultural supply chain who apply rodenticides. Michael Formica, chief legal strategist for the National Pork Producers Council (NPPC), says it will also have a negative impact in urban areas where rodent infestation is a major problem.

“This is an example of one area where rural communities can build positive engagement and cooperate with urban communities. As much as rats and rodents are pests on the farm, they are even more so in an urban area,” Formica says. “In the back alleys in DC, you see rats that look like cats racing from one building to another, running around at night. People don’t want to live with them.”

And they shouldn’t have to, Delozier says. Rodent control companies have made effective, safe bait under EPA’s existing stringent restrictions. EPA’s proposed measures will add great cost and will likely be prohibitive for many.

What Does This Mean for Farmers?

If this proposal is enacted, rodenticide users will see many new restrictions.

“The average livestock farmer wouldn’t be able to use them, you would have to go through certification and training in your state,” Formica explains. “If you’ve got a row crop or grain operation, a lot of folks have that certification because they spray pesticides. But most livestock farmers don’t have all those different certifications.”

Certifications would be required annually, which takes a lot of time, paperwork and training.

“If you don’t have that certification, you would need to hire exterminators to come out. That’s expensive and creates its own biosecurity problem because you’re having people come out not just to apply the rat poison, but also pick up the dead rats,” Formica says.

Pick up dead rats? Yes, that’s part of the new measures, too.

“The proposal talks about mandatory carcass searches in the field. That seems to be quite a challenge to expect a farmer or a farm worker to stop what they’re doing and search for rodent carcasses in potentially hundreds or thousands of acres,” Boatright says.

Once the rodent carcasses are found, farmers would be required to not just log them, but also pick them up and dispose of them.

Another limitation of these measures includes the requirement of single-use base stations, which would create a lot of garbage, Formica adds. The bait stations being used today are refillable.

What Will Happen if Rodent Bait Goes Off the Shelves?

“The more regulation you put on farmers, the more resistance you will have and that’s not conducive to the economic engine that is farming and food in the U.S.,” says Mike Slegl, vice president of product sales for QC Supply.

Farmers aren’t misusing product with the intent of controlling other things, Slegl adds. Some believe EPA is rushing to do this because of pressure from environmentalists for Endangered Species Act concerns.

“There is a potential major negative impact of an additional EPA regulation on the true sustainability of livestock production and the livelihood of farms,” Slegl says. “If it’s one more forced hand that overnight becomes more expensive to something they’re already doing, there’s going to be major resistance and people will push towards non-compliance.”

Delozier fears EPA’s rodenticide mitigation measures will ultimately increase the cost of goods to the consumer.

“Whenever we add requirements, there is always a cost that goes into the food system and will eventually cost the consumer more, too,” Delozier says. “Farmers are already using rodenticides that have to be EPA-approved.”

Darrin Karcher, a poultry specialist and associate professor at Purdue University, says it could be a double-edged sword.

“With the larger integrated companies, if they have to pay someone else to do it, they will pay someone because it has to be taken care of. Where it may catch are those individuals doing it themselves who may not have financial depths to pursue having other people take care of application,” Karcher says. “The question becomes, can they find a way to do that?”

An Increased Biosecurity Risk

And what if they can’t? Rodents present a major biosecurity risk for farms. With devastating diseases like Highly Pathogenic Avian Influenza (HPAI) in the poultry industry and the threat of deadly foreign animal diseases like African swine fever (ASF) in the pork industry, leaders fear how this could impact the health of the nation’s livestock herds.

“The restricted-use pesticide designation concerns me,” says Matthew Galloway, Midwest sales manager for ag rodenticides with Liphatech Inc. “For the broiler and breeder side of the poultry industry, there are hundreds of thousands of barns all over the U.S. One contract grower often has four or five barns and there may be several thousand barns within each company. If farmers don’t get their license, they will have to hire an outside applicator. Then you run into the risk of biosecurity breaches. We can’t have applicators running through multiple farms over a week’s time, otherwise we’ll really see a massive problem.”

It’s also a major problem if rodents get out of control because farms can’t afford the added cost.

“You can put all the filters you want on the ventilation systems in your barns and be as biosecure of a facility as possible, but if rats can get in and out, they will find a way. They aren’t showering,” Formica says.

What Can You Do?

Every 15 years, pesticides are reviewed by EPA. This rodenticide review is part of a pilot project for EPA as they’re implementing their Endangered Species Act work plan. These mitigation measures seek to achieve compliance with their statutory directives at EPA, following recent court cases directing EPA.

“We will see this approach in reviewing other pesticides as well. Folks need to be prepared to provide input,” he says.

This is a proposed interim decision, Boatright explains. EPA will take comments through Feb. 13 and review them. They will then promulgate a final rule at some point in the future.

“Make your voice heard,” Liphatech’s Galloway says. “We’ve got to do everything we can. Submit comments to EPA.”

