CLFP Challenging EPA Pest Management Regulations

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CLFP is part of an industry coalition that is challenging several provisions of U.S. EPA regulations regarding the use of rodenticides at commercial facilities. Of specific concern to CLFP is a new requirement that rodenticide bait stations must be used within 50 feet of buildings. EPA added this provision out of concern that pets or wild animals in the vicinity may ingest rats that have consumed the poison and keeping the bait stations in close proximity to buildings may limit that risk. CLFP contacted EPA to oppose this new standard for two reasons.

First, tomato paste processors store large quantities of finished product outdoors in sealed containers in storage bins. The high volume of vehicle traffic around processing facilities and the very large number of bins involved usually precludes storing the bins within 50 feet of buildings. Food safety inspectors expect the rodent population to be under control where the bins are stacked. So, to avoid any potential rodent infestation the tomato paste processors have deployed rodenticide bait stations at the most effective locations and also use good site management and sanitation practices. EPA’s regulation would stop tomato paste processors from using bait stations in many cases and potentially cause food safety compliance issues.

Second, most food processing plants locate their dumpsters and trash receptacles away from buildings to reduce the potential for rodent and pest populations developing next to food facilities. Moving the dumpsters closer to the buildings to meet the EPA 50-foot limit for bait stations would run counter to good sanitation and rodent management practices. CLFP assumes that EPA did not fully consider this issue when developing the regulations, as it will be impractical and potentially unsafe to implement.

CLFP requested that EPA provide an exemption from the 50-foot limit for food processing facilities. The primary concern of all food processors is to manage their facilities in a manner that will consistently provide safe and wholesome food to consumers. EPA’s proposal is not consistent with industry practices and good sanitation. CLFP believes that processing plant managers and local pest control advisors should be allowed to use their best professional judgment as to where to best place rodenticide bait stations at a food facility. CLFP and the industry coalition will be working with EPA to address this issue and find a common sense solution.

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