I would like to express my gratitude to the association for actively participating in addressing the proposed regulations on Site Decontamination (specifically, the eye wash issue) in response to DPR. Our collective efforts in voicing our concerns have been acknowledged. PCOC has also submitted a comprehensive letter outlining various points and objections along with their reasoning. DPR will now be required to address all the feedback received. It is anticipated that DPR will respond to the group-submitted form letter collectively, while also addressing the detailed letter point by point. As this process will take some time, we are uncertain about the timeline for the next steps. Furthermore, the nature of these next steps depends on DPR's response to the issues raised.

In addition to our involvement in the response to DPR on the Decontamination Site regulations, PCOC is actively monitoring and opposing several bills that are currently progressing through the legislature. These bills are being driven by environmental activist groups with the aim of regulating pesticide use in urban areas. Here are the bills that have been under our watch:

AB 363 (Bauer-Kahan): Neonic re-evaluation: This bill mandates DPR to complete its re-evaluation by the end of this year and develop mitigation strategies for problematic use patterns by mid-2024. However, the timelines outlined in this bill pose a significant challenge and are unrealistic. Based on history and what we know about the re-evaluation process, DPR will not be able to meet these deadlines which may result in non-compliance or hasty decisions without proper scientific backing.

AB 652 (Lee): Environmental Justice Advisory Committee for DPR: This bill proposes the establishment of an advisory committee to provide input and recommendations to the department, ensuring the protection of all groups potentially affected by pesticide exposure. The scope of potential reach of this group to influence DPR is one that we do not know.

AB 1322 (Friedman): Second Generation Anti-Coagulant and Diphacinone: This bill introduces an additional definition of Integrated Pest Management (IPM) and mandates its adherence before the use of Second Generation Anti-Coagulants (SGAR) or diphacinone. It also calls for the re-evaluation of diphacinone to assess exposure pathways and sublethal effects, as well as the establishment of a 10% detection rate on representative species before lifting the re-evaluation status. DPR has already proposed re-evaluation of diphacinone for different reasons, just the timing is what it is.

PCOC is maintaining communication with DPR regarding these bills. We disagree with these bills primarily because they contradict the Governor's veto message on AB 2146 from last year, which emphasized that all pesticide-related matters should be handled by DPR rather than through legislative processes. We will continue our active opposition to these bills and make every effort to safeguard our interests. If necessary, we will mobilize the association through a Voter Voice campaign on any or all of these bills, reaching out to our membership for support.

Darren Van Steenwyk, M.S., BCE
PCOC Legislative Committee Chair
Regional Entomologist
Sprague Pest Solutions
1 661-610-8725
dvansteenwyk@spraguepest.com