UC DANR Pesticide Use and Experimentation Lisa Blecker, Statewide Pesticide Coordinator Office of Pesticide Information and Coordination (OPIC) 530-752-3912.

UC DANR Pesticide Use UC DANR Pesticide Use and Experimentation and Experimentation

Lisa Blecker, Statewide Pesticide CoordinatorLisa Blecker, Statewide Pesticide Coordinator

Office of Pesticide Information and Office of Pesticide Information and Coordination (OPIC)Coordination (OPIC)

[email protected]

ucanr.org/opicucanr.org/opic

Rights and ResponsibilitiesRights and Responsibilities

Research rightsResearch rights UC has a mandate to conduct UC has a mandate to conduct

agricultural research.agricultural research. Researchers Researchers grantedgranted the right to the right to

conduct hazardous chemical research onconduct hazardous chemical research onUC and cooperatorsUC and cooperators’’ property. property.

Research responsibilitiesResearch responsibilities To do no harmTo do no harm To conduct intellectually honest research To conduct intellectually honest research

Pest Management Chemical Pest Management Chemical Experiments Create Risks Experiments Create Risks and Potential Liabilitiesand Potential Liabilities

RisksRisks To CooperatorsTo Cooperators To the PublicTo the Public To ConsumersTo Consumers To the UniversityTo the University ReputationReputation Research RightsResearch Rights

LiabilitiesLiabilities Individual ResearcherIndividual Researcher County, DANR and UCCounty, DANR and UC

Policy on Pesticides and Related Policy on Pesticides and Related Chemicals: Use and Chemicals: Use and

ExperimentationExperimentation ANR Administrative Handbook Section 281 ANR Administrative Handbook Section 281

Applies to UC ANRApplies to UC ANR All research, published pest All research, published pest

management guidelines and management guidelines and recommendations relating to recommendations relating to pesticide use are to be conducted in pesticide use are to be conducted in accordance with all applicable laws accordance with all applicable laws and regulations and this policy.and regulations and this policy.

Scope and DefinitionsScope and Definitions

Applies to all ANR employees who Applies to all ANR employees who use or handle pesticides for use or handle pesticides for experimental purposesexperimental purposes

Applies to experimentation with Applies to experimentation with pesticides or related substances in pesticides or related substances in any field test or field demonstration.any field test or field demonstration.

Where Does this Apply?Where Does this Apply?

On any CampusOn any Campus On Field StationsOn Field Stations On Agricultural Research and Extension CentersOn Agricultural Research and Extension Centers On any other land or treated site (including On any other land or treated site (including

livestock) when used in experimental pesticide livestock) when used in experimental pesticide research field trials and demonstration research field trials and demonstration operations that are activities of the Universityoperations that are activities of the University

Does not include greenhouses or Does not include greenhouses or laboratorieslaboratories

Pop QuizPop Quiz

UC Pesticide Policy Exempts you UC Pesticide Policy Exempts you from which of the following :from which of the following : PPE requirementsPPE requirements Research AuthorizationResearch Authorization Training pesticide handlersTraining pesticide handlers Restricted Materials PermitRestricted Materials Permit Pesticide Use ReportingPesticide Use Reporting Field postingField posting

Pop QuizPop Quiz

Exempt from Restricted Materials Exempt from Restricted Materials Permit and Research Authorization Permit and Research Authorization when using pesticides as part of when using pesticides as part of research, experimental or research, experimental or demonstration plotsdemonstration plots

DefinitionsDefinitions

Pesticide: Pesticide: Any chemical or biotic agent used or intended for Any chemical or biotic agent used or intended for

use for pest control. use for pest control. Pesticide includes any substance, or mixture of Pesticide includes any substance, or mixture of

substances which is intended to be used for substances which is intended to be used for defoliating plants, regulating plant growth, or for defoliating plants, regulating plant growth, or for preventing, destroying, repelling, or mitigating any preventing, destroying, repelling, or mitigating any pest which may infest or be detrimental to pest which may infest or be detrimental to vegetation, humans, animals, or households, or be vegetation, humans, animals, or households, or be present in any agricultural or nonagricultural present in any agricultural or nonagricultural environment whatsoever.environment whatsoever.

Any chemical or microbial agent that is being used Any chemical or microbial agent that is being used with the intent of testing in any field test.with the intent of testing in any field test.

Intent of UseIntent of Use

A pesticide can be any substance used to A pesticide can be any substance used to control a pest whether or not it is registered control a pest whether or not it is registered as a pesticide.as a pesticide.

If that substance is not labeled for the use or If that substance is not labeled for the use or lacks an exemption it would be illegal to use it lacks an exemption it would be illegal to use it for pest controlfor pest control

ExceptionsExceptions Home remedies used by the homeowner Home remedies used by the homeowner

for non-agricultural sitesfor non-agricultural sites Substances such as steam for weed controlSubstances such as steam for weed control

Some Materials that are Some Materials that are PesticidesPesticides

DisinfectantsDisinfectants CloroxClorox Chemicals to sterilize benches or countertopsChemicals to sterilize benches or countertops

AlgaecidesAlgaecides Animal repellentsAnimal repellents PheromonesPheromones

All must be registered and the All must be registered and the site listed for legal usesite listed for legal use

DefinitionsDefinitions

Experimental Pesticide:Experimental Pesticide: New formulations of existing products.New formulations of existing products. New products containing old active New products containing old active

ingredients.ingredients. Applications to any crop or site not on the Applications to any crop or site not on the

California-registered label California-registered label No California label existsNo California label exists Use of any spray adjuvant not registered in Use of any spray adjuvant not registered in

California.California. Use in conflict with the CA registered label.Use in conflict with the CA registered label.

Use in Conflict with LabelUse in Conflict with Label Does not include:Does not include:

Applications at lower than label rates.Applications at lower than label rates. Less frequent application intervals.Less frequent application intervals. Tank mixes (unless specifically Tank mixes (unless specifically

prohibited on the label).prohibited on the label). Use against pests not listed or Use against pests not listed or

prohibited on the label.prohibited on the label. Increasing the concentration of the mixture, if published Increasing the concentration of the mixture, if published

in a UC Pest Management Guidelinein a UC Pest Management Guideline Cannot increase the amount of a.i. applied per acreCannot increase the amount of a.i. applied per acre

Providing all other label directions are followed.Providing all other label directions are followed.

Potential Groundwater Potential Groundwater Contaminating ChemicalsContaminating Chemicals

Listed in 3 CCR Section 6800(a)Listed in 3 CCR Section 6800(a) May be applied by UC for research and May be applied by UC for research and

experimental purposes experimental purposes only pursuant to a only pursuant to a valid research authorizationvalid research authorization. The UC . The UC research exemption from the requirement for research exemption from the requirement for a Research Authorization a Research Authorization does not applydoes not apply when these potentially groundwater polluting when these potentially groundwater polluting chemicals are used for research and chemicals are used for research and experimentation purposes.experimentation purposes.

