Harvard Law School Animal Law and Policy Clinic And Community Members Bring Petition to Ban SGARS to MA Pesticide Board 12/17/2024
You can read the full document here.
(thanks to Bonnie Tate from Save Easton Wildlife for taking the meeting notes that I used as reference for this blog post)
Summary of MDAR Pesticide Subcommittee Meeting: December 17, 2024
On December 17, 2024, the Massachusetts Department of Agricultural Resources (MDAR) Pesticide Subcommittee met to discuss the potential regulation of Second-Generation Anticoagulant Rodenticides (SGARs). The meeting was chaired by Michael Moore, who noted that in his 15 years of experience with the subcommittee, petitions like the one under consideration were a rarity, and there was no clear precedent for guidance on such matters.
Key Takeaways from the Meeting
Background on SGARs and Petition Status Richard Berman, a subcommittee member, pointed out that SGARs were discussed in October, and the committee agreed to delay action until more information could be gathered. In December, the Environmental Protection Agency (EPA) reviewed SGARs, and their assessment is ongoing. The subcommittee is working to understand the scientific and environmental implications of SGAR use more thoroughly before making any decisions.
Challenges in Evidence Gathering Taryn LaScola from MDAR explained the difficulty in proving a direct link between SGARs and rodenticide-related deaths. While the department has received calls about potential issues, the lab results often show the presence of rodenticides but don't confirm a direct cause of death. LaScola emphasized that, given the complexities of reversing registered products, it would be ideal to conduct a third-party scientific review—similar to past reviews of glyphosate and neonicotinoids. This review would be conducted by MDAR and would provide the subcommittee with an evidence-based report to guide future decisions.
Moving Forward: A Third-Party Review and Timeline With the consensus in the room, it was agreed that MDAR would hire a third-party contractor to conduct a scientific review of SGARs. The goal is to use the surplus funds before the end of the current fiscal year (June 2025). The contractor will gather relevant data and provide a comprehensive report, which will be presented to the subcommittee. Following this, the subcommittee will conduct an individual review, including the scientific findings, and vote on whether or not to impose any restrictions or bans on SGARs.
Subcommittee's Vote After discussing the motion put forward by Taryn LaScola, the subcommittee voted in favor of moving ahead with the third-party review. Richard Berman, while in agreement with the overall process, abstained from the vote, reflecting the complexity and the need for careful consideration of both the benefits and risks of SGARs.
What’s Next?
The next steps are clear: MDAR will proceed with hiring a third-party contractor to conduct the scientific review, and the subcommittee will review the findings before making a final decision on whether to limit or ban SGARs. This process ensures that the decision will be based on the best available science, with input from a broad range of experts and stakeholders.
Who's Who in the MDAR Pesticide Subcommittee?
For those who are unfamiliar with the MDAR Pesticide Subcommittee, it typically consists of five members. Today’s meeting included the following:
Michael Moore – Chair
Taryn LaScola – MDAR
Nicole Keleher – Department of Conservation and Recreation
Meg Blanchet – Department of Public Health
Richard Berman – Public Member and Commercial Pesticide Applicator (appointed by the Governor)
Looking Ahead
The subcommittee’s process ensures that any regulatory changes related to SGARs will be well-informed and based on a careful review of scientific data. This thorough approach is critical to balancing public health concerns, environmental safety, and the practical needs of pest control.
Stay tuned for more updates as the scientific review progresses and the subcommittee prepares for further discussions and votes in the coming months.