Department of Pesticide Regulation

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

May 12, 2000

ENF 2000-021

TO: County Agricultural Commissioners


Through ENF 2000-011, the Department of Pesticide Regulation (DPR) requested that all restricted material permits for paraquat dichloride be amended to require respiratory hazard mitigation measures.

Permits must be amended in a method, to be established by the county, that allows the permittee sufficient time to comply and will also serve as adequate documentation of notification.

Using the Notice of Intent as a method of notifying the permittee may not be appropriate for three reasons: (1) this late notice may not afford the permit holder sufficient time to incorporate the new permit requirements; (2) it places unnecessary time constraints on the county as all amendments must be made within a 24-hour period; and (3) this method of notification may not adequately serve to document that the permittee has been notified of the requirement.

DPR recognizes the difficulty in implementing suggested permit conditions in the midst of the application season. However, in the event a violation of the permit condition is observed and enforcement action pursued, it is vital that the county be able to document the permittee/pest control operator was notified of the permit condition.

If you have any questions or comments regarding this letter or 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. Merkely, Agricultural Commissioner Liaison