6. Growing Pains
Full use reporting greatly expanded the scope and complexity of data collected by DPR. It also exposed some shortcomings in the data collection and reporting processes. The complexity of the product label and other databases accessed when pesticide reporting data is processed, and the use of these databases by other DPR programs, also prompted DPR to modify these databases to meet the challenge of full use reporting.
Because full use reporting was a major program that no other state had undertaken, it was inevitable that there were problems to be worked out. During the first few years, DPR invested its resources processing the backlog of data and enhancing the county-based computer systems. Initial implementation and processing problems included:
Timeliness of Data Processing
Even with all their collective field experience, DPR and county agricultural commissioners seriously underestimated the increase in workload associated with full use reporting. DPR staffing was inadequate and quickly fell behind in processing the data. It took several years through the government budgetary process to obtain resources to adequately fund and staff the program. Contracts with counties for electronic submission of use reports have had the greatest impact in managing the workload.
A three- to six-month lag in processing the data and making it available to outside requesters is realistic considering the numbers of reports to be processed, the numbers of individuals involved (including the thousands of pesticide users subject to reporting requirements, as well as county commissioner and DPR staff who collect, review, and process data), and the inherent delay in submitting use reports to the commissioners up to a month after pesticide application.
In processing the 1990 use reports, it became evident that new standards and guidelines would have to be developed for recording two of the data fields--the grower/operator and site ID. Inconsistent recording of numbers was a problem with operator IDs. For example, although an operator ID could be 30-90-3000001, it may have been recorded as 30-90-301, 30-90-30-1, 3090301, 30-1, etc. To resolve this problem, the operator ID was separated into four fields--reporting county, year, home county, and operator number. The operator number is now the last set of numbers at the right margin and the remainder of the field is filled with zeros.
Problems with the site ID revolved around naming conventions. For example, the site may be identified as "Home Ranch Smith." This became a problem in data entry as the software allows only eight characters. To address this, standard abbreviations and guidelines were developed for staff when coding the reports for data entry.
Consistent reporting of these data has been stressed in the counties and with growers, operators, Pest control operators, and others subject to reporting requirements. Today, these problems have been substantially eliminated by consistently applying the coding standards and guidelines, and by having most counties submit data electronically.
Site IDs and County Mapping Assistance
During the first ten years of full use reporting, site IDs were only unique when combined with the grower ID and often the commodity. They did not refer to parcels or specific geographic locations. Site IDs changed from year to year for the same grower, as well as with changes in land ownership and property management. Evaluating historical pesticide use geographically to the degree now required is nearly impossible under the current site ID system. To deal with this, DPR is revising the site ID system to use GIS identifiers. (See Section 8 for discussion.)
DPR's pesticide product label database is used to cross-check data entries to determine if the product reported used is registered on the reported commodity. The DPR label database uses a crop coding system based on crop names used by the U.S. EPA to prepare official label language. However, this system caused some problems until DPR modified it to account for U.S. EPA's grouping of certain crops under generic names. Problems occurred when the label language in the database called a crop by one name, and the use report used another. For example, a grower may have reported a pesticide use on "almonds," but the actual label on the pesticide product--coded into the database--stated the pesticide was to be used on "nuts." To eliminate records being rejected as "errors" because the specific commodity listed on the use report is not on the label, DPR modified the database. To designate a commodity not specifically listed on the label as a correct use, a qualifier code is appended to the commodity code in the label database. In our example above, a qualifier code would be attached to the "almond" code when nuts are only listed on the label. This system greatly reduces the number of rejections.
Plants and commodities grown in greenhouse and nursery operations represented a challenge in use reporting because of their diversity. Six commodity groupings were suggested by industry and incorporate terminology that are generally known and accepted. The six use reporting categories are: greenhouse-grown cut flowers or greens; outdoor-grown cut flowers or greens; greenhouse-grown plants in containers; outdoor container/field-grown plants; greenhouse-grown transplants/propagative material; and outdoor-grown transplants/propagative material.
Tomatoes and grapes were also separated into two categories because of public and processor interest in differentiating pesticide use. Tomatoes are assigned two codes to differentiate between fresh market and processing categories. One code was assigned to table grapes, which includes grapes grown for fresh market, raisins, canning or juicing. A second code was assigned to wine grapes.
County Error Lists
Because of the initial increase in workload both at DPR and the counties, problems arose in processing the error lists in a timely manner. With the changes in how incoming data are checked, DPR now has the ability to send error lists to the counties for their review within a week. Before returning the error lists, DPR staff first review the product label database to ensure it accurately reflects the registered label. Apparent reporting problems are returned to the county to be researched and corrected.
U.S. EPA/California Registration Numbers
The pesticide label database contains all products registered in California, whether active or inactive. In California, all products are assigned a two letter alpha code appended to the U.S. EPA registration number; both the registration number and the alpha code are recorded in the pesticide label database. Registrants may market additional brand names of a product formulation containing the same percentage of active ingredient. Each additional brand is registered as a separate product and is assigned a sequential alpha code, thus providing a unique registration number to each brand name. The alpha code in most cases is not on the physical product label and is not reported by the pesticide user. The absence of the alpha code in the pesticide use report created "errors" when the use report database was checked against the pesticide label database. The validation program was modified to eliminate the check for the alpha code, thus improving the efficiency of the checking process.
Soil Fumigants and Rodenticides
To meet the crop/commodity-specific requirements for both the restricted materials permit and full use reporting programs, the reports may record the use of a pesticide on a commodity for which the pesticide is not registered. This might occur when a pesticide is applied to a site to control a particular pest, but is not applied directly to the crop in the field. For example, a grower may apply a fumigant to bare soil before planting, or a rodenticide to treat rodent burrows in a planted field, both without contact with the crop. Although the pesticide was not used on the crop, recording the data as if the application were made directly to the commodity provides valuable crop history information, particularly for enforcement purposes and for conducting analyses of trends in pesticide use. To avoid these records being rejected as errors, these types of products are flagged in the label database so that their use on any commodity is accepted.