Board of Health

Stanley Remiszewski, chair
Judy Kohn

Dear All Wildlife Advocates: 

After many, many months of efforts by you and hundreds of others - the very benign, very modest Hawkins bill (towards better protection of Massachusetts wildlife via better poison control) remains stalled in Beacon Hill.  To say this is frustrating is beyond understatement, especially right now when we've just learned of the poisoning of yet another magnificent Massachusetts raptor - a Great Horned Owl, in Arlington.

The stalled Hawkins Bill notwithstanding, there is something we all can do now towards saving our raptors and it costs nothing except some of your time.  And it's at the Federal level. 

You see the EPA has just issued their Proposed Interim Registration Review Decision (PID) - (click here to read) - for Seven Anticoagulant Rodenticides, that are wreaking havoc on our treasured raptors.  Indeed the same rodenticides that are showing up in all (100%) of our preeminent rodent controllers in Massachusetts - the Great Horned Owls and the Red Tailed Hawks.

What this means is that it's an opportunity now for us to comment on this PID and insist that the EPA take stronger action.

For example, notwithstanding proposed limitations on non-professional purchase of these poisons by consumers at brick & mortar retailers - Amazon will readily provide anyone with these same poisons over-night and I personally do not see how this will change via the PID.

On another point that the PID puts forth - i.e. that exterminators will be required to do carcass collection towards avoid secondary non target animal poisoning - the only carcass collection evidence I've seen is via poisoned raptors, foxes, pumas etc whose collection efforts resulted in their death.  I would never trust an exterminator to beat out our raptors in finding poisoned rodents - IMO it just will not happen.

There's many more points to challenge/propose.

If you want to write a comment to the EPA, please follow these instructions:

  1. Go to Regulations.gov
  2. In the search box, put in EPA-HQ-OPP-2015-0767. That's the docket for brodifacoum, one of the most toxic SGARs.
  3. Look for "Pesticide Registration Review: Proposed Interim Decision for the Rodenticides".
  4. Click the Comment Box below on the left side.
  5. Write in your comment.
  6. Fill out the rest of the boxes, include any supplemental files you need to, if appropriate, and then click the "you're not a robot" button and finally hit the submit button.
  7. You do need to repeat the process for each PID cited rodenticide.

Some advice:

A comment that expresses support or disagreement for a particular action provides general feedback to EPA.  However, a comment that is constructive and provides information to support an argument is more likely to inform EPA’s decision-making process. Be concise but support your claims. 

Explain your views as clearly as possible, avoiding the use of profanity or personal threats. Explain why you agree or disagree; suggest alternatives and substitute language for your requested changes. Provide specific examples to illustrate your concerns and suggest alternatives.

Base your comments on sound reasoning, scientific evidence, and/or how you will be impacted by the agency’s proposal. Describe any assumptions and provide the technical information and/or data that you used. If you estimate potential costs or burdens, explain how you arrived at your estimate in sufficient detail to allow for it to be reproduced. 

The comment process is not a vote – one well-supported comment is often more informative to the agency than a thousand form letters. Indeed - to be effective therefore - we are all going to have to make unique and original comments.

We have until February 13, 2023 to submit our comments.

 

Last updated 12/2022