Bill Threatens Life Sciences Industry’s Ability to Keep Facilities Rodent-Free

By Brett Johnson
June 18, 2019

Assembly Bill 1788, authored by Assemblymember Richard Bloom (D – Santa Monica), would prohibit the use of second-generation anticoagulant rodenticides (SGARs) throughout the state and also prohibit the use of first-generation anticoagulant (FGARs) rodenticides on state-owned property. The bill cites state findings of related toxins in dead wildlife as the impetus for the bill.

The SGARs targeted by AB 1788, however, are one of the, if not the, most effective tools in controlling rodent populations. They also form roughly half of the active ingredients currently available in California to combat rodent infestations, meaning a substantial loss to many rodent control plans.

For the life sciences industry in California, rodent control is incredibly important, as the federal Food and Drug Administration (FDA) expects all facilities handling drugs and medical devices, among other FDA-approved products, to be free of rodents. For good reason, there is no tolerance for rodent-introduced impurities when, for instance, the facility is producing injected medicines or implanted medical devices. This means the presence of rodents in a facility could lead to the (at least a temporary) shutdown of a facility until issues are corrected, which is a substantial risk for any California-based life sciences company.

CLSA has been working with the proponents of the bill, as well as with our partners in other industries, including healthcare providers, in an attempt to identify exemptions that make sense given the author’s and proponents’ stated interest in maintaining and protecting the public health. The statute already includes exemptions for those engaged in “agricultural activities,” which includes canning and winemaking, among other things, despite their greater prevalence in rural areas with closer proximity to wildlife of concern.

The bill will next be heard this month in the Senate Environmental Quality Committee. CLSA will continue coordinating opposition and amendment efforts on the bill in the hopes of coming to an acceptable resolution for both sides.

Any CLSA members who would like to provide input or would like further information on AB 1788 are asked to reach out to Oliver Rocroi, CLSA’s Senior Director, State Government Affairs ( or Brett Johnson, CLSA’s Senior Director, Policy & Regulatory Affairs (