Enforcement Branch

March 14, 2000							  ENF 2000-010


TO:       County Agricultural Commissioners

SUBJECT:  DRAFT SUGGESTED PERMIT CONDITIONS FOR METAM-SODIUM APPLICATIONS 


The Department of Pesticide Regulation (DPR) is proposing suggested permit 
conditions (conditions) for applications of metam-sodium.  These conditions 
would be in addition to the current labeling, which includes a Technical 
Information Bulletin (TIB).  The conditions pertain to metam-sodium 
applications using shank, sprinkler, and flood methods.  Attached is a 
draft of the proposed conditions for your review.
   
The Metam-Sodium Task Force requested DPR to consider conditions for 
metam-sodium applications to address issues that were not covered by the TIB.  
The Task Force recently submitted their proposed permit conditions to DPR 
along with a "Metam-Sodium Inversion Chart For Sensitive Areas" and 
"Metam-Sodium Application Summary" (copies attached).  DPR staff reviewed 
and revised the Task Force’s proposed conditions.  DPR also reviewed the 
inversion chart and determined it lacked clarity and, if followed, would not 
ensure mitigation of problems resulting from potential inversions.  Although 
DPR agrees the "Application Summary" could be a useful record, mandating its 
use would be subject to form management requirements specified in the State 
Administrative Manual.  Therefore, DPR encourages applicators or persons 
conducting post-application monitoring to use the "Application Summary" to 
document the information required by the conditions, as opposed to requiring 
that it be used.

The Task Force advised DPR of proposed studies they have scheduled for 
spring 2000.  Following the proposed studies, the Task Force intends to submit 
additional data pertaining to buffer zones.  Based on a review of the data, 
buffer zones proposed in the draft conditions may be amended to decrease or 
increase distances between the application and sensitive areas.

If you have questions or want to submit written comments, you may contact 
Ms. Nancy Grussing, of my staff, at (916) 445-3866, or by e-mail at 
ngrussing@cdpr.ca.gov.

Sincerely,

original signed by

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

Attachments

cc:  Mr. Daniel J. Merkley, Agricultural Commissioner Liaison (w/Attachments)
     Ms. Nancy Grussing (w/Attachments)

NG

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