Rodenticides; Notice of Availability of Proposed Mitigation Decision

May 17, 2007 Ms. Kelly Sherman U.S. Environmental Protection Agency Ariel Rios Building 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460 Re: Docket No. EPA-HQ-OPP-2006-0955 ? Rodenticides; Proposed Risk Mitigation Decision; Extension of Comment Period Dear Ms. Sherman: I am writing on behalf of the American Veterinary Medical Association (AVMA), to ascertain additional knowledge of the EPA?s proposed regulations regarding rodenticides, and to consider their potential ramifications on animal health and public health. The goal of the proposed EPA regulations is to help protect the safety of children and wildlife, by ensuring that rodenticides are contained within tamper-resistant bait stations. In addition, while the public would still have access to first-generation anticoagulant rodenticides, second-generation rodenticides would be applied only by certified applicators under the proposed regulations. The AVMA applauds the EPA?s efforts to ensure the safety of our nation?s children, as well as our wildlife and endangered species. As the EPA progresses in its regulation of rodenticides, the AVMA asks the EPA to evaluate the potential risk of unintended consequences on animal health and food safety. Changes in the availability of various rodenticide formulations might affect rodenticide use and effectiveness in animal agriculture. For example, trichinae and Toxoplasma sp. are capable of causing significant and sometimes fatal food-borne diseases from pork products, but effective rodent control in swine facilities has been pivotal in controlling these organisms in the food supply. In addition, effective rodent control is essential in controlling the exposure of poultry to Salmonella spp. The AVMA wants to be certain that the public is not only protected from rodenticide exposure, but also from diseases that can be prevented with effective rodent control. As animal agricultural settings might be affected by new rodenticide regulation differently than residential settings, the AVMA wants to be certain that there would be no unintended adverse effects on animal health and public health through the food supply. The AVMA advocates a science-based food safety system from farm to fork, including raising animals in healthful environments with close professional monitoring to prevent traumatic, infectious, and parasitic diseases and chemical residues. Thank you for your time, and for providing a greater understanding of the EPA Office of Pesticide Programs regulatory considerations regarding the use of rodenticides in animal settings to the AVMA Food Safety Advisory Committee. Please contact Dr. Lynne White (lwhite@avma.org or 800-248-2862 ext. 6784) at the AVMA Scientific Activities Division with any information that might help the AVMA?s Committee to gain additional insight on the EPA rodenticide regulatory considerations, and feel free to contact the AVMA if you have any questions or concerns or if we can provide any additional information for you. Very respectfully, Elizabeth Curry-Galvin, DVM Director, Scientific Activities Division American Veterinary Medical Association ECG/LAW CC:Ms. Kathy Davis, EPA Dr. Angela Demaree, AVMA Governmental Relations Division Dr. Lyle Vogel, AVMA Animal Welfare Division Dr. David Smith, AVMA Food Safety Advisory Committee Chair Dr. David Jessup, AVMA Committee on Environmental Issues Chair