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

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Presentation on theme: "UC DANR Pesticide Use and Experimentation Lisa Blecker, Statewide Pesticide Coordinator Office of Pesticide Information and Coordination (OPIC) 530-752-3912."— Presentation transcript:

1 UC DANR Pesticide Use and Experimentation Lisa Blecker, Statewide Pesticide Coordinator Office of Pesticide Information and Coordination (OPIC) ucanr.org/opic

2 Rights and Responsibilities Research rights Research rights UC has a mandate to conduct UC has a mandate to conduct agricultural research. Researchers granted the right to Researchers granted the right to conduct hazardous chemical research on UC and cooperators’ property. Research responsibilities Research responsibilities To do no harm To do no harm To conduct intellectually honest research To conduct intellectually honest research

3 Pest Management Chemical Experiments Create Risks and Potential Liabilities Risks Risks To Cooperators To Cooperators To the Public To the Public To Consumers To Consumers To the University To the University Reputation Reputation Research Rights Research Rights Liabilities Liabilities Individual Researcher Individual Researcher County, DANR and UC County, DANR and UC

4 Policy on Pesticides and Related Chemicals: Use and Experimentation ANR Administrative Handbook Section 281 Applies to UC ANR Applies to UC ANR All research, published pest management guidelines and recommendations relating to pesticide use are to be conducted in accordance with all applicable laws and regulations and this policy. All research, published pest management guidelines and recommendations relating to pesticide use are to be conducted in accordance with all applicable laws and regulations and this policy.

5 Scope and Definitions Applies to all ANR employees who use or handle pesticides for experimental purposes Applies to all ANR employees who use or handle pesticides for experimental purposes Applies to experimentation with pesticides or related substances in any field test or field demonstration. Applies to experimentation with pesticides or related substances in any field test or field demonstration.

6 Where Does this Apply? On any Campus On any Campus On Field Stations On Field Stations On Agricultural Research and Extension Centers On Agricultural Research and Extension Centers On any other land or treated site (including livestock) when used in experimental pesticide research field trials and demonstration operations that are activities of the University On any other land or treated site (including livestock) when used in experimental pesticide research field trials and demonstration operations that are activities of the University Does not include greenhouses or laboratories Does not include greenhouses or laboratories

7 Pop Quiz UC Pesticide Policy Exempts you from which of the following : UC Pesticide Policy Exempts you from which of the following : PPE requirements PPE requirements Research Authorization Research Authorization Training pesticide handlers Training pesticide handlers Restricted Materials Permit Restricted Materials Permit Pesticide Use Reporting Pesticide Use Reporting Field posting Field posting

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

9 Definitions Pesticide: Pesticide: Any chemical or biotic agent used or intended for use for pest control. Any chemical or biotic agent used or intended for use for pest control. Pesticide includes any substance, or mixture of substances which is intended to be used for defoliating plants, regulating plant growth, or for preventing, destroying, repelling, or mitigating any pest which may infest or be detrimental to vegetation, humans, animals, or households, or be present in any agricultural or nonagricultural environment whatsoever. Pesticide includes any substance, or mixture of substances which is intended to be used for defoliating plants, regulating plant growth, or for preventing, destroying, repelling, or mitigating any pest which may infest or be detrimental to vegetation, humans, animals, or households, or be present in any agricultural or nonagricultural environment whatsoever. Any chemical or microbial agent that is being used with the intent of testing in any field test. Any chemical or microbial agent that is being used with the intent of testing in any field test.

10 Intent of Use A pesticide can be any substance used to control a pest whether or not it is registered as a pesticide. A pesticide can be any substance used to control a pest whether or not it is registered as a pesticide. If that substance is not labeled for the use or lacks an exemption it would be illegal to use it for pest control If that substance is not labeled for the use or lacks an exemption it would be illegal to use it for pest control Exceptions Exceptions Home remedies used by the homeowner Home remedies used by the homeowner for non-agricultural sites for non-agricultural sites Substances such as steam for weed control Substances such as steam for weed control

11 Some Materials that are Pesticides Disinfectants Disinfectants Clorox Clorox Chemicals to sterilize benches or countertops Chemicals to sterilize benches or countertops Algaecides Algaecides Animal repellents Animal repellents Pheromones Pheromones All must be registered and the All must be registered and the site listed for legal use

12 Definitions Experimental Pesticide: Experimental Pesticide: New formulations of existing products. New formulations of existing products. New products containing old active ingredients. New products containing old active ingredients. Applications to any crop or site not on the California- registered label Applications to any crop or site not on the California- registered label No California label exists No California label exists Use of any spray adjuvant not registered in California. Use of any spray adjuvant not registered in California. Use in conflict with the CA registered label. Use in conflict with the CA registered label.

