1080 and M-44s Official ASI Comments

January 2, 2008

Office of Pesticide Programs
Regulatory Public Docket (7502P)
Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, D.C. 20460-0001

RE: Comments to Docket ID Number EPA-HQ-OPP-2007-0944
Petition Requesting EPA to Issue a Notice of Intent to Cancel the Registrations of
M-44 Sodium Cyanide Capsules and Sodium Fluoroacetate
Federal Register Volume 72, Number E7-22369, Pages 64623 - 64624

The American Sheep Industry Association (ASI), the national trade organization representing the nation's sheep farmers and ranchers, opposes the petition to cancel the registration of sodium cyanide and sodium fluoroacetate for predator control. ASI rejects the claims of the petitioners as expressed in the federal register docket that sodium cyanide M-44 capsules and compound 1080 cannot perform their intended functions without causing unreasonable adverse effects on the environment and posing an imminent hazard.

The agency must exercise great caution in any use of the petitioners' information as it contains gross inaccuracies and misrepresentations of predator management and livestock production.

The registrations for predator control are supported by the U.S. Department of Agriculture's (USDA) Animal and Plant Health Inspection Service (APHIS). ASI agrees with the department that cyanide used in the M-44 ejector device and sodium fluoroacetate used in the Livestock Protection Collar are safe and effective tools for predator control.

Despite the claims of petitioners that these tools are ineffective, the M-44 is critical for coyote control in the United States. In fact, over the past ten years the M-44 is the second most effective tool in coyote control, second only to aerial control of coyotes. Coyotes are the dominant predator on sheep; therefore, removal of an effective coyote control method as requested by the petitioners would directly impact predator control and sheep farms and ranches.

Again, in direct contrast to the petitioners' claims, loss of sheep and lambs killed by predators is the single largest cause of death in the U.S. sheep industry.

The latest sheep loss survey completed by USDA's National Agricultural Statistics Service clearly defines the loss of sheep killed by predators as larger than any other cause of death including sheep dying from respiratory problems, old age or lambing complications.

Sheep killed by predators cost the nation's family farmers and ranchers tens of millions of dollars annually WITH both lethal and non-lethal predator management tools in place. Petitioners claim that the risk of predation to sheep is miniscule and is a blatant misrepresentation in the federal government sheep loss survey. The survey does not measure sheep lost to predators ABSENT of predator control or MINUS certain tools, including the M-44 ejector and the Livestock Protection Collar.

Some causes of sheep death, such as old age, are very difficult to impact through management. Therefore, causes that can be influenced, such as predator control, are even more important to sheep producers.

The petitioners appear to argue that change in predator control would have no impact on sheep losses. Taking way the second most effective tool for coyote control would obviously impact predator management and livestock production. Research shows that losses in the absence of adequate control would increase up to 28% of the lamb crop and up to 3% of the calf crop.

APHIS-Wildlife Services (WS) relies on these chemicals to selectively remove predators in proximity to livestock only when and where they can be safely used. On public land, interagency meetings between the land managing agency and WS are held annually to help identify when and where they can be safely used.

The petition does not indicate that the use of either of these pesticides causes environmental or human safety concerns. Therefore, we request the agency utilize the scientific information that supported the initial registration of these products and still continues to support their use.

On behalf of the farm and ranch families of our nation that produce lamb and wool, we appreciate the opportunity to comment and urge the agency to continue registration of sodium cyanide and sodium fluoroacetate for predator control.