Experimental Pesticide UseExperimental Pesticide Use Application is made for research purposes only.Application is made for research purposes only. No commercial pest control benefit is intended or No commercial pest control benefit is intended or

expected.expected. Applications must conform to State and Federal Applications must conform to State and Federal

guidelines.guidelines.

Pesticide applications that are made solely for pest Pesticide applications that are made solely for pest control purposes rather than research purposes control purposes rather than research purposes cannot be experimental and must be made in cannot be experimental and must be made in accordance with CA registered labels and all accordance with CA registered labels and all applicable laws and regulations.applicable laws and regulations.

Pesticide Research and Pesticide Research and Pesticides used for Pesticides used for ExperimentationExperimentation

Research using pest control chemicals Research using pest control chemicals can consist of either experimental can consist of either experimental pesticide applications or applications pesticide applications or applications made strictly in accordance with CA made strictly in accordance with CA registered labels, or both. If registered labels, or both. If experimental pesticide uses are experimental pesticide uses are involved, the use must follow either this involved, the use must follow either this policy or the requirements and policy or the requirements and procedures of the DPR Research procedures of the DPR Research Authorization Program.Authorization Program.

Exemption of UC from Exemption of UC from Obtaining Research Obtaining Research

AuthorizationAuthorization Title 3, California Code of Title 3, California Code of

Regulations (CCR), Section 6268, Regulations (CCR), Section 6268, Research AuthorizationResearch Authorization University employees are exempt, University employees are exempt,

providing UC has a policy covering providing UC has a policy covering experimental use.experimental use.

Microbial PesticidesMicrobial Pesticides

The USEPA generally requires a notification The USEPA generally requires a notification or a Federal EUP for any experimental or a Federal EUP for any experimental program involving the deliberate release into program involving the deliberate release into the environment of the environment of living, genetically living, genetically engineered microbial pesticidesengineered microbial pesticides, , irrespective of the acreage involved.irrespective of the acreage involved.

The DPR Pesticide Registration Branch must The DPR Pesticide Registration Branch must also be notified of any proposed field testing also be notified of any proposed field testing (on or off UC property) by UC personnel (on or off UC property) by UC personnel involving genetically engineered microbial involving genetically engineered microbial pesticides.pesticides.

6800 (a) List6800 (a) List

AtrazineAtrazine SimazineSimazine BromacilBromacil DiuronDiuron

PrometonPrometon BentazonBentazon NorflurazonNorflurazon

See EH 03-05 for list of areas affected: http://www.cdpr.ca.gov/docs/emon/grndwtr/eh0305update.pdf

Groundwater Protection Groundwater Protection AreasAreas

See map of Riverside County

NoncomplianceNoncompliance

Will result in the loss of the Will result in the loss of the exemption provided under Title 3 exemption provided under Title 3 CCR, Section 6268.CCR, Section 6268.

May be deemed a violation of Section May be deemed a violation of Section 6260.6260. Authorization for ResearchAuthorization for Research

Restricted Materials PermitRestricted Materials Permit

Required of UC employees when Required of UC employees when possessing, using, or applying possessing, using, or applying any restricted material for any restricted material for pest control purposespest control purposes..

No permit is required for restricted No permit is required for restricted materials materials used only for experimental or used only for experimental or research purposesresearch purposes, when possessed or , when possessed or used by or under the supervision of used by or under the supervision of research personnel from UC.research personnel from UC.

How do I know if I need a How do I know if I need a Research Authorization or a Research Authorization or a Restricted Materials Permit?Restricted Materials Permit?

Do I need an RA or a RMP?Do I need an RA or a RMP?

I am using a restricted material for research and/or demonstration

I am using a restricted material for routine pest

control

RMPNeeded!!

!

Am I using pesticides

listed in 3CCR S. 6800?

Am I in a groundwater

sensitive area?

RMP and RA

Needed!!!

No RMP No RA

YES

YES

NO

NO

Employee of UCEmployee of UC

A A ““employeeemployee”” of the UC, for purposes of the UC, for purposes of this policy, is defined as any of this policy, is defined as any person whose current UC position person whose current UC position description or Ag Experiment Station description or Ag Experiment Station project description includes project description includes responsibilities for pest management responsibilities for pest management research and demonstration.research and demonstration.

What About County What About County Employees?Employees?

If working with or under the If working with or under the supervision of a UC employee, supervision of a UC employee, ensure that they are trained and ensure that they are trained and wear appropriate safety equipment.wear appropriate safety equipment.

SupervisorSupervisor

For purposes of this policy, For purposes of this policy, ““supervisorsupervisor”” shall be defined as an employee of the shall be defined as an employee of the UC working as a researcher, project UC working as a researcher, project leader, Principal Investigator or leader, Principal Investigator or designated representative responsible designated representative responsible for execution of any pesticide research for execution of any pesticide research project, employee training, or pest project, employee training, or pest control procedure.control procedure.

University PropertyUniversity Property

land owned or land owned or controlled by the controlled by the UC and includes UC and includes only property only property over which the UC over which the UC maintains day-to-maintains day-to-day controlday control

Non-UC PropertyNon-UC Property

Property under the day-to-day Property under the day-to-day control of individuals and institutions control of individuals and institutions other than the UC is not included in other than the UC is not included in the definition of UC property.the definition of UC property.

ToleranceTolerance

Tolerance is the maximum pesticide residue Tolerance is the maximum pesticide residue level that can legally remain on a commodity level that can legally remain on a commodity at the time of harvest, as defined in at the time of harvest, as defined in Title 40 Code of Federal Regulations, Part 180.

Maximum Residue Levels (MRLs) are the Maximum Residue Levels (MRLs) are the international equivalent of tolerances international equivalent of tolerances http://www.mrldatabase.com/

US tolerances and MRLs may US tolerances and MRLs may notnot be be equivalent.equivalent.

Responsibilities Incurred by Responsibilities Incurred by Employees of UCEmployees of UC

Supervisor: Supervisor: Provide a safe work environment and Provide a safe work environment and

provide training to persons working under their provide training to persons working under their direction.direction.

Ensure that pesticides are used in accordance with Ensure that pesticides are used in accordance with State and Federal laws, regulations, and label State and Federal laws, regulations, and label requirements.requirements.

Make employees aware of the hazards of the Make employees aware of the hazards of the chemicals and pesticides being used for chemicals and pesticides being used for experimentationexperimentation

Use the pesticide label as a guide to employee Use the pesticide label as a guide to employee training.training.

In absence of a registered label, use the MSDS as In absence of a registered label, use the MSDS as guide to training and personal protective equipment guide to training and personal protective equipment requirements.requirements.

TrainingTraining

Must include information on pesticide Must include information on pesticide hazards and safety prior to any hazards and safety prior to any handling of pesticides.handling of pesticides.

