October 31, 2006                                                        
                   

Ms. Kelly Sherman

U.S. EPA

Office of Pesticide Programs

Document Processing Desk

Room S-4900

One Potomac Yard

2777 S. Crystal Drive

Arlington, VA  22202

Dear Kelly,

There has been considerable activity these past couple of days among the
rodenticide stakeholders in an effort to propose a unified position on
mitigation.  This position has already been communicated to the EPA via
the Rodenticide Registrants Task Force. The National Pest Management
Association will do likewise. Bell Laboratories, Inc. supports the
position of these groups. Because I feel that it has not been fully
addressed or considered, I would like to reinforce the importance of
those engaged in farming operations. 

Farmers are businessmen and wear many hats due to the nature of their
business. They are usually engaged in a wide array of activities in
running their operation.  They are usually do-it-yourself minded and
don’t enlist in professional for hire services unless it is absolutely
essential.  This is no different when it comes to rodent control. 
Rodents are an ongoing problem on nearly all farms, including poultry,
dairy, grain, vegetable, fruit, cotton and seed operations, just to name
a few. Some farm operations include on-site food processing and
packaging which are required to be rodent free for obvious contamination
concerns. Rodents infringe on all of these types of operations in a very
significant way.  

Farmers don’t purchase their rodenticides from Wal-Mart, Home Depot
and many other chains of this type like urbanites and suburbanites are
accustomed to doing. Their purchases are at farm stores where they buy
in larger volumes because they have so much to tend to.  They also do it
for cost-savings, convenience and one-stop shopping for other items that
may be needed for their farm operation. My opinion is that farmers have
done a remarkable job in their rodent control efforts.  While many
farmers have some type of pesticide applicators license, there are many
more that do not have such a license. They are accustomed to buying
their product at the farm store and then simply placing the product
where necessary according to the label directions given.  I see them as
being very experienced and responsible and place them in a category of
someone who is required to use rodenticides as part of their job and
running their business.  They are in a unique class, different from
professional pest control operators and different from the urban
consumer. 

In the mitigation measures offered up by industry, the farmer is listed
alongside the certified applicator so that he/she will have access to
those products that have professional labels and can use these products
outdoors as well as indoors. Bell Laboratories, Inc. and the rest of the
industry supports this as illustrated in their mitigation proposal.  I
felt it important elaborate on the importance of the farming operation
segment and ask that you support their efforts by allowing continued
access to professional products for rodent control.           

Sincerely,

John Lublinkhof, Ph.D.

Director of Regulatory Affairs

Cc:  Dr. Debra Edwards

        Ms. Susan Lewis