13 Use 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). Use against pests not listed or Use against pests not listed or prohibited on the label. Increasing the concentration of the mixture, if published in a UC Pest Management Guideline Increasing the concentration of the mixture, if published in a UC Pest Management Guideline Cannot increase the amount of a.i. applied per acre Cannot increase the amount of a.i. applied per acre Providing all other label directions are followed. Providing all other label directions are followed.

14 Potential Groundwater Contaminating Chemicals Listed in 3 CCR Section 6800(a) Listed in 3 CCR Section 6800(a) May be applied by UC for research and experimental purposes only pursuant to a valid research authorization. The UC research exemption from the requirement for a Research Authorization does not apply when these potentially groundwater polluting chemicals are used for research and experimentation purposes. May be applied by UC for research and experimental purposes only pursuant to a valid research authorization. The UC research exemption from the requirement for a Research Authorization does not apply when these potentially groundwater polluting chemicals are used for research and experimentation purposes.

15 Experimental Pesticide Use Application is made for research purposes only. Application is made for research purposes only. No commercial pest control benefit is intended or expected. No commercial pest control benefit is intended or expected. Applications must conform to State and Federal guidelines. Applications must conform to State and Federal guidelines. Pesticide applications that are made solely for pest control purposes rather than research purposes cannot be experimental and must be made in accordance with CA registered labels and all applicable laws and regulations. Pesticide applications that are made solely for pest control purposes rather than research purposes cannot be experimental and must be made in accordance with CA registered labels and all applicable laws and regulations.

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

17 Exemption of UC from Obtaining Research Authorization Title 3, California Code of Regulations (CCR), Section 6268, Research Authorization Title 3, California Code of Regulations (CCR), Section 6268, Research Authorization University employees are exempt, providing UC has a policy covering experimental use. University employees are exempt, providing UC has a policy covering experimental use.

18 Microbial Pesticides The USEPA generally requires a notification or a Federal EUP for any experimental program involving the deliberate release into the environment of living, genetically engineered microbial pesticides, irrespective of the acreage involved. The USEPA generally requires a notification or a Federal EUP for any experimental program involving the deliberate release into the environment of living, genetically engineered microbial pesticides, irrespective of the acreage involved. The DPR Pesticide Registration Branch must also be notified of any proposed field testing (on or off UC property) by UC personnel involving genetically engineered microbial pesticides. The DPR Pesticide Registration Branch must also be notified of any proposed field testing (on or off UC property) by UC personnel involving genetically engineered microbial pesticides.

19 6800 (a) List Atrazine Atrazine Simazine Simazine Bromacil Bromacil Diuron Diuron Prometon Prometon Bentazon Bentazon Norflurazon Norflurazon See EH for list of areas affected:

20 Groundwater Protection Areas See map of Riverside County

21 Noncompliance Will result in the loss of the exemption provided under Title 3 CCR, Section Will result in the loss of the exemption provided under Title 3 CCR, Section May be deemed a violation of Section May be deemed a violation of Section Authorization for Research Authorization for Research

22 Restricted Materials Permit Required of UC employees when possessing, using, or applying Required of UC employees when possessing, using, or applying any restricted material for pest control purposes. No permit is required for restricted materials used only for experimental or research purposes, when possessed or used by or under the supervision of research personnel from UC. No permit is required for restricted materials used only for experimental or research purposes, when possessed or used by or under the supervision of research personnel from UC.

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

24 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 RMP Needed!!! 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 NO

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

26 What About County Employees? If working with or under the supervision of a UC employee, ensure that they are trained and wear appropriate safety equipment. If working with or under the supervision of a UC employee, ensure that they are trained and wear appropriate safety equipment.

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

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

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

30 Tolerance Tolerance is the maximum pesticide residue level that can legally remain on a commodity at the time of harvest, as defined in Title 40 Code of Federal Regulations, Part 180. Tolerance is the maximum pesticide residue level that can legally remain on a commodity at the time of harvest, as defined in Title 40 Code of Federal Regulations, Part 180.Title 40 Code of Federal Regulations, Part 180Title 40 Code of Federal Regulations, Part 180 Maximum Residue Levels (MRLs) are the international equivalent of tolerances Maximum Residue Levels (MRLs) are the international equivalent of tolerances US tolerances and MRLs may not be equivalent. US tolerances and MRLs may not be equivalent.

