California's pesticide regulatory program is considered by many to be a model program, and its pesticide use reporting program is recognized as the most comprehensive in the world. In 1990, California became the first state to require full reporting of agricultural pesticide use. In the next few years, the State's Department of Pesticide Regulation (DPR) struggled with the inevitable problems of breaking new ground on a large-scale, highly complex endeavor. At the same time, other states and many public interest groups began to ask questions about the program, and in response, DPR published the first edition of this overview in June 1995. Since then, the use reporting program has evolved and DPR has made several improvements and enhancements, prompting the updating of the overview. DPR has developed this document to describe the pesticide use reporting program, and explain how it functions as an integral component of the State's pesticide regulatory system.
History of Use Reporting in California
Limited use reporting requirements have been in force in California since at least 1950. Then, the California Department of Food and Agriculture, through the county agricultural commissioners, required agricultural pest control operators to submit monthly reports of their work. The requirements of counties differed, but many required a monthly report for each pesticide application which included the location, date, crop, acres or other units treated, pest, kind of pesticide used, and the strength and amount of the spray or dust mixture applied. Only statistics on aerial pesticide applications were forwarded for statewide tabulation. In 1955, the Department of Food and Agriculture asked that ground application acreage be forwarded as well, but dropped the requirements for detailed reporting of pesticides used and commodities treated.
The regulations were changed in 1970 when the state instituted a bifurcated system, requiring that commercial pest control operators (those engaged in pest control for hire, such as ground and aerial applicators, structural applicators, and professional gardeners) report all pesticides used and that farmers report only their use of restricted materials.
Restricted materials are pesticides deemed to have a high potential to cause harm to public health, farm workers, domestic animals, honeybees, the environment, wildlife, or other crops. All federally restricted-use pesticides have been designated as restricted materials in California. In addition, California has designated additional materials as restricted-use. California's system for allowing use of these materials only through a permit process is described in the next section.
Both pest control operators and growers filed use reports with the agricultural commissioner in the county where they made the applications. These reports had to include the pesticide applied, date and location (section, township, and range) of the application, and the crop and acres treated if the application was in agriculture. The commissioners forwarded this information to the State, which entered the data into a computerized database and published annual data summaries.
Full Use Reporting Begins
Demands for more realistic and comprehensive pesticide use data to accurately estimate dietary risk as well as exposure and potential risk to workers increased dramatically during the late 1980s. DPR began the full use reporting program in 1990 in response to these concerns. Under the program, all agricultural pesticide use must be reported monthly to the county agricultural commissioner who in turn reports the data to DPR. The reports must include the date and location (section, township, and range) where the application was made, and detail the kind and amount of pesticides used. If the pesticide is applied to a crop, the type of commodity must be specified. In addition, identification numbers (IDs) for the site and the pesticide user ("operator") were added. Planted acres were also added, which in combination with the treated acres, are useful in pesticide risk assessment. Before buying or using pesticides, every operator is required to obtain a unique operator ID from each county in which pest control work will be performed. Growers obtain a site ID from the county agricultural commissioner for each location and crop/commodity where pest control work will be performed, and it is recorded on the restricted material permit or other approved form.
California has a broad legal definition of "agricultural use," so the reporting requirements include pesticide applications to parks, golf courses, cemeteries, rangeland, pastures, and along roadside and railroad rights-of-way. In addition, all postharvest pesticide treatments of agricultural commodities must be reported, along with all pesticide treatments in poultry and fish production, as well as some livestock applications. The primary exceptions to the full use reporting requirements are home and garden use and most industrial and institutional uses.
Structural pest control operators, professional gardeners, and other nonagricultural pest control operators had to report all pesticide use under the earlier regulations, and these requirements did not change under the full use reporting program. The following description will focus primarily on the requirements for reporting pesticides used in agriculture.