Department of Pesticide Regulation

REVISION TO VOLUME 5, INVESTIGATION PROCEDURES, PESTICIDE USE ENFORCEMENT PROGRAM STANDARDS COMPENDIUM, INVESTIGATIONS OF PESTICIDE RELATED SUICIDES/SUICIDE ATTEMPTS

This letter announces a revision to Volume 5, Investigation Procedures, of the Pesticide Use Enforcement Program Standards Compendium (Compendium). The updated volume is also available online at www.cdpr.ca.gov/docs/enforce/compend/vol_5/invstprc.htm.

The enclosed revision includes two, two-sided replacement pages:

• Page 15 - existing text with revised page 16 printed on the back
• Page 16 - revised procedures for CAC investigation of suicide/attempted suicide episodes
• Page 16.1 - f. Fatalities, existing text, formerly on page 16, with
• Page 16.2 - intentionally left blank on the back

Pursuant to the three-way Cooperative Agreement between the California Department of Pesticide Regulation (DPR), the California Association of County Agricultural Commissioners and Sealers (CACASA) and the U.S. Environmental Protection Agency, Region IX (U.S. EPA), certain pesticide incidents are categorized as priority investigations. Suicide attempts requiring hospitalization and suicides are included among the human effects criteria that have required a priority investigation by County Agricultural Commissioners (CAC). The Cooperative Agreement specifically notes that investigations of suicides and suicide attempts should follow the procedures outlined in the DPR Investigation Procedures Manual, which is now the Pesticide Use Enforcement Program Standards Compendium Volume 5, Investigation Procedures.

Background
DPR is keenly aware that suicides and attempted suicides present unique problems for CAC investigators. The current Compendium Volume 5, Investigation Procedures, states that when following up on suicides, the investigator should obtain a copy of the coroner's report and use it as the basis for his or her investigation. When following up on attempted suicides, the instructions discourage the investigator from directly contacting individuals involved due to the personal confidential and sensitive nature of these episodes. Therefore, investigators must seek out other sources - such as police records, paramedics, and physicians - for information and evidence.

Over the years, DPR's Pesticide Illness Surveillance Program (PISP) scientists have noticed from review of the Pesticide Episode Investigation Reports involving suicides and attempted suicides, that despite investigator's best efforts, the success in obtaining pertinent information and/or evidence is rather limited and the amount of time and effort that CAC staff spends on these investigations is not commensurate with the information and/or evidence obtained. More often than not, the information and/or evidence obtained by the CAC investigators are already available in initiating documents such as the California Poison Control System generated Pesticide Illness Reports.

Revised Procedure
To more efficiently use both county and state resources, rather than following up on all suicides and attempted suicides cases, the CACs will only be requested to investigate those cases the Worker Health and Safety Branch (WH&S) Pesticide Illness Surveillance Program (PISP) staff determines could uncover information of benefit or importance in our mutual efforts to protect human health and the environment from pesticides. An example of such an investigation would be a case involving Restricted Use Pesticides (RUP). In this situation the CAC would be asked to determine if a violation occurred and how the victim obtained the RUP. For details, see enclosed, revised procedures in Volume 5, Investigation Procedures.

Future Changes
As a future step, DPR, CACASA and U.S. EPA, Region IX will need to meet and agree on language to modify the USEPA Cooperative Agreement, Appendix A - Priority Investigation Effects Criteria.

The PISP staff will continue to collect, record, and classify all details of all cases involving suicide and attempted suicide and include these cases in the PISP database using information obtained from initiating documents. On occasion, CACs may receive reports of suicides and attempted suicides through local channels, for example HazMat responders. In these situations, DPR requests that the CACs contact WH&S's PISP staff about these incidents to ensure they are captured in the PISP database.

We believe that by eliminating investigations of pesticide related suicides and attempted suicides, CACs will be able to use their resources more effectively in other program areas.

Please contact your Enforcement Branch Liaison or Mr. George Farnsworth with questions or comments at George.Farnsworth@cdpr.ca.gov, or 916-445-4163.

cc:   Ms. Pam Cooper, U.S. EPA, Region IX
        Mr. Thomas Babb, DPR Agricultural Commissioner Liaison
        Enforcement Branch Liaisons