31 Responsibilities Incurred by Employees of UC Supervisor: Supervisor: Provide a safe work environment and Provide a safe work environment and provide training to persons working under their direction. Ensure that pesticides are used in accordance with State and Federal laws, regulations, and label requirements. Ensure that pesticides are used in accordance with State and Federal laws, regulations, and label requirements. Make employees aware of the hazards of the chemicals and pesticides being used for experimentation Make employees aware of the hazards of the chemicals and pesticides being used for experimentation Use the pesticide label as a guide to employee training. Use the pesticide label as a guide to employee training. In absence of a registered label, use the MSDS as guide to training and personal protective equipment requirements. In absence of a registered label, use the MSDS as guide to training and personal protective equipment requirements.

32 Training Must include information on pesticide hazards and safety prior to any handling of pesticides. Must include information on pesticide hazards and safety prior to any handling of pesticides. Laws and regulations applicable to all activities they may perform. Laws and regulations applicable to all activities they may perform.

33 Personal Safety Age. Persons under the age of 18 shall not mix, load, or apply pesticides Age. Persons under the age of 18 shall not mix, load, or apply pesticides Instruction and training. The supervisor shall provide training for each employee handling pesticides. This shall include: Instruction and training. The supervisor shall provide training for each employee handling pesticides. This shall include: Potential hazards involved for each pesticide Potential hazards involved for each pesticide Safety procedures to be followed Safety procedures to be followed Clothing and protective equipment Clothing and protective equipment Common symptoms of pesticide poisoning and ways poisoning can occur Common symptoms of pesticide poisoning and ways poisoning can occur Medical supervision requirements Medical supervision requirements Applicable laws, regulations and label requirements Applicable laws, regulations and label requirements

34 Pesticide Safety Training Requirements

35 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

36 Timing and record of instruction and training. Instruction shall be completed before the employee is allowed to handle pesticides and at least annually thereafter. The supervisor shall maintain a permanent record of the date and extent of instruction given. Timing and record of instruction and training. Instruction shall be completed before the employee is allowed to handle pesticides and at least annually thereafter. The supervisor shall maintain a permanent record of the date and extent of instruction given. Emergency medical care. The supervisor shall make prior arrangements for emergency medical care as required by 3 CCR Section Emergency medical care. The supervisor shall make prior arrangements for emergency medical care as required by 3 CCR Section Medical Supervision. The supervisor shall provide medical supervision in the form of a written agreement with a licensed physician for any employee who regularly handles any Category I or II pesticide containing an organophosphate or carbamate. This shall meet the requirements of 3 CCR Section Medical Supervision. The supervisor shall provide medical supervision in the form of a written agreement with a licensed physician for any employee who regularly handles any Category I or II pesticide containing an organophosphate or carbamate. This shall meet the requirements of 3 CCR Section 6728.

37 Regularly Handle Pesticides Applies only to cholinesterase inhibiting pesticides. Applies only to cholinesterase inhibiting pesticides. Employee handles pesticide any part of a day for more than 6 days in any 30 consecutive days. Employee handles pesticide any part of a day for more than 6 days in any 30 consecutive days. Excluding days where solely using closed mixing system or water soluble bags. Excluding days where solely using closed mixing system or water soluble bags.

38 Other General Requirements The supervisor shall meet the requirements of state regulations for: The supervisor shall meet the requirements of state regulations for: Working alone with pesticides (Category 1) Working alone with pesticides (Category 1) Contact every 2 hours by day, 1 hour at night Contact every 2 hours by day, 1 hour at night Clothing change area Clothing change area Mixing and loading site requirements Mixing and loading site requirements Work clothing Work clothing Protective equipment Protective equipment Adequate light Adequate light Servicing equipment Servicing equipment Equipment specifications Equipment specifications Availability of MSDSs Availability of MSDSs

39 Where do I Find Training Resources? ANR Environmental Health & Safety Web Site ANR Environmental Health & Safety Web Site Brian Oatman, R&E Centers Environmental Health & Safety Coordinator Brian Oatman, R&E Centers Environmental Health & Safety Coordinator (530) (530)

40 Information Available at ANR EH & S Web Site Ag Worker Protection Program Ag Worker Protection Program Confined Space Program Confined Space Program Disposal of Chemical Waste Disposal of Chemical Waste Employee Health & Safety Training Employee Health & Safety Training Experimental Use of Pesticides Experimental Use of Pesticides Emergency Eyewash & Shower Placement/Design Emergency Eyewash & Shower Placement/Design

