EPA Releases Rodenticide Strategy, Including Final Biological Evaluation
The U.S. Environmental Protection Agency (EPA) has released the final biological evaluation (BE), and associated response to comments, for 11 rodenticide active ingredients. The mitigation measures described in this final BE will also serve as the agency’s Rodenticide Strategy as outlined in EPA’s Endangered Species Act (ESA) Workplan. According to EPA, each year rodents cause significant damage to property, crops, and food supplies. They may also spread diseases, posing a serious risk to public health. Rodenticides are used in residential, agricultural, and non-agricultural settings to control a variety of pests including house mice, Norway rats, roof rats, moles, voles, pocket gophers, prairie dogs, ground squirrels, feral hogs, and mongooses.
The 11 rodenticides evaluated in the BE are: chlorophacinone; diphacinone and its sodium salt; warfarin and its sodium salt; brodifacoum; bromadiolone; difenacoum; difethialone; bromethalin; cholecalciferol; strychnine; and zinc phosphide. These rodenticides are intended to control target animals using different biochemical mechanisms (e.g., neurotoxicity, reduced blood clotting). EPA’s final BE finds that the currently labeled uses of the 11 rodenticides evaluated in this assessment remained the same as those in the draft BE, and:
- Will have no effect on 88% of species and 95% percent of critical habitats;
- Are not likely to adversely affect 4-11% of species and 1% of critical habitats;
- Are likely to adversely affect 1-8% of listed species and 4% of critical habitats; and,
- Have a likelihood of future Jeopardy/Adverse Modification (J/AM) of less than5% of listed species and less than 1% of critical habitats.
The final BE describes several scenarios intended to illustrate how EPA may implement mitigations from the Rodenticide Strategy as each rodenticide goes through registration review and for new active ingredient registrations. It provides additional clarity regarding the applicability of each mitigation measure to each rodenticide product and use, and how EPA anticipates implementing these measures. The final Rodenticide Strategy does not itself impose any requirements or restrictions on pesticide use. Any mitigation measures needed to address potential likelihood of future J/AM for listed species will only apply in geographically specific areas where listed species with J/AM predictions are located, using EPA’s Bulletins Live! Two system, as part of label language, or in the Terms and Conditions of registration.
The Association has already been in contact with CDFA as we evaluate the impact of these regulations on the tree nut industry.
Welcome to WAPA
Governor Signs Ag Overtime Bill
Ignoring the pleas of real farmworkers and the agricultural industry, Governor Edmund G. Brown Jr. today
signed AB 1066, the ag overtime legislation. This means that California will have the most stringent trigger
of any state in the country for overtime for farmworkers, with 45 states having no overtime protection at
all. The Governor signed this bill, supposedly to bring “equality to all workers”, yet taxi cab drivers,
commercial fishermen, car salesmen, student nurses, computer programmers, and carnival workers all work
without any overtime provisions whatsoever. The Governor signed this ag overtime bill in the same year that
minimum wage legislation was also passed that will take California to the highest minimum wage as well as
legislation forcing California to adopt additional greenhouse gas regulations for businesses in California.
California is the only state in the country subject to such regulations. Today’s signing occurred despite
numerous requests by the agricultural industry to meet with the Governor to discuss our concerns. The
message is clear. California simply doesn’t care. These provisions will be phased in over the next few years
ending with the overtime provisions to be triggered at 8 hours per day and 40 hours per week.
In the Beginning
As folks transitioned out of cotton and into tree nuts, the industry recognized the need to have active and
effective representation at the local, state and national levels. Having enjoyed such effective
representation over the years from the California Cotton Ginners and Growers Associations, these folks
yearned for the same representation in the tree nut processing industry. Issues such as air quality, food
safety, labor, taxes, employee safety, and environmental concerns are at the forefront, and there is a
significant need for an aggressive and dynamic Association to lead the industry into the next decade and
beyond. In recognition of this, the Western Agricultural Processors Association was created in 2009.
The Western Agricultural Processors Association (WAPA) shares staff and office space with the California
Cotton Ginners and Growers Associations taking advantage of a unique and opportunistic situation. WAPA is a
voluntary dues organization with four shared staff and one dedicated staff person. Regulatory, legislative
and legal issues fall under the purview of this new organization for the tree nut processing industry, which
includes almonds, pecans, pistachios and walnuts. From air quality permits to conditional use permits, from
regulatory hearings on greenhouse gases to federal legislation on food safety, and from OSHA violations to
assisting members on hazardous materials business plans, no issue is too small or too large for WAPA. WAPA
has assembled one of the best and most capable staffs in the industry, and the results are already starting
to show
Membership
The Western Agricultural Processors Association represents facilities involved in the processing of almonds,
pecans, pistachios and walnuts.Membership in the Association is classified as Regular memberships are
limited to almond hullers or processors, pecan and pistachio processors, and walnut dehydrators and
processors.
Associate memberships are limited to any individual or business entity which is not engaged in agricultural
processing, but which provides products or services directly related to the agricultural processing
industry. WAPA Associate members include, but are not limited to, commodity brokers, accounting firms, and
insurance brokers.
Organization
The Western Agricultural Processors Association is governed by a Board of Directors, elected by its
membership.The Board consists of up to 15 members from throughout the state, and throughout the industry.The
Board meets on a quarterly basis and conducts an Annual Meeting in the spring of each year.WAPA, in
conjunction with the California Cotton Ginners and Growers Associations, conducts a special training school
for its members focused on safety.In combination with the school, the Association holds a Labor Management
Seminar for all of the managers.
Consulting Services
In researching and considering the concept of forming a new organization, the Boards of Directors for the
California Cotton Ginners and Growers Associations instructed staff to perform some of the work on a
consulting basis first. The point was to determine the workload from consulting and to determine if there
was sufficient interest. In November of 2007, the Association began conducting services under consulting
contracts for such services as air quality permits and safety plans.The effort has been so successful that
demand has progressed outside the tree nut industry into other agricultural processing facilities, including
vegetable dehydration facilities, tomato processing facilities, and wheat mills, as well as cotton gins in
Arizona.It was determined by the new Board of Directors of WAPA, that WAPA would maintain the consulting
services to provide offsetting income to help with the expenses of getting the new organization up and
running.Today, WAPA provides for a long list of satisfied clients in the agricultural processing industry,
by providing critical services such as air quality, safety, food safety, and environmental issues (Hazardous
Materials Business Plan, Spill Prevention Control and Countermeasure Plans, etc.).