Laws and regulations applicable to all Laws and regulations applicable to all activities they may perform.activities they may perform.

Personal SafetyPersonal Safety AgeAge. Persons under the age of 18 shall not . Persons under the age of 18 shall not

mix, load, or apply pesticidesmix, load, or apply pesticides Instruction and trainingInstruction and training.. The supervisor The supervisor

shall provide training for each employee shall provide training for each employee handling pesticides. This shall include:handling pesticides. This shall include: Potential hazards involved for each pesticidePotential hazards involved for each pesticide Safety procedures to be followedSafety procedures to be followed Clothing and protective equipmentClothing and protective equipment Common symptoms of pesticide poisoning and Common symptoms of pesticide poisoning and

ways poisoning can occurways poisoning can occur Medical supervision requirementsMedical supervision requirements Applicable laws, regulations and label requirementsApplicable laws, regulations and label requirements

Pesticide Safety Training Pesticide Safety Training Requirements Requirements

30 Days after REI expires

Pesticide Handler training required

Early-Entry Worker training required No training

required

FIELD TIMELINE

Training Timeline for Field Workers and Handlers

Restricted Entry

Interval (REI)

No pesticide application

Pesticide application

No training required

Fieldworker training required

Before pesticide

application

Timing and record of instruction and trainingTiming and record of instruction and training.. Instruction shall be completed before the employee is Instruction shall be completed before the employee is allowed to handle pesticides and at least annually allowed to handle pesticides and at least annually thereafter. The supervisor shall maintain a permanent thereafter. The supervisor shall maintain a permanent record of the date and extent of instruction given.record of the date and extent of instruction given.

Emergency medical careEmergency medical care.. The supervisor shall make The supervisor shall make prior arrangements for emergency medical care as prior arrangements for emergency medical care as required by 3 CCR Section 6726.required by 3 CCR Section 6726.

Medical SupervisionMedical Supervision.. The supervisor shall provide The supervisor shall provide medical supervision in the form of a written agreement medical supervision in the form of a written agreement with a licensed physician for any employee who with a licensed physician for any employee who regularly handles any Category I or II pesticide regularly handles any Category I or II pesticide containing an organophosphate or carbamate. This shall containing an organophosphate or carbamate. This shall meet the requirements of 3 CCR Section 6728.meet the requirements of 3 CCR Section 6728.

Regularly Handle PesticidesRegularly Handle Pesticides

Applies only to cholinesterase Applies only to cholinesterase inhibiting pesticides.inhibiting pesticides.

Employee handles pesticide any part Employee handles pesticide any part of a day for more than 6 days in any of a day for more than 6 days in any 30 consecutive days.30 consecutive days.

Excluding days where solely using Excluding days where solely using closed mixing system or water closed mixing system or water soluble bags.soluble bags.

Other General Other General RequirementsRequirements

The supervisor shall meet the requirements of The supervisor shall meet the requirements of state regulations for:state regulations for: Working alone with pesticides (Category 1)Working alone with pesticides (Category 1)

Contact every 2 hours by day, 1 hour at nightContact every 2 hours by day, 1 hour at night Clothing change areaClothing change area Mixing and loading site requirementsMixing and loading site requirements Work clothingWork clothing Protective equipmentProtective equipment Adequate lightAdequate light Servicing equipmentServicing equipment Equipment specificationsEquipment specifications Availability of MSDSsAvailability of MSDSs

Where do I Find Training Where do I Find Training Resources?Resources?

ANR Environmental Health & Safety ANR Environmental Health & Safety Web SiteWeb Site http://safety.ucanr.org/ Brian Oatman, R&E Centers Brian Oatman, R&E Centers

Environmental Health & Safety Environmental Health & Safety CoordinatorCoordinator

(530) 752-6024(530) 752-6024 [email protected]@ucdavis.edu

Information Available at Information Available at ANR ANR

EH & S Web Site EH & S Web Site Ag Worker Protection ProgramAg Worker Protection Program Confined Space ProgramConfined Space Program Disposal of Chemical WasteDisposal of Chemical Waste Employee Health & Safety TrainingEmployee Health & Safety Training Experimental Use of PesticidesExperimental Use of Pesticides Emergency Eyewash & Shower Emergency Eyewash & Shower

Placement/DesignPlacement/Design

Information Available at Information Available at ANR ANR

EH & S Web Site (Cont.)EH & S Web Site (Cont.) Health & Safety Training LibraryHealth & Safety Training Library Pesticide Use & HandlingPesticide Use & Handling Respiratory Protection ProgramRespiratory Protection Program Storage and Removal of Regulated Storage and Removal of Regulated

WasteWaste

Environmental Health & Safety Environmental Health & Safety Notes – Agricultural OperationsNotes – Agricultural Operations Pesticide Glove UsePesticide Glove Use General Tractor General Tractor

SafetySafety PTO SafetyPTO Safety Pinch Point Pinch Point

HazardsHazards High-Pressure High-Pressure

Washer SafetyWasher Safety

All-Terrain VehiclesAll-Terrain Vehicles Flail Mower and Flail Mower and

Shredder SafetyShredder Safety Shear and Cutting Shear and Cutting

Point HazardsPoint Hazards Fence SafetyFence Safety And Many MoreAnd Many More

Restricted Entry IntervalRestricted Entry Interval

Entry after ApplicationEntry after Application No person shall enter any area treated No person shall enter any area treated

with a pesticide unless he or she follows with a pesticide unless he or she follows the labeling directions for entry the labeling directions for entry activities. State restricted entry activities. State restricted entry regulations (3 CCR Section 6772) may be regulations (3 CCR Section 6772) may be more restrictive than those stated on the more restrictive than those stated on the label. In all cases the most restrictive label. In all cases the most restrictive reentry regulations shall be followed.reentry regulations shall be followed.

