Department of Pesticide Regulation

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Back to 2000 Enforcement Branch Letters

April 17, 2001   ENF 2001-017
County Agricultural Commissioners  



The suggested permit conditions for the molinate (Ordram®) worker safety requirements, the rice water-holding requirements, and the drift control requirements for certain rice pesticides will remain the same for 2001, except for new suggested permit conditions for thiobencarb concerning see page. Please note that the attached suggested permit conditions have been updated and will reflect the year 2001. Propanil regulations also remain unchanged from the previous year; however, please review closely this year's program expectations.

This year we will be starting the second tri-annual review period as adopted by the Central Valley Regional Water Quality Control Board's (CVRWQCB) Resolution No. 5-01-074 in which the Regional Board approved water quality management practices for the 2001 through 2003 rice seasons.

The Department of Pesticide Regulation (DPR) will continue monitoring the following pesticides at Colusa Basin Drain, Butte Slough, and Sacramento River: molinate, thiobencarb, carbofuran (last year to ensure use has ceased), methyl parathion, malathion, propanil, and triclopyr.

See page Control Requirements

DPR developed suggested permit conditions to mitigate potential lateral movement of thiobencarb from rice fields. Concerns as to thiobencarb see page began following the detection of the herbicide by the CVRWQCB. A memorandum from Dr. John Sanders, Chief of the Environmental Monitoring Branch, to the CVRWQCB is attached for your reference. See page is the lateral movement of irrigation water through a rice field levee or border to an area outside the normally flooded production area. Seepage can occur through levees into adjacent dry fields or into adjacent drains and canals. Seepage is not water leaking through the "field drop box."

DPR is asking county agricultural commissioners (CACs) to check for seepage when inspecting water-holding compliance. Although CACs are not expected to drive around the entire field, DPR does request a check for seepage or collection of seepage that occurs through the outer borders of a field or the bottom border located at the lowest part of the field.

NOTE: The drop box should be located at the lowest part of the field; therefore, water seeping through the surrounding border will collect there.

CACs may use the water-holding inspection logs to document seepage observations. The Pesticide Use Monitoring Inspection Form (PR-ENF-021) may also be used to document seepage observations. When using the form, indicate "water-hold inspection" on the blank line under "application inspection." In the "Remarks" section, write one of the following comments for each field inspected: No Seepage Detected, Seepage Flow less than 5 gallons per minute, or Seepage Flow more than 5 gallons per minute.

Although, CACs are not required to inspect for "compacted" borders, if seepage is occurring, CACs should consider if borders were "compacted." DPR requests that the CAC provide a copy of the inspection to the grower whenever seepage is observed. Also, a copy of all seepage inspections should be faxed to Dr. Sanders at (916) 324-4088 or e-mailed to him at August 1, 2001. DPR plans to compile the information provided by the CACs and submit it to the CVRWQCB.

Please continue to distribute the brochure, Seepage Water Management, Voluntary Guidelines for Good Stewardship in Rice Production, Publication 21568, to growers at the time of permit issuance.

Warrior® & Dimilin

Two active ingredients, lambda-cyhalothrin (Warrior®) and diflubenzuron (Dimilin), are currently registered for use on rice. Warrior® and Dimilin may be used as alternatives to Furadan®5G, which was cancelled for application to rice, effective August 31, 2000.

Due to concerns of potential aquatic toxicity and possible sediment accumulation resulting from Warrior® applications, the California Department of Fish and Game (DFG), the California Rice Commission, and Syngenta (registrant for Warrior®) plan to work together to identify cooperative rice growers where water monitoring will take place during the 2001 season.

Methyl Parathion Use Status

On October 27, 1999, the U. S. Environmental Protection Agency accepted the voluntary cancellation of methyl parathion (Federal Register, Notice FRL-6387-8). This action cancels specific food/feed crops and non-food uses. The action further requires that current methyl parathion registrations be revised to specify certain food/feed uses, including rice. Penncap-M®, EPA Registration No. 4581-393-AA, is currently registered by DPR for use on rice.

Phenoxy/Dicamba Use Status

The status of phenoxy use on rice within the Sacramento Valley remains as last year. CACs may refer to Attachment 9, Drift Control Requirements for Phenoxy/Dicamba Herbicides, as permit conditions guidance when issuing restricted material permits.


Ground Use Area

Within the ground use area, the CAC has authority to modify the acreage limit and buffer zones. DPR supports CAC discretion to modify buffer zones, as follows:

For propanil ground applications, provide a one-mile buffer zone to cultivated grape vineyards, pistachios, or prunes; or a half-mile buffer zone provided a positive wind flow is away from these crops during the application. If the wind flow changes during an application, it must cease immediately.

