Department of Pesticide Regulation

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May 17, 2000

ENF 2000-022

TO: County Agricultural Commissioners


This letter clarifies azinphos-methyl (AZM) restricted entry interval (REI) labeling requirements and updates the current status of the Department of Pesticide Regulation's (DPR's) AZM REI regulations.

The emergency AZM exposure mitigation regulations sections 6486.7 and 6772 (b) of Title 3, California Code of Regulations (3CCR), adopted in 1998 and readopted in 1999 expired by operation of law on December 10, 1999. Therefore, on December 10, 1999, the requirements reverted to those in effect prior to the adoption of the emergency action. DPR filed a regular rulemaking package replacing the emergency regulations on March 13, 2000. DPR anticipates that these regulations will be in place by June 1, 2000.

Currently there are no regulatory restrictions based on specific cultural work "activities" from the expiration of the label-required REI to the end of the California-extended REI in section 6772, 3CCR (See ENF 99-008, attached). Therefore, except for stone fruit, the AZM labeling must be followed to determine the REI until the regular rulemaking package takes effect. The regular rulemaking action will impose a general 14-day REI on all stone and pome fruit.

The following AZM products have been revised by the registrants to reflect California's extended REIs for stone fruit in existing regulation [3CCR section 6772(b), Footnote (A)], and provide for shorter REIs for specific activities such as irrigating and scouting, etc. These products are:

  • 1. Gowan Azinphos-M 50 WSB (U.S. EPA Registration No. 10163-78-ZA)
  • 2. Gowan Azinphos-M 2 EC (U.S. EPA Registration No. 10163-80-AA)
  • 3. Bayer Guthion Solupak (U.S. EPA Registration No. 3125-301ZA)
  • 4. Bayer Guthion 2L (U.S. EPA Registration No. 3125-102-AA)

These AZM products list different REIs for different work activities under each crop/site. For example, stone fruit crops, such as apricots, cherries, plums, and prunes, and pome fruit crops, such as pears, are found under "Tree Crops." When a specific activity is not listed under a particular crop/site, it defaults to the "other activities" category. For example, for pear blight cutting/pruning, the REI is two days under "other activities" which is found under "Tree Crops." When a particular crop/site is not listed, default to "all other crops" and follow the REIs for the activities listed.

Please note that the four AZM products listed above reflect Personal Protective Equipment (PPE) as required in emergency AZM regulation section 6486.7 for airblast applications.

The following AZM products are currently registered, but they have not been revised to reflect the emergency or AZM regulations, sections 6486.7 and 6772 (b). These products lack a chemical-resistant suit and eye protection to meet PPE for airblast applications. They reflect a general REI of 48 hours. These products are:

  • 1. Gowan Azinphos-M 50-W (U.S. EPA Registration No. 10163-78-AA)
  • 2. Miles Guthion 2S (U.S. EPA Registration No. 3125-123-ZC)

The use of existing stocks of AZM products for which California registration has expired follow individual product labeling to determine the REI requirements.

The use of activity-specific REIs found on AZM product labeling creates a couple of challenges. First, the provisions that are normally in effect during an REI are found in 3CCR section 6770(a)-(e). Those provisions apply to the activity for the length of each activity-specific REI. After the termination of the shorter activity-specific REI, the provisions of 3CCR section 6770(f) apply to each specific activity (see ENF 99-008) until the expiration of the longer California-extended REI in 3CCR section 6772.

Secondly, how long must the site be posted? Since the shorter REI has expired, there is no need for PPE or other early entry requirements. Can workers enter a posted site without PPE to conduct those shorter-term activities? The answer is yes. Posting has to remain in effect until the longest REI has expired. However, since the REI has expired for the shorter-term activities, they may be conducted without restriction.

If you have questions, contact your Liaison Senior Pesticide Use Specialist.


original signed by

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


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