Pesticides with State Pesticides with State Specific REIs (3 CCR Section Specific REIs (3 CCR Section

6772)6772) Azinphos-methyl Azinphos-methyl

(Guthion)(Guthion) Chlorpyrifos Chlorpyrifos

(Lorsban)(Lorsban) DiazinonDiazinon Endosulfan Endosulfan

(Thiodan)(Thiodan) Methidathion Methidathion

(Supracide)(Supracide) Methomyl (Lannate)Methomyl (Lannate)

Parathion-methyl Parathion-methyl (non-encapsulated)(non-encapsulated)

Phorate (Thimet)Phorate (Thimet) Phosmet (Imidan)Phosmet (Imidan) Propargite Propargite

(Omite/Comite)(Omite/Comite) Sulfur (not specific Sulfur (not specific

to formulation)to formulation)

   CROPS OTHER CROPSPESTICIDE APPLES CITRUS CORN GRAPES PEACHES/

NECTARINES

Azinphos-methyl

14(B) 30   21 14(B) 14(A)(B)

Chlorpyriphos   2        Diazinon   5   5 5  Endosulfan 2 2 2 2 2 2Malathion   1   1 1  Methidathion   30        Methomyl       7(C)    Parathion-methyl (non- encapsulated)

14 14(D) 14(D) 14(E) 21 14(D)

Phorate (Thimet)

    7      

Phosmet (Imidan)

      5 5  

Propargite 21 42 7 30 21 21(F)(G)Sulfur       3(H)    

(A) This restricted entry interval for other crops applies to stone fruit, such as apricots, cherries, plums, and prunes, and pome fruit, such as pears, only. Stone fruit does not include almonds and other nut crops.(B) If the total azinphos-methyl applied in the current calendar year is 1.0 pounds per acre or less, thinning may be done after seven days. (C) Applications of methomyl made after August 15, have a 21-day restricted entry interval. This interval may be terminated after 10 days if leaf samples tested pursuant to Section 6774 (c)(4) show 0.1 micrograms per square centimeter or less of dislodgeable foliar residue of methomyl.(D) This restricted entry interval applies only when more than one pound per acre of non-encapsulated parathion-methyl is applied.(E) The restricted entry interval for non-encapsulated parathion-methyl on grapes in Monterey County is six days.(F) The restricted entry interval for strawberries and field grown roses treated with propargite is 3 days.(G) The restricted entry interval for cotton fields treated with propargite is seven days. However, from the end of the restricted entry interval until the beginning of harvest, the employer shall assure that employees entering propargite treated cotton fields wear work clothing with long sleeves and legs and gloves.(H) This restricted entry interval for sulfur applies from May 15 through harvest in the counties of: Fresno, Kern, Kings, Madera, Merced, San Joaquin, Stanislaus, and Tulare; and during March and April in Riverside County.

Pesticides with State Specific Pesticides with State Specific REIsREIs

In Absence of LabelingIn Absence of Labeling Do not enter treated areas for 4 hours after Do not enter treated areas for 4 hours after

application unless protected. After 4 hours, application unless protected. After 4 hours, anyone entering the area must wear shoes and anyone entering the area must wear shoes and socks, a long sleeved shirt, and long pants.socks, a long sleeved shirt, and long pants.

Non-Ag and Urban areas: Persons shall not enter Non-Ag and Urban areas: Persons shall not enter areas treated with liquid formulations for 2 hours areas treated with liquid formulations for 2 hours and until the treated area has dried. When using and until the treated area has dried. When using baits, dusts and other dry formulations, persons baits, dusts and other dry formulations, persons should not enter the area during the application.should not enter the area during the application.

Standard industry care and practice Standard industry care and practice should be observed.should be observed.

When do I post a Restricted When do I post a Restricted Entry Interval (REI) sign?Entry Interval (REI) sign?

Whenever the label requires posting Whenever the label requires posting (Federal regulation)(Federal regulation)

If REI is greater than 7 days (CA If REI is greater than 7 days (CA regulation)regulation)

If REI is posted in 3 CCR Section 6772If REI is posted in 3 CCR Section 6772

Posting Treated PlotsPosting Treated Plots Post in accordance with any applicable Post in accordance with any applicable

pesticide label or regulation.pesticide label or regulation. For non-ag and urban areas, notify the For non-ag and urban areas, notify the

owners or residents of the treated property owners or residents of the treated property with information indicating the nature of the with information indicating the nature of the treatment, time and date of treatment, and treatment, time and date of treatment, and any special instructions regarding restricted any special instructions regarding restricted entry or use after treatmententry or use after treatment

In plots treated with materials requiring In plots treated with materials requiring restricted entry intervals under 3 CCR restricted entry intervals under 3 CCR Section 6772, reentry intervals must be Section 6772, reentry intervals must be posted.posted.

Posting IssuesPosting Issues

Verify with property owner and/or PCO Verify with property owner and/or PCO that a REI is not in effect.that a REI is not in effect.

Double-check any entry points for REI Double-check any entry points for REI warning sign.warning sign.

Immediately follow-up on any illness Immediately follow-up on any illness complaints after employees work in a complaints after employees work in a growergrower’’s field/orchard.s field/orchard.

Remove posting signs within 3 days of REI Remove posting signs within 3 days of REI expiration.expiration.

Personal Protective Personal Protective Equipment (PPE) for Equipment (PPE) for

Unregistered PesticidesUnregistered Pesticides If equivalent to Category I for eye or skin If equivalent to Category I for eye or skin

damage: damage: Coveralls over long-sleeved shirtCoveralls over long-sleeved shirt Long pantsLong pants Chemical-resistant gloves Chemical-resistant gloves Chemical-resistant footwear plus socksChemical-resistant footwear plus socks Protective eyewearProtective eyewear Chemical resistant headgear for overhead Chemical resistant headgear for overhead

exposureexposure Chemical-resistant apron when cleaning Chemical-resistant apron when cleaning

equipment, mixing or loadingequipment, mixing or loading

Personal Protective Personal Protective Equipment (PPE) for Equipment (PPE) for

Unregistered PesticidesUnregistered Pesticides If equivalent to Category I for systemic If equivalent to Category I for systemic

toxicity:toxicity: Long-sleeved shirtLong-sleeved shirt Long pantsLong pants Chemical-resistant gloves Chemical-resistant gloves Shoes plus socksShoes plus socks Protective eyewear (face shield for mixers and Protective eyewear (face shield for mixers and

loaders)loaders) Chemical-resistant apron when mixing or Chemical-resistant apron when mixing or

loadingloading Respirator, where required by labelRespirator, where required by label

Unidentified or Unlabeled Unidentified or Unlabeled PesticidesPesticides

Shall be stored, transported, Shall be stored, transported, handled, and disposed of according handled, and disposed of according to the standards established by State to the standards established by State and County regulations for Category I and County regulations for Category I pesticides.pesticides.

Environmental Considerations Environmental Considerations in Determining Plot Locationsin Determining Plot Locations The supervisor shall consider the potential The supervisor shall consider the potential

consequences of any proposed experimental use of consequences of any proposed experimental use of pesticides, paying particular attention to proximity pesticides, paying particular attention to proximity to:to: Areas of frequent human activity or habitation (especially Areas of frequent human activity or habitation (especially

schools)schools) Bodies of sources of waterBodies of sources of water Wildlife management areasWildlife management areas Critical habitats of rare or endangered speciesCritical habitats of rare or endangered species Livestock and cropsLivestock and crops

All research applications will be made in a way that All research applications will be made in a way that minimizes adverse environmental impacts.minimizes adverse environmental impacts.

