Department of Pesticide Regulation logo

Department of Pesticide Regulation

The Great Seal of the State of California
Mary-Ann Warmerdam
  Arnold Schwarzenegger
August 31, 2010
  ENF 10-10
County Agricultural Commissioners



In March 2010, you were notified that the structural fumigation industry prepared the California Aeration Plan (CAP) as the "next generation" Fumigation Safety Program to submit to DPR within the context of 3CCR section 6780. CAP is designed to provide the 1 ppm level of protection required by sulfuryl fluoride labels, as well as to minimize chloropicrin-related complaints from residents and others re-entering fumigated structures.

Use of the CAP was approved May 11, 2010 by Director Mary-Ann Warmerdam. In that letter, use of the Tarpaulin Removal and Aeration Plan (TRAP) was allowed until September 1 to allow for transition to CAP. Since then, fumigators have demonstrated due diligence in procuring the equipment and conducting training necessary to implement CAP. Unfortunately, suppliers of tarps have not been able to fill orders, due to the demand caused by this transition.

By request of the structural fumigation industry, the Director has allowed use of the TRAP until October 31, 2010. After that date, use of the TRAP for compliance with Title 3, California Code of Regulations section 6780 will not be allowed.

We believe that allowing these additional two months will provide for an orderly transition to CAP. If you have any questions, please contact Mr. Cliff Smith, Senior Environmental Scientist, at 916-324-6680 or

Original Signature by:
Nan Gorder, Ph.D.
Chief, Enforcement Branch

cc:   Mr. Tom Babb, DPR Agricultural Commissioner Liaison
        Mr. David Haskell, DPR Research Program Specialist II
        Ms. Mona Montano, DPR Research Program Specialist II
        Enforcement Branch Liaisons

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