Comments Needed on Cattle Spray Boxes to Control Fever Ticks

In September, the Texas Department of Agriculture (TDA) submitted a proposed rule that will require products containing coumaphos, with an active ingredient of 42% by weight, to be applied in a ventilated area. Coumaphos is the active ingredient in Co-Ral® Flowable Insecticide used exclusively by the state-federal Cattle Fever Tick Eradication Program (CFTEP) to dip and spray cattle. The product label already states that the insecticide must be applied in a ventilated area, but TDA has reinterpreted this statement to mean that the cattle (not the human applicators) must be in well ventilated area. TCFA opposes TDA’s new label interpretation because it would prevent the CFTEP from using spray boxes to control fever ticks.
TCFA urges members to file comments opposing TDA’s proposed rule. The deadline to submit comments is this Friday, November 30. 
Below is a sample letter that can be copied and pasted into an email toRuleComments@TexasAgriculture.gov. Feel free to personalize the email and alter it as you see fit.
Please contact Josh Winegarner at (806) 358-3681 with any questions.
Thanks
______________
Mr. Philip Wright
Administrator for Agriculture and Consumer Protection
Texas Department of Agriculture
Dear Mr. Wright:
Thank you for the opportunity to comment on TDA’s proposed rule concerning the application of coumaphos to control fever ticks. I am a cattle producer and I oppose the adoption of the proposed rule because it is redundant, unnecessary and would prevent the USDA-APHIS and the Texas Animal Health Commission (TAHC) from using spray boxes to control fever ticks.
Co-Ral, a coumaphos product, has been used exclusively by USDA-APHIS and TAHC to dip and spray cattle for over 40 years and is the only proven way to control the spread of fever ticks. The use of Co-Ral in spray boxes is an important tool for those producers whomust treat their cattle but do not operate near a dipping vat. I do not understand the need for this rule given that the Co-Ral label already states: Do not spray in confined, non-ventilated areas. Likewise, I do not understand what the proposed rule is intended to accomplish. Based on comments made by Commissioner Miller, it appears that he is concerned that the use of Co-Ral in spray boxes is harmful to cattle. However, USDA-APHIS and TAHC have both stated that they have no evidence of any cattle health issues related to spray boxes.
Commissioner Miller also has indicated that the spray boxes do not provide enough ventilation and the use of Co-Ral in the spray boxes is a violation of the product label. However, USDA-APHIS has long held that the label’s reference to ventilation was intended for the safety of the applicator. The Environmental Protection Agency (EPA), which issued the label, recently confirmed this in a letter which explained that their authority applies to human safety and the environment, not animal health.
I am concerned that the Commissioner’s new interpretation of the label and the proposed rule will prevent the continued use of Co-Ral in spray boxes. This would be a majorsetback and hindrance to our ability to effectively control fever ticks and would cost cattle producers more money due to increased transportation costs to move cattle to dipping vats. Therefore, I urge you to withdraw the proposed rule.
Sincerely,
[Add name and address]
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