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Brian R. Leahy

                       Department of Pesticide Regulation

The Great Seal of the State of California

Edmund G. Brown Jr.

October 18, 2016

ENF 16-25



County Agricultural Commissioners


In 2015, the U. S. Environmental Protection Agency (U.S. EPA) approved revised labels for Methyl Bromide use as a commodity fumigant. These new labels are to be on products released for sale by the registrant by September 2016.

An important change to these newly revised labels is found under the "Directions for Use" section of the label:

"Applications in California: Where a Restricted Materials Permit with site-specific Final Permit Conditions is required for fumigation pursuant to Title 3 of the California Code of Regulations section 6400, the certified applicator must follow the conditions and instructions specified in the Final Permit Conditions issued by the County Agricultural Commissioner provided that the buffer zone distances are equal to or greater than the buffer zone distances specified in the August 8, 1994 California Methyl Bromide Commodity Fumigation Reference Manual in place of the following sections of this label: Buffer Zones; Buffer Zone Entry Restrictions; Respirator Requirements & Work Time Restrictions; and Aeration Period."

In summary, the following four sections of the label are superseded by permit conditions issued by the CAC. The DPR Compendium Volume 3, Restricted Materials and Permitting, contains the recommended permit conditions.

  1. Buffer zones
  2. Buffer Zone Entry Restrictions
  3. Respirator Requirements & Work Time Restrictions
  4. Aeration Period

We received confirmation from the U.S. EPA that the intent of this paragraph on the label is to allow for the California Methyl Bromide Commodity Fumigation Reference Manual (Manual) to replace these four sections of the label, when the CAC issues permit conditions. The DPR recommended permit conditions in Volume 3 were based on the information in the 1994 Manual referenced on these new labels.

DPR considers these newly revised labels as improvements to the previous labels and equivalently protective to the restrictions outlined in the 1994 Manual. In situations when the CAC does not issue permit conditions, the applicator must follow the product label requirements.

If you have any questions, please contact the Enforcement Branch Liaison assigned to your county.


Original Signature by:

Donna Marciano
Chief, Enforcement Branch

cc: Mr. Joe Marade, DPR Agricultural Commissioner Liaison
      Enforcement Branch Liaisons

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