Department of Pesticide Regulation

Back to County Agricultural Commissioner Resources
Back to 2000 Enforcement Branch Letters

March 14, 2000

ENF 2000-011

TO: County Agricultural Commissioners


In September 1996, the U.S. Environmental Protection Agency (U.S. EPA) issued a Re-registration Eligibility Decision (RED) document for paraquat dichloride. Among the changes allowed under this RED was the removal of the respiratory requirements.

The Department of Pesticide Regulation's (DPR's) Pesticide Registration Branch received requests from Zeneca for approval of label changes for their products, Gramoxone Extra Herbicide, (U.S. EPA Reg. No. 10182-280-AA) and Starfire Concentrate (U.S. EPA Reg. No. 10182-372-AA) to implement the changes allowed by the U.S. EPA - RED document. DPR's Pesticide Registration Branch's policy at that time was to accept RED labeling changes as non-substantive, thus not requiring review. These product labels are currently registered for use in California and do not bear respiratory requirement statements.

A subsequent request to amend the Statement of Practical Treatment on the Gramoxone Extra Herbicide label triggered an evaluation by DPR's Worker Health and Safety Branch (WH&S). During this evaluation, WH&S noted that the respiratory requirements had been removed from the label. WH&S advised DPR management and the registrant that review of worker illness data indicated that respiratory protection is still needed to adequately protect workers handling the product. DPR has been in communication with U.S. EPA regarding this issue and U.S. EPA is currently reviewing the data.

DPR requests that all restricted material permits for paraquat dichloride be amended to require the following respiratory hazard mitigation measures:

Persons working as applicators or flaggers (except applicators working in an enclosed cab or flaggers working in an enclosed vehicle) shall wear a dust/mist respirator approved by MSHA/NIOSH (number prefix TC-84-A).

If you have any questions or comments regarding the suggested conditions, please contact the Senior Pesticide Use Specialist Liaison serving your county.


original signed by

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

cc: Mr. Daniel J. Merkley, Agricultural Commissioner Liaison