Pesticide Contamination Prevention Act Review Process Triggered by Detections of Imidacloprid in Groundwater
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Legal Agricultural Use Determination
Detections of imidacloprid in groundwater were determined to be the result of legal agricultural use of a pesticide product or products containing imidacloprid. DPR responded by placing imidacloprid in the formal pesticide detection response process.
September 2021 – Request to Proceed with Pesticide Detection Response Process for Imidacloprid, PDF
- Legal Agricultural Use Determination for Imidacloprid Detections in California, PDF
- Study GW17/17A: Groundwater Protection List Monitoring for Imidacloprid, PDF
- Study 228: Monitoring the Concentrations of Detected Pesticides in Wells Located in Highly Sensitive Areas (Well Network Sampling), Annual Update 2020, PDF
- February 2022 – Summary of Imidacloprid Groundwater Detections in 2021, PDF
Formal Review Process
In September 2021, DPR began the formal review process of imidacloprid by notifying registrants with affected pesticide products.
September 2021 – Notice of Imidacloprid Product Residue Detections in California Groundwater and Registrant Opportunity to Request a Hearing, PDF
- April 2021 – Updated Risks from Human Exposure to Imidacloprid Residues in Well Water, PDF
- Suggested Information for Registrant Report and Documented Evidence for Hearing, PDF
September 2021 – Notice of Hearing Request Received for the PCPA Review Process of Imidacloprid, PDF
October 2021 – Proposed Hearing Procedures for Certain Products Containing Imidacloprid, PDF
December 2021 – Final Hearing Procedures for Certain Products Containing Imidacloprid, PDF
January 2022 – Notice of Hearing Pertaining to Imidacloprid Product Residue Detections in Groundwater, PDF
March 2022 – Notice of Agenda for Phase 1 of Hearing Pertaining to Imidacloprid Product Residue Detections in Groundwater, PDF
April 2022 – Notice of Agenda for Phase 2(a) of Hearing Pertaining to Imidacloprid Product Residue Detections in Groundwater, PDF
May 2022 – Notice of Agenda for Phase 2(b) of Hearing Pertaining to Imidacloprid Product Residue Detections in Groundwater, PDF
PREC Subcommittee Findings and Recommendations
- May 2022 - PREC Subcommittee Findings and Recommendations for the Pesticide Contamination Prevention Act Review Process for Imidacloprid, PDF
- June 2022 – Notice of Decision Pertaining to Imidacloprid Residue Detections in Groundwater, PDF
- June 2022 – Director’s Decision Regarding the Continued Use of Imidacloprid, PDF
Reports, Evidence, and Public Comments Received
Reports Received from State Agencies
- February 2022 – OEHHA’s Findings on the Health Effects of Imidacloprid Relevant to its Identification as a Potential Groundwater Contaminant, PDF
- March 2022 – An Economic and Pest Management Evaluation of the Insecticide Imidacloprid in California Agriculture, PDF
Rebuttal Evidence Submitted by Hearing Participants
- April 2022 – Evidence Requested by the Subcommittee for Phase 2 of the Hearing on Imidacloprid Detections in Groundwater, DPR, PDF
- April 2022 – Excerpts from a Developmental Neurotoxicity Study of Imidacloprid Technical in Wistar Rats, submitted by UPL NA INC
- April 2022 – J.J. Mauget’s Rebuttal to Supplemental Comments from the Natural Resources Defense Council, et al.
- April 2022 – Imidacloprid: Perspective on Reported Groundwater Detections in California, Presented by Bayer during Phase 2(a)
- April 2022 – Phase 2 Hearing for Imidacloprid Relevant to its Identification as a Groundwater Contaminant, Presented by OEHHA during Phase 2(a)
- May 2022 – Bayer and Respondents’ Rebuttal Evidence as Outlined in California Department of Pesticide Regulation Notice 2022-09 regarding the Detections of Imidacloprid in California Groundwater
- May 2022 – Evidence Requested by the Subcommittee for Phase 2 of the Hearing on Imidacloprid Detections in Groundwater, DPR, PDF
Evidence Submitted by Affected Registrants
Food and Agricultural Code section 13150(a) requires pesticide registrants subject to the Pesticide Contamination Prevention Act review process for imidacloprid to submit a report and evidence that demonstrates both of the following:
- That the presence in the soil of any active ingredient, other specified ingredient, or degradation product does not threaten to pollute the groundwater of the state in any region within the state in which the pesticide may be used according to the terms under which it is registered.
