Determine which rodenticides a California structural pest-control company may legally use, and under what exemptions

Steps

1. Identify the three stacked anticoagulant-rodenticide bans in Food & Agricultural Code §12978.7: AB 1788 (2020, effective January 2021) prohibited the four second-generation anticoagulant rodenticides (SGARs) — brodifacoum, bromadiolone, difenacoum, difethialone; AB 1322 (2023) added the first-generation anticoagulant rodenticide (FGAR) diphacinone; AB 2552 (signed 9/25/2024, effective 1/1/2025) added the FGARs chlorophacinone and warfarin — all under the same exemption structure (verified against leginfo.legislature.ca.gov bill text and CDPR ENF 24-20, 2026-07-14).
2. Confirm none of the three bans has sunset: CDPR's SGAR/diphacinone reevaluation (opened March 2019) remains open as of mid-2026 — DPR issued draft proposed anticoagulant-rodenticide regulations in 2025 and continues publishing semiannual reevaluation-status notices (e.g., Notice 2026-05) rather than the completion certification the statute requires before restrictions can lift.
3. Check the current exemption list (CDPR ENF 24-20 letter) before any anticoagulant use: agricultural production sites under FAC §11408 (vineyards, orchards, farms, livestock/poultry operations), water-supply/hydroelectric infrastructure protection, vector-control-district public-health use, offshore invasive-species eradication, Department of Fish and Wildlife-authorized invasive-rodent control for endangered species, declared public-health emergencies, DPR/CDFA-funded reevaluation research, medical waste generators, FDA-registered drug-manufacturing facilities, and specific non-agricultural sites (food-storage warehouses, food-processing plants, factories/breweries/wineries).
4. For Branch 2 (structural) pest-control jobs specifically, confirm the use site is both on the exemption list and on the product label — routine residential, office, retail, and school jobs are prohibited for all seven listed active ingredients unless the site itself qualifies (e.g., a brewery, food-processing plant, or medical waste generator).
5. Verify permit status: exempt/allowed uses require no restricted-material permit, but county agricultural commissioners cannot issue a permit for a non-exempt use at all — there is no permit workaround for a prohibited use.
6. Re-check cdpr.ca.gov before each job cycle — DPR's 2025 draft regulation would add above-ground bait placement limits, application-duration caps, and mandatory Sustainable Rodent Management training/plans; confirm whether these have moved from draft to adopted status before relying on the current exemption list.