DPR does not support a CAC's discretion to modify buffer zones beyond the aforementioned distances. Modifications of acreage limits and buffer zones should be based on the CAC's site-specific evaluation, not on "waivers" obtained from growers of sensitive crops. DPR requests CACs to restrict the practice of "waivers" to situations where the same enterprise owns both the rice and the sensitive crop.

Aerial Use Area

DPR does not endorse any decrease of the buffer zones and will not support a CAC's discretion to modify buffer zones for aerial applications.

The 1998 Propanil Aerial Use Protocol and Controls [referenced in Section 6462(1)] Limitations on Application states: "No more than 500 acres of rice may be treated with propanil by helicopter in the Colusa County aerial use area on a single day. No more than 300 acres of rice may be treated with propanil by helicopter in the Glenn County aerial use area on a single day." Section 6462(b)(2)(C)(3) provides: "Unless expressly authorized by the commissioner, no more than 1,500 acres of rice may be treated by ground in each county per day." Therefore, the regulations allow 2,000 acres total per day (1,500 acres by ground and 500 acres by helicopter) in Colusa County, and 1,800 acres total per day (1,500 acres by ground and 300 acres by helicopter) in Glenn County.

Reporting Propanil Use Data

DPR requests the Butte, Colusa, Glenn, Placer, Sutter, Yolo, and Yuba CACs to maintain a record of propanil use on a daily basis using the Propanil Application Log (attached) or a similar electronic format. The record/log should include the number of acres treated, method of application (e.g., air/ground), and application site (e.g., section/ township/range) for each application in the county. Please FAX the record/log to Ms. Nancy Grussing, Supervising Pesticide Use Specialist, at (916) 445-3097 or e-mail it to her at The record/log must be received no later than the close of business on Tuesday of each week throughout the propanil use season. The record/ log should reflect daily use data for the previous Tuesday through Monday report period. If no record/log of propanil use is received, DPR will assume that no use occurred during the reporting period.


Due to the extent of late propanil use reporting in previous years, DPR requests that CACs take enforcement action against all persons in violation of pesticide use reporting regulations. In addition, DPR requests enforcement actions for violations of restricted material sales and use laws and regulations pertinent to propanil. This use information is vital for the analysis and development of future regulations.

DPR plans to increase surveillance monitoring throughout the Sacramento Valley during the 2001 season. It is imperative that CACs inform the regulated community that strict compliance with all propanil use requirements is expected.

Shark™40 DF

Shark™40 DF Herbicide, manufactured by FMC Corporation, is currently under review by DPR. The proposed date for final approval of Shark™40 DF Herbicide is not known at this time.

Permit Conditions Summary

Please refer to the following suggested permit conditions when issuing Year 2001 permits for molinate, thiobencarb, methyl parathion, and phenoxy/dicamba.

Attachment A, Molinate Worker Safety
Attachment 1 Molinate Water Management Requirements
Attachment 2 Thiobencarb Water Management Requirements
Attachment 3 Methyl Parathion Water Management Requirements
Attachment 4 Malathion Water Management Requirements
Attachment 5 Drift Control Requirements for Granular Molinate and Thiobencarb
Attachment 6 Drift Control Requirements for Liquid Thiobencarb
Attachment 7 Drift Control Requirements for Malathion
Attachment 8 Drift Control Requirements for Methyl Parathion
Attachment 9 Drift Control Requirements for Phenoxy/Dicamba
Attachment 10 Propanil Application Acreage Log

DPR data reporting guidelines for the 2001 rice pesticides program will be sent to commissioners in the rice-producing counties as a separate letter.

If you have any questions concerning the suggested molinate worker safety permit conditions, rice water-holding requirements, phenoxy/ dicamba, propanil, methyl parathion, and Shark™40 DF, please contact the Senior Pesticide Use Specialist Liaison serving your county.

Original Signature by:
Scott T. Paulsen, Chief
Pesticide Enforcement Branch
(916) 324-4100


cc:  Mr. Dave Lawson, Syngenta, Inc. (w/Attachments)
      Mr. Daniel J. Merkley, Agricultural Commissioner Liaison (w/Attachments)
      John Sanders, Ph.D. (w/Attachments)
      Ms. Nancy Grussing (w/Attachments)

1001 I Street  ·   P.O. Box 4015  ·  Sacramento, California 95812-4015  ·
A Department of the California Environmental Protection Agency