Department of Pesticide Regulation

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June 9, 2000

ENF 2000-024

TO: County Agricultural Commissioners


The Department of Pesticide Regulation (DPR) revised the "Reference Manual for Structural Pest Control Enforcement Program" and the "Inspection Procedures" manual to correct errors and incorporate changes approved by DPR and by the California Agricultural Commissioner and Sealer Association during the Spring Conference.

The following procedural changes do not affect the inspection forms currently used by your staff. Please continue to use the versions of the inspection forms cited in the manuals and in this letter.

Major revisions to both manuals:

  • 1. The current manuals indicate that inspections "should be conducted at the frequency determined in your county [NWP]." All current references to the Negotiated Work Plan (NWP) were changed to "conduct...inspections according to...the goals identified in your county's [NWP]." This reflects the new NWP's focus on issues rather than on numeric targets.

    "Reference Manual for Structural Pest Control Enforcement Program": page 54. "Inspection Procedures" manual: pages 27, 31, 44, and 47.

  • 2. Pesticide Equipment and Storage Site inspections are no longer separate inspections. The inspection criteria have been incorporated into other inspections, as described in the attached revisions. This change significantly increases the value of the remaining inspections for mill assessment revenue disbursement and addresses concerns expressed by county agricultural commissioner and DPR staff over the removal of numeric targets from the NWP. DPR also revised the Pesticide Regulatory Activities Monthly Report to reflect these changes.

    "Reference Manual for Structural Pest Control Enforcement Program": pages 24 and 46. "Inspection Procedures" manual: pages 2, 27, and 50.

    Since DPR does not have a manual for commodity and field Fumigation Use Monitoring Inspections, please observe the following criteria for completing field and commodity fumigation inspections.

    • a. A completed Fumigation Inspection (PR-ENF-144, revised 6/98) includes all applicable criteria items listed in:

      • i. A. Commodity Fumigation, or B. Field Fumigation, and
      • ii. C. Equipment Inspection, and
      • iii. F. Pesticide Storage Site Inspection.
    • b. If you inspected a company's permanent or mobile storage site(s) within the last two years and found them in compliance, then you may exercise discretion in choosing to reinspect these sites when conducting a commodity or field fumigation inspection within this time period.

Corrections and Minor Revisions to the "Reference Manual for Structural Pest Control Enforcement Program" manual:

  • 1. Pages ii and iii: New section headings, pages 23 and 25. New section, "Criteria for Completed Inspections", page 25. Page change, "Containers properly rinsed", page 30.
  • 2. Pages 24-30: Inserted new section, "Criteria for Completed Inspections", on page 25 which caused formatting changes through page 30. Changed headings on pages 23 and 25. No other content changes.

Corrections and Minor Revisions to the "Inspection Procedures" manual:

  • 1. Page 1: Removed last paragraph. Included information on page two (see Major Revisions, item 2).
  • 2. Page 3: Changed heading to maintain consistency throughout manual.
  • 3. Page 5, item 4A: "Handlers are exempt when using "Caution" pesticides and with a closed system which does not operate under positive pressure."
  • 4. Page 7, 2nd paragraph: "NOTE: Non-laminated Tyvex coveralls are considered equivalent to clean work clothing cloth coveralls (WHS 89-06)."
  • 5. Page 7, 3rd paragraph: "However, handlers must have chemical resistant clothing at the work site immediately available and use it when outside the cab and inside the treatment area."
  • 6. Page 8, item 6: "Scope: Employees handling any pesticide for the commercial or research production of an agricultural plant commodity when the label requires eye protection." and employees handling pesticides with the signal word "Danger" or "Warning" for other than commercial or research production of an agricultural plant product.
  • 7. Page 9, item d): "Handlers using positive pressure closed systems shall wear protective eyewear in addition to 1 and 2 b and c above."
  • 8. Page 10, item 9, 3rd paragraph: "If there are no usual points of entry, signs must be posted at the corners of the field and every 600 feet where the field is adjacent to an unfenced right of way such as a road, path or trail."
  • 9. Page 11, item 12: "Employees's" (struck possessive).
  • 10. Page 14, item 19: "Containers Secure and Under Control". 3CCR 6670[b]
  • 11. Page 15, item 21: "Handlers Trained". Section added to correspond to the inspection form.
  • 12. Page 16, item 22: "Pest Control Operator Registered in the County". Section added to correspond to the inspection form.
  • 13. Page 17, 1st paragraph: Note: This is a general standard that applies to all users, whereas 3CCR 6742 below only applies to WSD. Sentence deleted, no additions.
  • 14. Page 24, 3rd paragraph: In all cases "In general, entry to treated fields is prohibited until four hours have elapsed from the time of application, handlers and no contact field workers are the exception."
  • 15. Page 24, 4th paragraph: "No contact activities also include tasks that do not involve touching or disrupting the soil subsurface after an application that is incorporated or injected into the soil." Added before last sentence.

List of revised pages:

  • 1. Reference Manual for Structural Pest Control Enforcement Program:

    Cover sheet-i

  • 2. Inspection Procedures:

    Cover sheet (single sided)

If you have any questions, please contact your 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/Attachments)