Department of Pesticide Regulation

OVERSIGHT INSPECTION PROCEDURES MANUAL

As you are aware, the Department of Pesticide Regulation (DPR) is beginning a new oversight inspection program (ENF 2002-021) which now combines the efforts of compliance assessment and overview training assessment into a single process that we expect will provide county agricultural commissioners (CACs) and DPR with information for prioritizing resources, measuring program improvements, and when identifiable, to follow-up on worker protection safety (WPS) items in previous county compliance assessment findings.

The attached procedures are for Senior Pesticide Use Specialists conducting oversight inspections of CAC staff performing pesticide inspections. They have been developed to help assure that oversight inspections are performed and documented in a consistent and uniform manner throughout the state.

In establishing this new process the inspections for fiscal year 2002/03 will be conducted primarily in four counties. Our present resources allow for us to conduct approximately 200 oversight inspections annually; however, some oversight inspections may be conducted in other counties if regional office resources allow or when requested by the CAC. Regional staff will discuss the procedures with individual commissioners and their staff prior to implementation. Please keep in mind that this is a working document and we expect that changes will be made as we proceed.

In your review and comment of the procedures, please note the following issues:

• DPR seniors will observe county inspections up to the point the county inspector has completed the inspection and signed the inspection form. The requirements portion of the county inspections should not be changed after this point in time. This is necessary to maintain the accuracy of the County Pesticide Compliance and Assessment database.
• After the county inspection is signed and before it is presented to the industry person for signing, the inspector will provide the inspection to the senior for review. At that time the senior will compare the county inspection with his or her own inspection report.
• The senior and the county inspector will briefly and discretely discuss discrepancies. If a violation was noted by the senior but not by the county inspector and the inspector agrees that the requirement was in violation, the inspector will be asked to provide the DPR inspection to the person being inspected and to use the DPR inspection report to conduct follow-up activities. In this case both the senior and the county inspector will sign the inspection report in the "Inspected By" space.
• In addition to filling out an inspection report, the senior will complete a County Oversight Summary form (COS). The COS is a departmental form (attached) that documents aspects of the county inspection program that will be used to identify training needs of the county and for evaluation of the county inspection program.
• All issues and problems identified in the inspections and/or the COS will be discussed with CAC management by the county's liaison senior and documented on the Issue Review form (attached).

These new procedures should increase the effectiveness of the oversight inspection process, more accurately assess industry compliance with pesticide laws and regulations, and identify county inspection program needs. I realize that this new way of doing business may certainly pose some concern, but hope we can mutually commit to establishing a process for the future that will better serve us all.

As always, if there are aspects of this program that present a problem for your county or you have comments or suggestions for modifying the program, please contact me or your senior liaison.

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