Both NPPC and AFBF are gathering feedback and information from its members and will be submitting comments to EPA by the Feb. 13 deadline.

“Weigh in and let elected officials know you value these products. The best thing you can do is call your member of Congress. We’re just coming out of three years of COVID, and there are tremendous human health issues of taking rodenticides off the market,” NPPC’s Formica says.

Read more about the rodent problem.

How Prop 12 Could Impact Crop and Livestock Producers

Fri, 12 May 2023 15:31:04 GMT

More than half of Californians voted in favor of stricter restrictions on animal confinement, commonly called Prop 12, which took effect on Jan. 1.

The law not only altered its livestock raising standards, but it also banned the sale of animal-derived products that do not comply with statute’s regulations. This means producers in other states cannot sell eggs, veal and pork products in California unless they meet Prop 12’s standards.

Challenged by numerous ag alliances, Prop 12 is scheduled to be taken up by the U.S. Supreme Court on Tuesday.

Impact for Crop Producers

If the Court rules in favor of California, the legislation will open a door to a much larger arena of regulatory authority. This case should have all producers on high alert, according to John Dillard, principal at OFW Law.

“If California were to win this case in the Supreme Court, there’s nothing stopping the state from saying, for example, you can only sell corn in California if it’s harvested with an electric combine,” he says.

Dillard says the Supreme Court’s ruling could give the green or red light for each state to set its own standards on any and all products that come across state lines.

Jim Wiesemeyer, Profarmer policy analyst told AgriTalk Host Chip Flory that he believes once all Prop 12 arguments are heard on Tuesday, the Court won’t produce a final ruling until next June.

The live court hearing will be available here on Tuesday.

More on Prop 12:

Follow California Proposition 12 SCOTUS Oral Arguments Live
Proposition 12 Will Push Pig Farmers Out of Business, NPPC and Farmers Say
California Proposition 12 Took Effect Jan. 1, But Supreme Court Action Ahead

Labor Shortage, Wet Weather Cause Lumber Prices to Surge 359%

Mon, 03 May 2021 18:15:25 GMT

As shoppers face sticker shock when buying lumber, prices continue to climb. Lumber prices are up 359% since last year at this time, with a 69% increase taking place since the start of 2021. But the higher prices aren’t trickling down to producers.

“Unfortunately, not; if you look at it from the stumpage and delivery, prices are very hyper local,” says Jonathan Smith, executive director of TimberMart-South.

TimberMart-South is a timber price reporting service that covers pricing from eastern Texas to the Southeast.

“If you look at it from a South-wide level, your stumpage prices are up about 2.5% year over year,” Smith adds.

Smith says with a hyperlocal market, as you move farther south to southern Georgia, producers there are seeing stumpage prices up 12% year over year. The increase is still a far cry from the 359% surge in lumber prices, a scenario that’s leaving even industry insiders stumped.

“That’s a good question,” Smith says, when asked why lumber prices are skyrocketing. “I think probably that’ll be in the economics books in the future. There’s a lot of market stuff that’s going on right now.”

Smith says inventories were tight leading into COVID-19, but he says there’s still a lot of wood available today.

“There’s a lot of timber on the stock, inventory growth to dry,” says Smith. “We’re good at doing what we do in the South. We are growing more than we’re harvesting on an annual basis.”

For David Mercker, University of Tennessee Extension forester , it’s a complex issue that boils down to one main economic principle.

“From a broad perspective, it’s fairly simple as with all commodities; it’s a supply and demand issue,” says Mercker.

While there are a lot of standing trees, Mercker says there’s an issue in getting that product processed.

“We have an ample supply of standing trees or timber,” adds Mercker. “But that doesn’t necessarily correlate with an ample supply of lumber.”

Mercker says it boils down to three different bottlenecks, and it all starts with a labor shortage.

“There’s an under-supply of labor at all levels in this industry, whether it’s logging, mills or truckers,” says Mercker. “I spoke with a mill operator recently who said he hired five people, and he said one person showed up for work, and they worked for two days. So, that’s a big issue.”

Mercker says the wet weather in the Southeast this winter also put a damper on harvest.

“And that makes it difficult for loggers,” he says. “They have to follow best management practices. And so, they can’t just run up on the property and contribute mud to the waterways and so forth.”

The final issue he says deals with the byproducts. “Millers can’t get rid of sawdust and chips,” says Mercker.

“I spoke with one mill operator, he said he’s operating at about 80% mill capacity because of all these obstacles that he’s facing right now,” he says.

The one factor that’s not an issue is the number of trees available to harvest. An abundance of trees today sprouted from an increase in the conservation reserve program (CRP) more than a decade ago.

“If we can’t produce enough wood because of labor shortages, then that’s going to keep prices high,” says Mercker.