41 Information Available at ANR EH & S Web Site (Cont.) Health & Safety Training Library Health & Safety Training Library Pesticide Use & Handling Pesticide Use & Handling Respiratory Protection Program Respiratory Protection Program Storage and Removal of Regulated Waste Storage and Removal of Regulated Waste

42 Environmental Health & Safety Notes – Agricultural Operations Pesticide Glove Use Pesticide Glove Use General Tractor Safety General Tractor Safety PTO Safety PTO Safety Pinch Point Hazards Pinch Point Hazards High-Pressure Washer Safety High-Pressure Washer Safety All-Terrain Vehicles All-Terrain Vehicles Flail Mower and Shredder Safety Flail Mower and Shredder Safety Shear and Cutting Point Hazards Shear and Cutting Point Hazards Fence Safety Fence Safety And Many More And Many More

43 Restricted Entry Interval Entry after Application Entry after Application No person shall enter any area treated with a pesticide unless he or she follows the labeling directions for entry activities. State restricted entry regulations (3 CCR Section 6772) may be more restrictive than those stated on the label. In all cases the most restrictive reentry regulations shall be followed. No person shall enter any area treated with a pesticide unless he or she follows the labeling directions for entry activities. State restricted entry regulations (3 CCR Section 6772) may be more restrictive than those stated on the label. In all cases the most restrictive reentry regulations shall be followed.

44 Pesticides with State Specific REIs (3 CCR Section 6772) Azinphos-methyl (Guthion) Azinphos-methyl (Guthion) Chlorpyrifos (Lorsban) Chlorpyrifos (Lorsban) Diazinon Diazinon Endosulfan (Thiodan) Endosulfan (Thiodan) Methidathion (Supracide) Methidathion (Supracide) Methomyl (Lannate) Methomyl (Lannate) Parathion-methyl (non-encapsulated) Parathion-methyl (non-encapsulated) Phorate (Thimet) Phorate (Thimet) Phosmet (Imidan) Phosmet (Imidan) Propargite (Omite/Comite) Propargite (Omite/Comite) Sulfur (not specific to formulation) Sulfur (not specific to formulation)

45 CROPSOTHER CROPS PESTICIDEAPPLESCITRUSCORNGRAPESPEACHES/ NECTARINES Azinphos- methyl 14(B) (B)14(A)(B) Chlorpyriphos 2 Diazinon 5 55 Endosulfan Malathion 1 11 Methidathion 30 Methomyl 7(C) Parathion- methyl (non- encapsulated) 1414(D) 14(E)2114(D) Phorate (Thimet) 7 Phosmet (Imidan) 55 Propargite (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 REIs

46 In Absence of Labeling Do not enter treated areas for 4 hours after application unless protected. After 4 hours, anyone entering the area must wear shoes and socks, a long sleeved shirt, and long pants. Do not enter treated areas for 4 hours after application unless protected. After 4 hours, anyone entering the area must wear shoes and socks, a long sleeved shirt, and long pants. Non-Ag and Urban areas: Persons shall not enter areas treated with liquid formulations for 2 hours and until the treated area has dried. When using baits, dusts and other dry formulations, persons should not enter the area during the application. Non-Ag and Urban areas: Persons shall not enter areas treated with liquid formulations for 2 hours and until the treated area has dried. When using baits, dusts and other dry formulations, persons should not enter the area during the application. Standard industry care and practice Standard industry care and practice should be observed.

47 When do I post a Restricted Entry Interval (REI) sign? Whenever the label requires posting (Federal regulation) Whenever the label requires posting (Federal regulation) If REI is greater than 7 days (CA regulation) If REI is greater than 7 days (CA regulation) If REI is posted in 3 CCR Section 6772 If REI is posted in 3 CCR Section 6772

48 Posting Treated Plots Post in accordance with any applicable pesticide label or regulation. Post in accordance with any applicable pesticide label or regulation. For non-ag and urban areas, notify the owners or residents of the treated property with information indicating the nature of the treatment, time and date of treatment, and any special instructions regarding restricted entry or use after treatment For non-ag and urban areas, notify the owners or residents of the treated property with information indicating the nature of the treatment, time and date of treatment, and any special instructions regarding restricted entry or use after treatment In plots treated with materials requiring restricted entry intervals under 3 CCR Section 6772, reentry intervals must be posted. In plots treated with materials requiring restricted entry intervals under 3 CCR Section 6772, reentry intervals must be posted.