Pesticide Use Record Pesticide Use Record Keeping and ReportingKeeping and Reporting

Supervisor shall keep a record for each Supervisor shall keep a record for each application:application: Location of siteLocation of site Plot size and total area treatedPlot size and total area treated Each commodity, crop, or site treatedEach commodity, crop, or site treated Pest species of concernPest species of concern Date of applicationDate of application Application methodApplication method Concentration and volume of pesticide appliedConcentration and volume of pesticide applied Date commodity was destroyed (when required)Date commodity was destroyed (when required) Name of grower, where applicableName of grower, where applicable

Records RetentionRecords Retention

Retained by supervisor, the supervisorRetained by supervisor, the supervisor’’s s campus departmental office, or the campus departmental office, or the appropriate county CE office.appropriate county CE office.

For at least 2 years after the final pesticide For at least 2 years after the final pesticide application.application.

Records shall be made available upon request Records shall be made available upon request to the county agricultural commissioner or to the county agricultural commissioner or DPR.DPR. Note: Policy makes records public: requires they Note: Policy makes records public: requires they

be available on request by agency.be available on request by agency.

Crop Control, Disposition, Crop Control, Disposition, and Destruct Notification and Destruct Notification

RequirementsRequirements Commodities treated with any Commodities treated with any

experimental pesticide for which there is experimental pesticide for which there is no pesticide residue tolerance or tolerance no pesticide residue tolerance or tolerance exemption cannot enter the channels of exemption cannot enter the channels of trade or in any way be made available for trade or in any way be made available for use as a human or animal food or feed.use as a human or animal food or feed.

Supervisor has primary responsibility to Supervisor has primary responsibility to ensure that the treated commodity is ensure that the treated commodity is posted and destroyed.posted and destroyed.

DestroyedDestroyed Destroyed means rendered unfit for Destroyed means rendered unfit for

utilization as human or animal feed.utilization as human or animal feed.

Photo: Dan Marcum

Remaining Plant PartsRemaining Plant Parts

All parts of the treated commodity All parts of the treated commodity potentially suitable for use as human potentially suitable for use as human or animal food or feed and not or animal food or feed and not removed from the site for research removed from the site for research purposes shall be destroyed.purposes shall be destroyed.

Posting RequirementsPosting Requirements Prior to application, a sign shall be posted at Prior to application, a sign shall be posted at

each corner of the experimental plot with the each corner of the experimental plot with the words, words, ““Commodity treated with Commodity treated with experimental pesticide, do not harvest.experimental pesticide, do not harvest.”” The The signs shall be in English and Spanish, and of signs shall be in English and Spanish, and of a size so the wording is readable to a person a size so the wording is readable to a person with normal vision, from a distance of 25 with normal vision, from a distance of 25 feet. Signs will remain in place until treated feet. Signs will remain in place until treated crop is destroyed.crop is destroyed.

Photo: Bennie Fouche

Requirements for Trials Requirements for Trials Conducted off UC PropertyConducted off UC Property

At least 24 hours prior to commencement of At least 24 hours prior to commencement of any any experimental pesticideexperimental pesticide trial on property trial on property not owned or controlled by the UC, the not owned or controlled by the UC, the supervisor shall submit to the county supervisor shall submit to the county agricultural commissioner and grower a copy agricultural commissioner and grower a copy of a document that shall include the of a document that shall include the information on the following slide.information on the following slide.

This serves as the equivalent of a Notice of This serves as the equivalent of a Notice of Intent (NOI) Intent (NOI)

Supervisor name, address, phone number and Supervisor name, address, phone number and date of reportdate of report

Qualified Applicator Certificate NumberQualified Applicator Certificate Number Experimental pesticide to be applied and USEPA Experimental pesticide to be applied and USEPA

Registration number. If USEPA number is not Registration number. If USEPA number is not available, use the chemical name or available, use the chemical name or experimental number from the MSDSexperimental number from the MSDS

Location of experimental trial (grower or ranch Location of experimental trial (grower or ranch name, address and site ID number)name, address and site ID number)

Size of trial (acres or rows)Size of trial (acres or rows) Commodity or site to be treatedCommodity or site to be treated Anticipated date of first and last applicationsAnticipated date of first and last applications Intended disposition of treated crop (harvest or Intended disposition of treated crop (harvest or

destruction)destruction) Date of anticipated harvest or destruction of Date of anticipated harvest or destruction of

commoditycommodity Signature of supervisor responsibleSignature of supervisor responsible

APPENDIX IPESTICIDE APPLICATION AND NOTIFICATION REQUIREMENTS

FOR TRIALS CONDUCTED OFF UNIVERSITY PROPERTY

At least 24 hours prior to commencement of any experimental pesticide trial on property not owned or controlled bythe University, submit this completed form to the local county agricultural commissioner and grower.

County  ______________________________

                           Research Supervisor                                                         Grower                                       Name:  _________________________________                   ___________________________________Address:  _______________________________                   __________________________________________________________________________                   ___________________________________Phone: _________________________________                   ___________________________________

QAC Certificate Number (of supervisor of application)_________________________________________

Pesticides to be applied, including product name, chemical name, experimental number, or U.S. EPA registration number, as appropriate: (Attach list if needed)

Location of trial and site identification number:  ________________________________________________________________________________________________________________________________Size of trial:  ________________________________________________________________________Commodity to be treated:  ______________________________________________________________Anticipated dates of first and last applications:  ______________________________________________Intended crop disposition:                

                                                             ___      Harvest - Crop can enter channels of trade

                                                                  ___      Destroy crop or use for research purposes only                                                                  ___      Non-crop use or non-bearing crop -                                                                no crop disposition is necessary             

Date of anticipated harvest or destruction of treated commodity:_________________________________

Signature of Supervisor of Research Trial ______________________________   DATE______________

Reporting Crop DestructReporting Crop Destruct

Some CACs require a 24 hour notice Some CACs require a 24 hour notice of crop destruct for trials off UC of crop destruct for trials off UC property.property.

Best to check with CAC when Best to check with CAC when submitting Appendix I to determine if submitting Appendix I to determine if they want a crop destruct notice, too.they want a crop destruct notice, too.

It is helpful to submit a detailed map It is helpful to submit a detailed map of the crop destruct site.of the crop destruct site.

