January 11, 2008
January 11 2008 - The American Sheep Industry Association (ASI) filed comments on Jan. 2, 2008, to the Environmental Protection Agency (EPA) adamantly supporting the continued registration of sodium cyanide capsules for M-44 devices and sodium fluoroacetate (Compound 1080) for livestock protection collars.
The EPA received a petition last year from animal rights groups requesting the agency cancel all uses of sodium cyanide capsules and Compound 1080 claiming that these substances cannot perform their intended functions without causing unreasonable adverse effect on the environment and posing an imminent hazard. The EPA is requesting comments from interested parties in response to this request.
ASI provided the agency with several scientific reviewed articles and studies pertaining to predator management and lethal controls including research findings stating that the lack of adequate control results in a 29 percent death loss of lambs.
ASI strongly cautioned the agency on any use of the petitioners data given the gross inaccuracies and misrepresentations present in their information. An example is the petitioners claim that the effectiveness of M-44s is miniscule. ASI relayed that M-44s are the second most effective coyote control tool in America. With coyotes being the dominant predator of sheep, the impact of losing this tool would have a significant impact.
Industry comments also corrected the petitioners' use of the U.S. Department of Agriculture's Livestock Loss reports. ASI clarified that these reports show the number of sheep and cattle losses to predators with current predator controls in place and yet hundreds of thousands of livestock are killed by predators.
ASI and the state sheep associations are working diligently to assure that the EPA is provided accurate information as it relates to M-44s and Compound 1080 and are asking farmers and ranchers to let your voice be heard by submitting comments supporting registration of these tools based on their experience with predator control.
Federal officials anticipate that EPA will extend the comment period from January 15 until March 5, 2008; however, a formal notice of this intent has not yet been published. Producers and livestock associations are encouraged to file their comments in a timely manner. Upon confirmation of an extension of the comment period, it is advised that organizations follow up with their membership letting them know of the opportunity for additional operators to comment.
As of January 10, there are nearly 250 comments posted to EPA on this topic.
Access to the original Federal Register
can be obtained at http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-22369.htm
To submit your comments via mail, the following address should be used: Office of Pesticide Programs (OPP); Regulatory Public Docket (7502P); Environmental Protection Agency; 1200 Pennsylvania Ave., NW; Washington, D.C. 20460-0001. Also include this additional information in a subject line to assure proper handling: 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.
Electronic comments can be submitted by going to http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&d=EPA-HQ-OPP-2007-0944-0010
. Click on the orange symbol next to "Add Comments" and type in your comments. You will be asked to identify your comments by docket identification number EPA-HQ-OPP-2007-0944.