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March 10, 2000

ENF 2000-007

TO: County Agricultural Commissioners

SUBJECT: RICE PESTICIDES PROGRAM FOR YEAR 2000

The year 2000 suggested permit conditions for the molinate (Ordram) worker safety requirements, the rice water-holding requirements, and the drift control requirements for certain rice pesticides will remain the same as they were for 1998. Please refer to enforcement letter ENF 98-010 (copy attached).

We are in the third year of a three-year review period as adopted by the Central Valley Regional Water Quality Control Board's (Regional Board's) Resolution No. 98-024 in which the Regional Board approved water quality management practices for the 1998 through 2000 rice seasons.

Last year, the University of California and Department of Pesticide Regulation (DPR) prepared a brochure entitled, Seepage Water Management, Voluntary Guidelines for Good Stewardship in Rice Production, Publication 21568. Please continue distributing the brochure to growers at the time of permit issuance.

Furadan 5G Use Status

It is DPR’s understanding that the California Rice Commission has requested that the U.S. Environmental Protection Agency (U.S. EPA) grant the use of existing stocks of Furadan 5G for the 2000 rice growing season. To date, DPR’s Pesticide Registration Branch has not received written confirmation from U.S. EPA approving this request. Last year, U.S. EPA modified the terms and conditions of FIFRA section 3 registration for the carbofuran technical, U.S. EPA Registration No. 279-3060, to allow for a limited amount of carbofuran to be used in the production of Furadan 5G for use on rice in California during the 1999 use season. The Furadan 5G produced under this authorization was labeled "For use in California only. Not for use after August 31, 1999." Until U.S. EPA approves the use of existing stocks for the 2000 rice season, any use of Furadan 5G on rice would be "in conflict" with labeling and a violation of Food and Agricultural Code section 12973.

Two new active ingredients, lambda-cyhalothrin (Warrior) and diflubenzuron (Dimilin), were registered and used as alternatives to Furadan on rice last year. These rice pesticides are currently registered for use on rice for this growing season. The registrants, Zeneca (Warrior) and UniRoyal (Dimilin), will conduct water quality monitoring for these products during the 2000 rice pesticide application season.

Seepage Monitoring

In addition to the routine rice pesticide monitoring, DPR’s Environmental Hazards Assessment Program will conduct water quality monitoring to determine if thiobencarb is present in seepage water. Water samples will be collected at one site each in Glenn and Colusa Counties, one time per week, for a ten-week period. The Regional Board is concerned about the increasing trend of thiobencarb use, and detections at CBD5, that show an increase in the length of time thiobencarb concentrations are exceeding the performance goal (1.5 ppb) during the use season. The Regional Board does not recognize DPR’s current voluntary seepage program as an approved water management practice if the seepage water contains rice pesticides. DPR will address this issue with the Regional Board for the upcoming triennial review of the rice pesticides program.

Phenoxy/Dicamba Use Status

The status of phenoxy/dicamba use on rice in the Sacramento Valley region will remain the same as last year. The Office of Administrative Law (OAL) did not approve the proposed Sacramento Valley phenoxy/dicamba regulation package submitted to OAL on December 11, 1998. Therefore, DPR recommends that commissioners continue using the 1998 Sacramento Valley phenoxy/dicamba emergency regulation, Title 3, California Code of Regulations section 6464 (d), as suggested permit conditions to phenoxy/dicamba restricted material permits for this year.

Shark 40 DF Use Status

DPR is currently reviewing the Section 3 registration for Shark. The proposed Shark Section 3 registration will be limited to ground use only. DPR is currently reviewing the Shark investigation submitted by the Pesticide Enforcement Branch’s Northern Regional Office. After this review, DPR will recommend mitigation measures to control the use of Shark to prevent off-site movement onto sensitive crops.

DPR data reporting guidelines for the 2000 rice pesticides program will be sent to commissioners in the rice-producing counties as a separate letter. If you have any questions concerning rice water-holding requirements, the suggested molinate worker safety permit conditions, Furadan 5G, phenoxy/dicamba, and Shark 40 DF, please contact the Senior Pesticide Use Specialist Liaison serving your county.

Sincerely,

original signed by

David Duncan, Acting Chief
Pesticide Enforcement Branch
(916) 445-3871

Attachment

cc: Mr. Dave Lawson, Zeneca, Inc. (w/Attachment)
Mr. Daniel J. Merkley, Agricultural Commissioner Liaison (w/Attachment)

VA