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June 22, 2000

ENF 2000-026

TO: County Agricultural Commissioners

SUBJECT: LABEL INTERPRETATIONS AND PERMIT CONDITIONS FOR THE USE OF S, S, S-TRIBUTYLPHOSPHOROTRITHIOATE (TRIBUFOS)

Approved labeling for Tribufos products contain the statement, "(Tribufos) may not be applied within seven (7) days of harvest." The Department of Pesticide Regulation (DPR) considers this enforceable pre harvest interval (PHI) language. Any harvesting activity occurring before seven days after an application of Tribufos, is a violation of Food and Agricultural Code section 12973 (use in conflict with labeling). This PHI provides adequate protection for harvester crews.

For the protection of employees who may conduct other activities that could involve contact with foliage, including some non-hand labor activities, the following permit condition is recommended.

No employee shall be directed or allowed to conduct any activities that may involve human contact with foliage, within the treated area, until seven days after an application of tribufos.

If you have any questions pertaining to this label interpretation and recommended permit condition, please contact the Senior Pesticide Use Specialist serving your county.

Sincerely,

original signed by

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

NG