As the bottlenecks produce higher lumber prices, those in the timber industry say they hope higher prices don’t scare off demand.

“From that perspective, a lot has got to happen on the consumption side in order to get that in a balance like we were in the mid 2000s,” says Smith.

As the lumber industry tries to find a balance, the housing industry continues to explode.

“Nobody knows what the future will hold,” says Smith. “We don’t know if this is a new normal, or if things will go back.”

Related Stories:

Continuing Coverage: Crop Protection and Ag Products in Short Supply

CDC Releases Checklist for Creating a COVID-19 Control Plan on Farms

Fri, 20 Nov 2020 03:07:08 GMT

The Centers for Disease Control and Prevention (CDC) this week published a checklist for agricultural employers to use to prevent and slow the spread of COVID-19. The checklist , developed by the CDC and the U.S. Department of Labor assists employers with applying specific preparation, prevention and management measures on their operation.

The checklist is broken into five sections:

• Section 1: Assessment

• Section 2: Control Plan based on the Hierarchy of Controls

» Screening and Monitoring Workers

» Managing Sick Workers

» Addressing Return to Work after Worker Exposure to COVID-19

» Engineering Controls

» Cleaning, Disinfection, and Sanitation

» Administrative Controls

» Personal Protective Equipment (PPE)

• Section 3: Special Considerations for Shared Housing

• Section 4: Special Considerations for Shared Transportation

• Section 5: Special Considerations for Children

Employers can use the list to reassess, update, and modify your assessment and control plan on a regular basis or as conditions change.

Eric Conn, founding partner at law firm Conn Maciel Carey LLP and chair of its chair OSHA workplace safety group, says employers should be aware that OSHA has not released standards specific to workplace safety and COVID-19. However, the agency is using the general duty clause as an enforcement tool.

Here are Conn’s top three reasons every employer should have a single COVID exposure control/response plan in writing:

1. Your employees are scared. Having a written plan gives them comfort and abates the incredible amount of angst right now. It demonstrates to your team that you’ve taken your response seriously and put a lot of thought into it.

2. It helps in your dealings with OSHA. By having a documented plan, it shows the agency the steps you have taken, and it can help defend actions you’ve taken.

3. We are on the verge of seeing a tidal wave of litigation. Conn expects more wrongful death, personal injury suits, and more litigation about employee’s and their family members becoming sick. Having a good, effective and coherent action plan will buy your outline for a defense.

“Having a written exposure plan, it’s just like lock out/tag out or an emergency action plan,” he says.

Conn shared his insights into the OSHA guidance and workplace health and safety issues during a webinar hosted by the National Grain and Feed Association and Grain Journal. He says the developing regulations around workplace health and safety issues and COVID-19 has been akin to “building the car while driving down the highway.”

Check Out Day Three of Farm Journal Field Days

Wed, 11 Nov 2020 05:22:17 GMT

Farm Journal Field Days will be back starting at 8 a.m. CDT tomorrow morning! Here are a few highlights for another fun-filled and information-packed day.

Login to Farm Journal Field Days Now !

Thursday’s agenda highlights include:

8 a.m.

Early Riser Session: The New Normal – Managing Consumer Preference and Environmental Concerns in a Post-COVID-19 World ( Learn more. )

9 a.m. - Noon

Keynote: Resiliency – How to Live “All In” and Overcome Obstacles with Gian Paul Gonazlez ( Learn more. )
Behind the Scenes at Newcomer Farms
“U.S. Farm Report” Roundtable: How to Play Grain Marketing Offense Heading Into Harvest

Noon

Farm Journal Live & #FarmON Highlights
2020 Election Preview: Watch These Races and Issues with Pro Farmer’s Jim Wiesemeyer
Panel: Is the U.S. Too Dependent on Corn?

3:30 p.m.

Future of Farming: Regenerative and Climate Positive Agriculture

4:15 p.m.

Networking at the Beer Garden hosted by This Farm Wife Meredith Bernard and featuring a guest Mixologist

Plus...check out the learning pavilions for specialized content and product showcases you can view live and on demand

Crop Pavilion
Livestock Pavilion
Business & Grain Marketing
Technology & Machinery
Ag Retail
Lifestyle & Rural America
Machinery Pete
Farming for Today + Tomorrow

Don’t forget to visit the Expo Hall where you can visit leading ag businesses and event sponsors.

As a registered attendee you have a chance to win one of 1,000 prizes throughout the Farm Journal Field Days virtual event!

We look forward to seeing you there! For the best Farm Journal Field Days virtual event experience, login via desktop computer or ipad.

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Farm Journal Field Days is a new farm show designed to provide farm and ranch leaders across America with three days of virtual discussion, tours, solutions, entertainment and information from key industry leaders that is accessible from anywhere. It’s taking place this week – Aug. 25-27. Register now to join the fun!