Pesticide Use Reporting Pesticide Use Reporting RequirementsRequirements

Must report pesticide use on or off UC propertyMust report pesticide use on or off UC property On UC Property: Either directly as the person On UC Property: Either directly as the person

responsible or through other means such as a monthly responsible or through other means such as a monthly summary of the RECsummary of the REC

Off UC Property: Provide information to operator of Off UC Property: Provide information to operator of property for his monthly summary reportproperty for his monthly summary report

Must be reported within 7 days for restricted Must be reported within 7 days for restricted materials or 30 days for other materialsmaterials or 30 days for other materials

Some CACs may request other forms for reporting Some CACs may request other forms for reporting such as DPRs RA reporting formsuch as DPRs RA reporting form

ENF 07-08ENF 07-08

DPR issued an enforcement letter to DPR issued an enforcement letter to CACs clarifying crop destruct CACs clarifying crop destruct requirements, particularly as they requirements, particularly as they relate to UC research.relate to UC research.

http://www.cdpr.ca.gov/docs/county/cacltrs/penfltrs/penf2007/2007008.htm

What Happens if Treated What Happens if Treated Commodity is Potentially Made Commodity is Potentially Made Available for Human or Animal Available for Human or Animal

Consumption?Consumption? Persons conducting the research shall Persons conducting the research shall

IMMEDIATELY notify:IMMEDIATELY notify: CAC CAC GrowerGrower DPR DPR UC ANR UC ANR Department Chair (CE Specialists and AES Department Chair (CE Specialists and AES

faculty) faculty) County Director (Farm Advisors)County Director (Farm Advisors)

Violations of UC Crop Violations of UC Crop Destruct PolicyDestruct Policy

Experimental plots harvested and Experimental plots harvested and marketedmarketed

PeachesPeaches Reliable source; no direct costsReliable source; no direct costs Kiwi Fruits Kiwi Fruits Reliable source; no direct costsReliable source; no direct costs Pumpkins Pumpkins Documented; minor direct costsDocumented; minor direct costs Cherries Cherries Documented; no direct costsDocumented; no direct costs Tomatoes Tomatoes Documented; Quietly settledDocumented; Quietly settled

No known violations for over 11 years!!!No known violations for over 11 years!!!

Registered UsesRegistered Uses

Food or feed treated with pesticides Food or feed treated with pesticides registered for application on the test registered for application on the test site and applied at or below the site and applied at or below the registered label rates may be registered label rates may be harvested and allowed to enter the harvested and allowed to enter the food marketing chain, provided all food marketing chain, provided all other label and State regulatory other label and State regulatory conditions are met.conditions are met.

Federally, but Not CA Federally, but Not CA Registered PesticidesRegistered Pesticides

If product has federal registration If product has federal registration and tolerance, may be used and tolerance, may be used experimentally in CA without crop experimentally in CA without crop destruct.destruct.

Pesticides Applied above Pesticides Applied above Label RatesLabel Rates

Experimental applications may Experimental applications may include those above the label rateinclude those above the label rate

The tolerance must not be exceeded The tolerance must not be exceeded at the time of harvestat the time of harvest

Laboratory analysis may be required Laboratory analysis may be required to assure the researcher and growerto assure the researcher and grower

The pesticide use report can be for The pesticide use report can be for the site or the site or ““research commodityresearch commodity””

Qualifications of Persons Qualifications of Persons Supervising Pesticide Supervising Pesticide

ApplicationsApplications Persons directly supervising Persons directly supervising

pesticide applications shall hold pesticide applications shall hold the Qualified Applicator Certificate the Qualified Applicator Certificate (QAC). (QAC).

It is recommended that employees It is recommended that employees whose responsibilities include whose responsibilities include applying pesticides be certified as applying pesticides be certified as a Qualified Applicator (QAC).a Qualified Applicator (QAC).

QAC License CategoriesQAC License Categories

Laws, Regulations and Laws, Regulations and Basic PrinciplesBasic Principles

Residential, Industrial Residential, Industrial and Institutionaland Institutional

Landscape Landscape MaintenanceMaintenance

Right-of-WayRight-of-Way Plant AgriculturePlant Agriculture ForestForest AquaticAquatic RegulatoryRegulatory Seed TreatmentSeed Treatment

Animal AgricultureAnimal Agriculture Demonstration and Demonstration and

ResearchResearch Health RelatedHealth Related Wood PreservativeWood Preservative Antifouling TributyltinAntifouling Tributyltin Sewer Line Root Sewer Line Root

ControlControl Field FumigationField Fumigation Microbial Pest ControlMicrobial Pest Control Maintenance Maintenance

GardenerGardener

Licensing and Certification Licensing and Certification FeesFees

http://www.cdpr.ca.gov/docs/license/fees.pdf

Exam ScheduleExam Schedule

http://www.cdpr.ca.gov/docs/license/exam_sched.pdf

Study MaterialsStudy Materials

http://www.cdpr.ca.gov/docs/license/studymat/index.htm

Continuing EducationContinuing Educationfor QAC/QALfor QAC/QAL

Accumulate at least 20 hours of Accumulate at least 20 hours of approved continuing education every 2 approved continuing education every 2 years before certificate renewal. years before certificate renewal.

A minimum of 4 of the 20 hours must A minimum of 4 of the 20 hours must cover the topic of pesticide laws and cover the topic of pesticide laws and regulations regulations

The primary license location The primary license location isis

Department of Pesticide RegulationDepartment of Pesticide RegulationPesticide Enforcement BranchPesticide Enforcement BranchLicensing and Certification ProgramLicensing and Certification Program1001 I Street1001 I StreetSacramento, CA 95814-2828Sacramento, CA 95814-2828

www.cdpr.ca.gov/docs/license/liccert.htm Questions call (916) 445-4038Questions call (916) 445-4038

Storage, Transportation, Storage, Transportation, Disposal of PesticidesDisposal of Pesticides

Containers or equipment that hold or Containers or equipment that hold or have held pesticides shall not be have held pesticides shall not be stored, handled, emptied, disposed stored, handled, emptied, disposed of, or left unattended in such a of, or left unattended in such a manner that they may present a manner that they may present a hazard to persons, animals, food, hazard to persons, animals, food, feed, crops, or property.feed, crops, or property.

Storage and DeliveryStorage and Delivery

The supervisor is responsible for The supervisor is responsible for all containers or equipment on all containers or equipment on the work site that hold or have the work site that hold or have held a pesticide. The supervisor held a pesticide. The supervisor shall either:shall either: Store all containers or equipment in Store all containers or equipment in

a locked enclosure, ora locked enclosure, or Provide a responsible person to Provide a responsible person to

maintain control over the maintain control over the containers at all times.containers at all times.

Storage and DeliveryStorage and Delivery

When not being used, all pesticide When not being used, all pesticide containers (regardless of the amount containers (regardless of the amount of pesticide they contain) shall have of pesticide they contain) shall have lids and closures securely fastened.lids and closures securely fastened.

Pesticides shall not be delivered to Pesticides shall not be delivered to any property unless they are stored any property unless they are stored or controlled as required.or controlled as required.

Posting of Pesticide Storage Posting of Pesticide Storage AreasAreas

All areas where pesticides or their used All areas where pesticides or their used containers are stored shall be posted with containers are stored shall be posted with warning signs as required by 3 CCR, warning signs as required by 3 CCR, Section 6674 in English and any other Section 6674 in English and any other appropriate language.appropriate language.

For unregistered pesticides and related For unregistered pesticides and related chemicals, the MSDS shall be used to chemicals, the MSDS shall be used to determine the appropriate warning sign determine the appropriate warning sign for posting.for posting.

