CAC Focus: San Francisco County Agricultural Commissioner's Office
The State of California established a Board of Horticulture in 1893 with San Francisco as a District. The City of San Francisco appointed a City Sealer in 1913 and the position of County Agricultural Commissioner/Sealer of Weights and Measures was created in 1987.
The San Francisco County Agricultural Commissioner/Sealer of Weights and Measures (CAC) office is located in the Fox Plaza building, 1390 Market St., San Francisco. It has 15 budgeted positions. They include Agricultural Commissioner/Sealer of Weights and Measures Cree J. Morgan, Deputy Sealer Carmen Kern, Pesticide Use Enforcement Officer Phil Calhoun, eight weights-and-measures inspectors, three agricultural inspectors, and one administrative professional. The commissioner's office has been part of the Environmental Health Branch of the San Francisco Department of Public Health since 2004. The CAC's territory covers the entirety of San Francisco– the city and county, which are geographically one in the same.
Cree Morgan, was hired by the county in 2016, succeeding Miguel Monroy. A native Californian, Morgan was raised in rural Marin County and graduated from Tomales High School. Graduating from UC Davis in 1992 with a degree in botany, he was hired by the Sonoma County Agricultural Commissioner's Office in 1998. He served as an agricultural biologist, senior agricultural biologist, and then environmental specialist, helping the Sonoma County Department of Agriculture with the majority of its programs. In addition to his regulatory inspection duties, he played a major role in developing the department's Vineyard/Orchard Erosion Control program as well as developing the technical resources for the department, including shaping its GIS infrastructure, training staff, and creating and administering program specific databases. Morgan has served on the Board of Directors for the California Association of Standards and Agricultural Professionals (CASAP) for nine years, including two years as board president. All of these experiences helped develop the management style he employs today, he said. "I feel that clear and direct communication is vital to success in our role not only as compliance officers but also as stewards for environmental and consumer protection as well as ensuring worker health and safety."
In addition to spending time with his family, Morgan enjoys playing music, gardening, and walking his dog in the picturesque Sonoma County countryside.
Trends seen, especially those that relate to pesticides
While in San Francisco the majority of the CAC's workload involves weights-and-measures enforcement (regulating devices such as taxi meters, gas pumps, commercial scales, and point of sale systems) there are also a significant amount of pesticide enforcement activities. Traditionally in San Francisco, pesticide use enforcement has chiefly concerned structural applications such as building owners tackling bedbug infestations in apartments and residential hotels. Recently, there has been more focus on production agriculture as the county guides cannabis growers into compliance with the state's evolving pesticide regulations on cannabis cultivation. "It's been a big increase in workload for Phil," Commissioner Morgan said, referring to Phil Calhoun, an industrial hygienist who serves as the CAC's pesticide use enforcement officer. The city has had permitted medical dispensaries and associated cannabis cultivators since 1992, in a program previously regulated under the San Francisco Department of Public Health's Medical Cannabis Ordinance. Since cannabis was legalized in 2016, the CAC's office has played an increasing role in educating growers on pesticide laws and regulations. California's Food and Agriculture Code requires Agricultural Commissioners: "to encourage the development and implementation of pest management systems, stressing application of biological and cultural pest control techniques with selective pesticides when necessary to achieve acceptable levels of control with the least possible harm to non-target organisms and the environment."
San Francisco County not only performs state-mandated headquarters inspections, and pesticide use mix/load and pesticide application inspections, the CAC office also engages in detailed discussions with the cultivators about every aspect of their practice: from their sourcing of cultivation materials (grow media, plant stock, etc.); to their control of the cultivation environment (temperature, humidity, etc.); to their pest prevention strategies (quarantine practices, employee hygiene, housekeeping, etc.). These discussions will often lead growers to discover how that can improve their own work practices to prevent and control pests. "Although we cannot mandate a specific Integrated Pest Management (IPM) program to growers, we can encourage them to consider all of these impactful strategies of pest prevention and control as alternatives to the simple 'spray and pray' method of pesticide usage," Morgan said.
"San Francisco wanted to get people out of the shadows," he further explained, adding that his office has issued Pesticide Applicator Certificates (PACs) and Operator Identification Numbers to dozens of growers, who work indoors in industrial park settings. Morgan noted that the PAC's are an added safety measure since a majority of the county's licensed cannabis growers use 25(b) – or "minimum risk" – pesticides on their products. These pesticides – with active ingredients like citric acid, clove oil, rosemary oil, and cinnamon oil – are exempt under federal pesticide registration, but use of the products are still subject to general Workers Health And Safety Requirements enforced by the CAC. Morgan noted that no injuries associated with Cannabis Cultivation have been reported since commercial cannabis cultivation began.
CAC staff played a key role on the San Francisco County Life Safety Inspection Team, which inspected all Cannabis facilities that had applied for their initial temporary local licenses to operate. This team, which was facilitated by the newly formed San Francisco Office of Cannabis, also included representatives from the Fire Department, Building Department, Hazardous Materials, and other Public Health Department staff.
In addition to educating and registering cannabis growers, Morgan communicates with schools as an essential part of implementing the Department of Pesticide Regulation's regulation on pesticide applications near schools. The regulation restricts many types of agricultural pesticide applications within ¼ mile of schools during operating hours, and requires growers to provide annual notification to schools in advance of their planned pesticide usage. About 30 schools in the city are affected – all within ¼ mile of a cannabis cultivation site.
Because of federal restrictions, growers have limited options for which pesticides can be used to control pests at various stages of plant growth (see CDPR- Pesticides Legal to Use on Cannabis and BCC Laboratory Testing Fact Sheet) Many growers have opted to use products that are exempt from registration (see Minimum Risk Pesticides) to solve their pest problems. Regardless of the products registration status, workers are still required by state regulation to follow safety procedures, including the use of personal protection equipment like respirators, gloves, and goggles.
Currently, there continues to be active discussions between County and State regulators about how to effectively implement California's new Cannabis regulations. Whatever changes are in store for Cannabis regulation in California we can be sure that County Agricultural Commissioner/Sealers will be up to the challenge.
Good times for cannabis businesses in Fog City
You may not think of production agriculture when you think of San Francisco. Yet, the city is home to dozens of cannabis cultivation, manufacturing, and distribution businesses; all subject to regulations including those involving pesticide use, the weighing and measuring of products, and product quality and labeling standards. Most of these regulations are enforced by the county Agricultural Commissioner/Sealer's Office.
Indoor Cultivation 101
Healthy "Mother" plants (below left) provide cuttings that will become rooted clones (below center) with identical genetic characteristics. These rooted clones will be planted in larger containers (below right) and continue their growth cycle as vegetative plants. Once they have grown to the desired size, the light cycle will be adjusted to stimulate flowering. Plants are harvested when flowers are fully mature. Each stage of plant growth has its own nutritional and environmental requirements for overall plant health. Cannabis cultivation indoors can be challenging because there is always a chance of a pest outbreak (like a root aphid infestation) that can destroy an entire room of plants. Also, the minimal post-harvest processing of this commodity means that there are few late-cycle treatment options. This possibility of total crop loss highlights the need for effective pest prevention and early pest identification strategies.