- That any active ingredient, other specified ingredient, or degradation product that has been found in groundwater has not polluted, and does not threaten to pollute, the groundwater of the state in any region within the state in which the pesticide may be used according to the terms under which it is registered.
DPR requested registrants to self-certify all reports and documents submitted to DPR are in compliance with Web Content Accessibility Guidelines (WCAG) 2.1, or a subsequent version, published by the Web Accessibility Initiative of the World Wide Web Consortium (W3C) at a minimum Level AA success criteria. Registrant reports self-certified as compliant can be found hyperlinked below. If a registrant did not self-certify their report, it will not be hyperlinked below, but you may request a copy of the submitted evidence by emailing PCPA@cdpr.ca.gov.
This table was last updated Friday, March 29, 2022.
|Evidence Received from Registrants Subject to the PCPA Review Process||Date Received|
|Bayer Environmental Science/Bayer Environmental Science A Division of Bayer Cropscience LP and Bayer Cropscience LP (“Bayer”), PDF
Bayer’s submission is also on behalf of the following registrants:
|February 18, 2022|
|Nufarm Americas Inc. AGT Division and Nufarm Americas, Inc.||February 18, 2022|
|Scimetrics LTD. Corporation||February 18, 2022|
|J.J. Mauget Co.||February 18, 2022|
Public comments and evidence submitted to DPR may have been edited for accessibility purposes. You may request a copy of any of the following public comments listed below by emailing PCPA@cdpr.ca.gov.
This table was last updated Monday, May 16, 2022.
|Date Received||Commenter Name||Commenter Affiliation|
|February 7, 2022||John Mora||Garden and Turf Management, PDF|
|February 7, 2022||Laural Roaldson||Laural Landscapes|
|February 8, 2022||Curtis Vaughan||Seed Dynamics, Inc.|
|February 8, 2022||Wayne Pricolo||Bowles Farming Company, PDF|
|February 10, 2022||Larry Cruff||Not provided|
|February 11, 2022||Gary W. Van Sickle||California Specialty Crops Council|
|February 15, 2022||Gary Atkins||Not provided|
|February 15, 2022||Joshua Rahm||California Walnut Commission, PDF|
|February 15, 2022||Jacob Villagomez||California Citrus Mutual, PDF|
|February 16, 2022||Lisa Tate||Rancho Filoso, LLC|
|February 16, 2022||Todd Birchler||Nufarm Americas|
|February 16, 2022||Mary Zischke||Grower-Shipper Association of Central California, PDF|
|February 17, 2022||Jeff Jensen||Golf Course Superintendents Association of America, PDF|
|February 17, 2022||Ricardo Aguilar||Aguilar Plant Care, PDF|
|February 17, 2022||Charles Brannon||Sierra Gold Nurseries|
|February 17, 2022||Gregory C. Loarie||Natural Resources Defense Council, Central California Environmental Justice Network, Pollinator Stewardship Council, Xerces Society for Invertebrate Conservation, Pesticide Action Network North America, and Center for Biological Diversity|
|February 18, 2022||James R. Cranney||California Citrus Quality Council, PDF|
|February 18, 2022||Roger van Klaveren||Generation Growers, Inc., PDF|
|February 18, 2022||Kim Wilenius||C&M Nursery, PDF|
|February 18, 2022||Renee Pinel||Western Plant Health|
|February 18, 2022||Adam Borchard||California Fresh Fruit Association, PDF|
|February 18, 2022||Bill Freese||Center for Food Safety|
|February 23, 2022||Steve Garsino||Not provided|
|April 7, 2022||Jennifer Sass||Natural Resources Defense Council, Central California Environmental Justice Network, Pollinator Stewardship Council, Xerces Society for Invertebrate Conservation, Pesticide Action Network North America, and Center for Biological Diversity|
|May 6, 2022||Alexis Temkin||The Environmental Working Group|
DPR also received approximately 3,869 public comments through an automated service called “EveryAction.” Of these 3,869 comments, approximately 289 were unique and contain differences in the subject line or body of the text itself. These “EveryAction” comments did not contain attachments.
For content questions, contact:
PCPA Hearing Coordinator
1001 I Street, P.O. Box 4015
Sacramento, CA 95812-4015