Department of Pesticide Regulation Logo 
Peter M. Rooney
Secretary for

Department of Pesticide Regulation

James W. Wells, Director
1020 N Street - Sacramento, California 95814-5624 -

  California Notice 98-4
  POST UNTIL July 1, 1998

California State Seal
Pete Wilson


The Director of the Department of Pesticide Regulation (DPR) files this notice concerning the reevaluation of pesticide products with the Secretary of the Resources Agency for posting, pursuant to Articles 8 and 12 (Title 3) of the California Code of Regulations. This notice must remain posted for a period of 30 days for public inspection.


DPR commenced reevaluation of pesticide products intended for agricultural or commercial structural use and formulated as a liquid on April 29, 1994. On March 1, 1995, DPR placed all agricultural and commercial structural pesticides formulated as a solid into reevaluation. Due to the number of products included in these two reevaluations, DPR determined that listing the products in this notice was not practical.


DPR based the reevaluations on concerns about the release into the atmosphere of volatile organic compounds (VOCs) from pesticide product formulations. These VOCs may contribute to tropospheric ozone formation. VOCs can react in the troposphere in the presence of sunlight with nitrogen oxides to form ozone. Ozone is harmful to both human health and vegetation.

The federal Clean Air Act requires states to submit state implementation plans (SIP) for implementing, maintaining, and enforcing national ambient air quality standards (NAAQS) for air pollutants, such as ozone, in air quality control regions of the state. Any region that does not meet the NAAQS for a given pollutant is designated as a federal nonattainment area (NAA). Many areas in California do not currently meet the NAAQS for ozone.

In 1994, the California Air Resources Board (ARB) submitted a revised ozone SIP, which the U.S. Environmental Protection Agency approved in 1996. This SIP revision included a pesticide element which DPR developed in consultation with ARB. The pesticide element (also referred to as the Pesticide SIP) addresses VOCs that result from the use of agricultural and commercial structural pesticides. (Consumer product pesticidal sources of VOCs are regulated by ARB.) The goal of the Pesticide SIP is to reduce pesticidal sources of VOCs by 20 percent from the base year of 1990 to the year 2005. In addition, the California Clean Air Act requires each air district that has been designated as an NAA for the state ambient air quality standard for ozone (which is more stringent than the federal standard) to submit a plan to ARB for attaining and maintaining that standard. DPR plans to enforce the Pesticide SIP reduction goal in any air district that formally references the Pesticide SIP in its local attainment plan for meeting federal or state standards for ozone.

DPR intends to estimate agricultural and commercial structural use pesticide VOC emissions annually from 1990 through 2005. These estimations are calculated by multiplying the emission potential of each pesticide product used in a given year by the reported use of that product. The purpose of the reevaluations was to give registrants of agricultural and commercial structural use pesticides the opportunity to submit emission potential data for their products.


DPR placed pesticides formulated as liquids into reevaluation first because they were likely to have a higher percentage of VOCs than solid formulations. The term "liquid" includes pesticides formulated as flowable concentrates, emulsifiable concentrates, oils, suspensions, solutions/liquids (ready-to-use), aqueous concentrates, and microencapsulated. The term "solid" includes pesticides formulated as dusts/powders, granular/flakes, soluble powders, dry flowables, pellets/tablets/cakes/brickettes, and wettable powders.

DPR requested that the registrants of products included in each reevaluation submit data regarding the volatility emission potential of each pesticide product. DPR requested that the data be developed using a thermogravimetric analysis (TGA) method developed by DPR. Registrants of liquid formulation pesticides submitted the data by April 1, 1995, and registrants of solid formulation pesticides submitted the data by November 15, 1995. DPR has reviewed all of the submitted data and information. DPR's Home Page ( displays the estimated VOC emission potential of agricultural and commercial structural use pesticides.


DPR continues to use the data collected during these two reevaluations in implementing the Pesticide SIP. With this notice, DPR concludes the reevaluation of agricultural and commercial structural pesticide products formulated as liquids and solids.

NOTE: In order to estimate the VOC emission potential of all formulation types of agricultural and commercial structural use pesticides in future years, VOC emission data are needed for products registered in California after initiation of the two reevaluations. In addition, as new agricultural and commercial structural products are registered for use in California, DPR will need VOC emission data for each product. Please note that the emission data are not required for registration and failure to submit such data will not hold up the registration process. In addition, data are not required to be submitted for any product that is the subregistration of another product, provided the primary product is registered in California and the registrant of the primary product submits VOC emission potential data.

DPR never placed agricultural and commercial structural use liquid and solid products formulated in a pressurized state or gaseous products into reevaluation due to time constraints. Instead, DPR estimated the VOC emission potential of pressurized products using information from the most current confidential statement of formula on file with DPR in April 1996. VOC emission data are also needed for pressurized products registered in California after April 1996. In addition, as new pressurized agricultural and commercial structural products are registered for use in California, DPR will need VOC emission data for each product.

Registrants have the option of: (1) submitting TGA data, or
(2) requesting that DPR determine the emission potential of the product to be what remains after subtraction of the water, exempt ingredients, and/or inorganic ingredient content of the product
(request must be accompanied by a copy of the product's statement of formula). If a registrant feels that TGA methodology is not appropriate to a particular product because of inherent chemical properties, it may write to DPR and request a determination. The request must include all of the information that the registrant would like DPR to consider.

If no data or requests are submitted, DPR will assign a default VOC emission potential to the product based on TGA values reported for products of the same formulation category.

Copies of TGA protocols for pesticide products formulated as liquids, solids, and pressurized products, as well as VOC Data Submission Forms, are available upon request. The VOC Data Submission Forms are available in hard copy and on diskette in Excel 5.0 format. Please note that a separate VOC Data Submission Form must be submitted for each product, along with signed copies of all thermograms. A current confidential statement of formula must accompany the submission or it will be considered incomplete. The TGA methods can be run by the registrant's choice of laboratory; however, for convenience, a list of laboratories that have expressed an interest in conducting the TGA method is available upon request.

For questions regarding this notice or to obtain a copy of a TGA protocol, VOC Data Submission Form, or a list of laboratories, please contact Ms. Ann Prichard, Senior Environmental Research Scientist, Pesticide Registration Branch, by E-mail at ( or by telephone at (916) 324-3931.

For technical information and questions regarding the TGA methods and VOC Data Submission Forms, please contact Judy Pino, Ph.D., Senior Environmental Research Scientist, Environmental Monitoring and Pest Management Branch, by E-mail at ( or by telephone at (916) 324-4023.

original signed by Barry Cortez

May 12, 1998

Barry Cortez, Chief
Pesticide Registration Branch
(916) 445-4377


California Environmental Protection Agency