Cinching/Choking of the Aeration Ducting is Not an Acceptable Method When Using the California Aeration Plan

It has been brought to the Department of Pesticide Regulation’s attention that Branch 1 Structural Pest Control Companies, when using the California Aeration Plan (CAP), are closing the aeration ducting by cinching or clamping the ducting tube.

Closing the aeration duct by constriction, also known as the cinch/choke method, is NOT an approved method under CAP. Under the heading “Aeration Ducting,” CAP states:

The aeration ducting shall be constructed in a manner that maintains its minimum 18-inch diameter without being inflated by the airflow (static pressure) of the fan. The intention is for the aeration ducting to have the same internal size (cross sectional diameter) whether the fan is operating or not.

This statement requires aeration ducting to maintain a minimum 18-inch diameter, regardless of airflow or the stage in the fumigation (e.g. application vs aeration). The cinch/choke method restricts the diameter of the tubing to less than 18 inches during the application period. Thus, the cinch/choke method is a violation of the current CAP and should be cited by County Agricultural Commissioner staff as a violation of Title 3 of the California Code of Regulations (3 CCR) section 6780(b). The only compatible method to seal the aeration duct that maintains the minimum ducting diameter regardless of airflow or fumigation stage, is to use a duct cover or cap over the end of the aeration duct that can be remotely removed from ground level at the time of aeration.

Sincerely,

Original signature by:

Joshua Ogawa

Chief, Enforcement Headquarters Branch

(916) 324-4100

Fidel Perez

Chief, Enforcement Regional Offices Branch

(916) 603-7700

CC:

Ms. Amber Morris, DPR County/State Liaison

Enforcement Branch Liaisons