POISON STORAGE AREA

ALL UNAUTHORIZED PERSONS KEEP OUT

KEEP DOOR LOCKED WHEN

NOT IN USE

Pesticide Storage Area SignPesticide Storage Area Sign

Container Label Container Label RequirementsRequirements

The manufacturerThe manufacturer’’s label shall not be s label shall not be removed from any pesticide removed from any pesticide container.container.

Service ContainersService Containers

Service containers are those other than those Service containers are those other than those bearing the registered pesticide label.bearing the registered pesticide label.

Regardless of size, shall be labeled with the Regardless of size, shall be labeled with the following information:following information: Signal word from the pesticide label, if availableSignal word from the pesticide label, if available Name of pesticideName of pesticide Name of manufacturerName of manufacturer Name of active ingredient (or mfg. Code no.)Name of active ingredient (or mfg. Code no.) Name, address, and telephone number of the person Name, address, and telephone number of the person

responsible for the demonstration, application or responsible for the demonstration, application or research.research.

This includes backpack sprayers!This includes backpack sprayers!

Prohibited Service Prohibited Service ContainersContainers

Pesticides shall not be placed or kept Pesticides shall not be placed or kept in any container commonly used for in any container commonly used for food, drink, household products, or food, drink, household products, or feed.feed. Soda, water and milk bottlesSoda, water and milk bottles Mason jarsMason jars Ziploc bags sold for food storageZiploc bags sold for food storage

Allowed Service ContainersAllowed Service Containers

Those designed for pesticide storage.Those designed for pesticide storage. Zip lock type bags not labeled for Zip lock type bags not labeled for

food storage.food storage. Other containers not sold as food Other containers not sold as food

storagestorage Nalgene jarsNalgene jars Screw top test tubesScrew top test tubes

Available at Craft StoresAvailable at Craft Stores

Transportation Transportation RequirementsRequirements

Pesticides shall not be transported in Pesticides shall not be transported in the same compartment with persons, the same compartment with persons, food, or feed.food, or feed.

Containers shall be secured to Containers shall be secured to vehicles during transportation in a vehicles during transportation in a way that will prevent spillage. way that will prevent spillage. Paper, cardboard, and similar Paper, cardboard, and similar containers shall be covered when containers shall be covered when necessary to protect them from necessary to protect them from moisture.moisture.

MSDSMSDS

Is the MSDS required to be in the Is the MSDS required to be in the vehicle when transporting pesticides vehicle when transporting pesticides from a warehouse to the storage area? from a warehouse to the storage area? No. Only the labels are required.No. Only the labels are required. If an employee wants to review the MSDS, If an employee wants to review the MSDS,

it must be available.it must be available. MSDSs must be available at a central MSDSs must be available at a central

location.location.

MSDS in VehicleMSDS in Vehicle

Are MSDSs required to be in the Are MSDSs required to be in the vehicle when transporting pesticides vehicle when transporting pesticides to the application site?to the application site? No. Unless the product is not registered No. Unless the product is not registered

and lacks a label, then the MSDS may and lacks a label, then the MSDS may being used in lieu of a label.being used in lieu of a label.

Container Rinsing Container Rinsing RequirementsRequirements

Each emptied container that has held less Each emptied container that has held less than 28 gallons of a liquid pesticide diluted than 28 gallons of a liquid pesticide diluted for use shall be rinsed by the user at the for use shall be rinsed by the user at the time of use by the triple-rinse method or time of use by the triple-rinse method or another rinse method approved by DPR.another rinse method approved by DPR. For containers less than 5 gallons, each rinse For containers less than 5 gallons, each rinse

shall be at least ¼ of volume.shall be at least ¼ of volume. For containers 5 gallons and For containers 5 gallons and

larger, each rinse shall be at least larger, each rinse shall be at least 1/5 of volume.1/5 of volume.

Pesticide DisposalPesticide Disposal

All undiluted, excess pesticides will All undiluted, excess pesticides will be disposed of in accordance with be disposed of in accordance with State and Federal laws and State and Federal laws and regulations, or in accordance with regulations, or in accordance with the requirements stated on the label.the requirements stated on the label.

Getting Rid of Surplus Getting Rid of Surplus PesticidesPesticides

Dilute mixes and rinsates should be Dilute mixes and rinsates should be applied to application siteapplied to application site

Concentrates in original containersConcentrates in original containers Return to registrant/manufacturer, if Return to registrant/manufacturer, if

willing to acceptwilling to accept Give registered products to Give registered products to

cooperator, if s/he can legally usecooperator, if s/he can legally use Dispose of as hazardous wasteDispose of as hazardous waste

Closed Pesticide Transfer Closed Pesticide Transfer SystemSystem

Must be used when required by State Must be used when required by State regulation.regulation.

If handling over one gallon of pesticides in If handling over one gallon of pesticides in toxicity Category I, a closed system must be toxicity Category I, a closed system must be used to transfer, mix, or load in accordance used to transfer, mix, or load in accordance with 3 CCR, Section 6746, Closed Systems.with 3 CCR, Section 6746, Closed Systems.

Does not apply if employees handle one Does not apply if employees handle one gallon or less of such pesticides per day in gallon or less of such pesticides per day in the original container.the original container.

Unregistered PesticidesUnregistered Pesticides

All experimental and unregistered All experimental and unregistered pesticide chemicals shall be stored pesticide chemicals shall be stored and transported in labeled containers and transported in labeled containers of a type appropriate to assure of a type appropriate to assure safety in handling.safety in handling.

Respiratory Protection -Respiratory Protection -EmployerEmployer Responsibilities Responsibilities

Provide a written Respiratory Protection Program (see Provide a written Respiratory Protection Program (see Administrative Guidelines at http://safety.ucanr.org/guidelines/). Administrative Guidelines at http://safety.ucanr.org/guidelines/).

Provide a medical evaluation when required. Provide a medical evaluation when required. Initial evaluation is required prior to use. Regulations only require when Initial evaluation is required prior to use. Regulations only require when

medical professional requires. UCD policy is annually. medical professional requires. UCD policy is annually. Conduct initial and annual required respirator fit testing. Conduct initial and annual required respirator fit testing. Provide respirators, replacement parts, cartridges and filters. Provide respirators, replacement parts, cartridges and filters. Conduct initial and annual required respiratory protection Conduct initial and annual required respiratory protection

training. training. Provide a means to clean and store respirators. Provide a means to clean and store respirators. Maintain employee training, medical and exposure records. Maintain employee training, medical and exposure records. Provide labels, Material Safety Data Sheets (MSDS) and any Provide labels, Material Safety Data Sheets (MSDS) and any

other related information to assist with respirator, cartridge and other related information to assist with respirator, cartridge and filter selection. filter selection.

Provide medical service if required. Provide medical service if required.

