PFB EPA Rodenticide Comments

Feb. 13, 2023

Melanie Biscoe
Pesticide Re-Evaluation Division (7508P)
Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001

RE: Pesticide Registration Review: Proposed Interim Decisions for the Rodenticides (#EPA-HQ-OPP-2017-0750)

Dear Ms. Biscoe:

Pennsylvania Farm Bureau (PFB) is pleased to offer its comments on the on the proposed interim decisions for the following rodenticides: Brodifacoum, bromadiolone, bromethalin, chlorophacinone, cholecalciferol, difenacoum, difethialone, diphacinone (and its sodium salt), strychnine, warfarin (and its sodium salt), and zinc phosphide (#EPA-HQ-OPP-2017-0750).

PFB is the Commonwealth’s largest general farm organization, representing over 30,000 members engaged in all manner of agricultural activities, including the production and processing of crops; the production and processing of animals; the production and processing of forestry products; landscaping and horticultural services; agriculture-related support services; and food manufacturing.

PFB supports farmer participation in Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) registration discussions on all products important to U.S. agriculture. We believe that implementation and defense of the FIFRA should be based on credible scientific information in order to benefit farmers, the environment, and the public as the sole federal regulatory authority over pesticides.

Consequently, we note that we oppose making all bulk rodenticides restricted use products (RUP); and likewise oppose EPA making product or label decisions based solely on a “likely to adversely affect” determination during EPA’s biological evaluation. Finally, we would recommend that professional and agricultural use rodenticides containing first-generation anticoagulants, bromethalin, cholecalciferol or zinc phosphide be available for sale in single-use quantities.

PFB appreciates the opportunity to advocate on behalf of our membership on this critical issue and thanks you for considering our comments.

Best regards,

Grant R. Gulibon
Regulatory Affairs Specialist