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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