Respiratory Protection -Respiratory Protection -EmployeeEmployee Responsibilities Responsibilities

Be familiar and understand the written Respiratory Be familiar and understand the written Respiratory Protection Program. Protection Program.

To be clean shaven before using a respirator (UC Policy). To be clean shaven before using a respirator (UC Policy). Inspect the respirator before and after each use. Inspect the respirator before and after each use. Perform a positive and negative fit check prior to using the Perform a positive and negative fit check prior to using the

respirator. respirator. Replace the cartridges and filters when necessary or Replace the cartridges and filters when necessary or

required. required. Care, maintenance and storage of the respirator, cartridges Care, maintenance and storage of the respirator, cartridges

and filters. and filters. To know which cartridge(s) and filter(s) to use for the To know which cartridge(s) and filter(s) to use for the

hazard. hazard. To wear the respirator where it is required. To wear the respirator where it is required. To notify the employer if suspected of being exposed to a To notify the employer if suspected of being exposed to a

hazardous substance. hazardous substance.

Respiratory ProtectionRespiratory Protection

Cartridge change-out requirements Cartridge change-out requirements are complicated!are complicated!

You must do a fit test annually as per You must do a fit test annually as per California Code of Regulations (CCR California Code of Regulations (CCR 6739).6739).

Contact Brian Oatman for scheduling Contact Brian Oatman for scheduling annual fit testing.annual fit testing.

Buffer ZonesBuffer Zones

Must be adhered toMust be adhered to LabeledLabeled RegulationRegulation

Waivers for small plots or small Waivers for small plots or small amounts of fumigants are possibleamounts of fumigants are possible Must obtain approval from local CACMust obtain approval from local CAC

Fumigation RequirementsFumigation Requirements UC employees are not completely exempt from fumigation UC employees are not completely exempt from fumigation

requirementsrequirements TrainingTraining PPEPPE Buffer zonesBuffer zones Other label and regulation requirementsOther label and regulation requirements

QAL/QAC category QAL/QAC category ““Research & DemonstrationResearch & Demonstration”” does cover does cover fumigation. Category fumigation. Category ““OO ”” is not needed is not needed

A Fumigation Management Plan is NOT requiredA Fumigation Management Plan is NOT required For training materials: For training materials:

http://www.epa.gov/oppsrrd1/reregistration/soil_fumigants/http://www.epa.gov/oppsrrd1/reregistration/soil_fumigants/

RecommendationsRecommendations Recommendation means the Recommendation means the

giving of any instruction or advice giving of any instruction or advice on any agricultural use as to any on any agricultural use as to any particular application on any particular application on any particular piece of property.particular piece of property.

A person making a written A person making a written recommendation does not incur recommendation does not incur an obligation to ensure that the an obligation to ensure that the actual use follows his or her actual use follows his or her recommendation.recommendation.

UC Recommendation UC Recommendation RequirementsRequirements

A written recommendation is A written recommendation is required when UC personnel are required when UC personnel are engaged in official duties relating to engaged in official duties relating to agricultural use of pesticides and agricultural use of pesticides and when they give any instruction or when they give any instruction or advice on a particular application on advice on a particular application on a particular piece of property.a particular piece of property.

Pesticide RecommendationsPesticide Recommendations

Pesticide use recommendations shall Pesticide use recommendations shall conform to usage prescribed by labels conform to usage prescribed by labels registered by the USEPA and DPRregistered by the USEPA and DPR

Recommendations must be in writingRecommendations must be in writing Written recommendations should Written recommendations should

identify pesticides by official common identify pesticides by official common name; when necessary, brand names name; when necessary, brand names maymaybe used (UC/DPR agreement).be used (UC/DPR agreement).

Published or Published or Presented ResultsPresented Results

Published or otherwise presented results, Published or otherwise presented results, descriptions and demonstrations of descriptions and demonstrations of experiments in which pesticides are used in experiments in which pesticides are used in a manner that does not conform with a manner that does not conform with registered uses shall be clearly identified as registered uses shall be clearly identified as experimental results only. Where experimental results only. Where appropriate, a warning shall be included appropriate, a warning shall be included that similar uses may result in that similar uses may result in contaminated crops with illegal pesticide contaminated crops with illegal pesticide residues.residues.

Newsletters, Other Newsletters, Other Publications & PresentationsPublications & Presentations You must ensure that any published You must ensure that any published

statements in newsletters, bulletins, statements in newsletters, bulletins, other written material or other written material or presentations regarding pesticide presentations regarding pesticide use are legal. If in doubt, contact the use are legal. If in doubt, contact the UC Statewide Pesticide Coordinator.UC Statewide Pesticide Coordinator.

Organic Research IssuesOrganic Research Issues

Always verify with grower that material(s) Always verify with grower that material(s) to be used in research plot are compliant to be used in research plot are compliant with the National Organic Program (NOP) with the National Organic Program (NOP) andand their certifier. their certifier.

Best not to make written recommendations Best not to make written recommendations for organic plots, unless you are absolutely for organic plots, unless you are absolutely certain that the material is compliant.certain that the material is compliant.

Even exempt materials must be NOP Even exempt materials must be NOP compliant and approved by the certifier.compliant and approved by the certifier.

Any material must be a part of the growerAny material must be a part of the grower’’s s approved organic farm plan - approved organic farm plan - before usingbefore using..

Chemicals Exempt Chemicals Exempt from Registrationfrom Registration

Castor oilCastor oil Cedar oilCedar oil Cinnamon & Cinnamon oilCinnamon & Cinnamon oil Citric acidCitric acid Citronella & Citronella oilCitronella & Citronella oil Cloves & clove oilCloves & clove oil Corn gluten mealCorn gluten meal Corn oilCorn oil Cottonseed oilCottonseed oil Dried BloodDried Blood EugenolEugenol Garlic & garlic oilGarlic & garlic oil GeraniolGeraniol Geranium oilGeranium oil Lauryl sulfateLauryl sulfate Lemongrass oilLemongrass oil

Linseed oilLinseed oil Malic acidMalic acid Mint & mint oilMint & mint oil Peppermint & peppermint oilPeppermint & peppermint oil 2-Phenethyl propionate2-Phenethyl propionate Potassium sorbatePotassium sorbate Putrescent whole egg solidsPutrescent whole egg solids Rosemary & rosemary oilRosemary & rosemary oil Sesame & sesame oilSesame & sesame oil Sodium chlorideSodium chloride Sodium lauryl sulfateSodium lauryl sulfate Soybean oilSoybean oil Thyme & thyme oilThyme & thyme oil White pepperWhite pepper Zinc metal stripsZinc metal strips

Note: A tolerance or exemption from tolerance is still required. Many of the above do not have either.

Lisa BleckerLisa Blecker530-752-3912530-752-3912

[email protected]

http://www.ucanr.org/opichttp://www.ucanr.org/opic

http://www.ipm.ucdavis.edu/http://www.ipm.ucdavis.edu/