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50 Posting Issues Verify with property owner and/or PCO that a REI is not in effect. Verify with property owner and/or PCO that a REI is not in effect. Double-check any entry points for REI warning sign. Double-check any entry points for REI warning sign. Immediately follow-up on any illness complaints after employees work in a grower’s field/orchard. Immediately follow-up on any illness complaints after employees work in a grower’s field/orchard. Remove posting signs within 3 days of REI expiration. Remove posting signs within 3 days of REI expiration.

51 Personal Protective Equipment (PPE) for Unregistered Pesticides If equivalent to Category I for eye or skin damage: If equivalent to Category I for eye or skin damage: Coveralls over long-sleeved shirt Coveralls over long-sleeved shirt Long pants Long pants Chemical-resistant gloves Chemical-resistant gloves Chemical-resistant footwear plus socks Chemical-resistant footwear plus socks Protective eyewear Protective eyewear Chemical resistant headgear for overhead exposure Chemical resistant headgear for overhead exposure Chemical-resistant apron when cleaning equipment, mixing or loading Chemical-resistant apron when cleaning equipment, mixing or loading

52 Personal Protective Equipment (PPE) for Unregistered Pesticides If equivalent to Category I for systemic toxicity: If equivalent to Category I for systemic toxicity: Long-sleeved shirt Long-sleeved shirt Long pants Long pants Chemical-resistant gloves Chemical-resistant gloves Shoes plus socks Shoes plus socks Protective eyewear (face shield for mixers and loaders) Protective eyewear (face shield for mixers and loaders) Chemical-resistant apron when mixing or loading Chemical-resistant apron when mixing or loading Respirator, where required by label Respirator, where required by label

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

54 Environmental Considerations in Determining Plot Locations The supervisor shall consider the potential consequences of any proposed experimental use of pesticides, paying particular attention to proximity to: The supervisor shall consider the potential consequences of any proposed experimental use of pesticides, paying particular attention to proximity to: Areas of frequent human activity or habitation (especially schools) Areas of frequent human activity or habitation (especially schools) Bodies of sources of water Bodies of sources of water Wildlife management areas Wildlife management areas Critical habitats of rare or endangered species Critical habitats of rare or endangered species Livestock and crops Livestock and crops All research applications will be made in a way that minimizes adverse environmental impacts. All research applications will be made in a way that minimizes adverse environmental impacts.

55 Pesticide Use Record Keeping and Reporting Supervisor shall keep a record for each application: Supervisor shall keep a record for each application: Location of site Location of site Plot size and total area treated Plot size and total area treated Each commodity, crop, or site treated Each commodity, crop, or site treated Pest species of concern Pest species of concern Date of application Date of application Application method Application method Concentration and volume of pesticide applied Concentration and volume of pesticide applied Date commodity was destroyed (when required) Date commodity was destroyed (when required) Name of grower, where applicable Name of grower, where applicable

56 Records Retention Retained by supervisor, the supervisor’s campus departmental office, or the appropriate county CE office. Retained by supervisor, the supervisor’s campus departmental office, or the appropriate county CE office. For at least 2 years after the final pesticide application. For at least 2 years after the final pesticide application. Records shall be made available upon request to the county agricultural commissioner or DPR. Records shall be made available upon request to the county agricultural commissioner or DPR. Note: Policy makes records public: requires they be available on request by agency. Note: Policy makes records public: requires they be available on request by agency.

57 Crop Control, Disposition, and Destruct Notification Requirements Commodities treated with any experimental pesticide for which there is no pesticide residue tolerance or tolerance exemption cannot enter the channels of trade or in any way be made available for use as a human or animal food or feed. Commodities treated with any experimental pesticide for which there is no pesticide residue tolerance or tolerance exemption cannot enter the channels of trade or in any way be made available for use as a human or animal food or feed. Supervisor has primary responsibility to ensure that the treated commodity is posted and destroyed. Supervisor has primary responsibility to ensure that the treated commodity is posted and destroyed.

58 Destroyed Destroyed means rendered unfit for utilization as human or animal feed. Destroyed means rendered unfit for utilization as human or animal feed. Photo: Dan Marcum

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

60 Posting Requirements Prior to application, a sign shall be posted at each corner of the experimental plot with the words, “Commodity treated with experimental pesticide, do not harvest.” The signs shall be in English and Spanish, and of a size so the wording is readable to a person with normal vision, from a distance of 25 feet. Signs will remain in place until treated crop is destroyed. Prior to application, a sign shall be posted at each corner of the experimental plot with the words, “Commodity treated with experimental pesticide, do not harvest.” The signs shall be in English and Spanish, and of a size so the wording is readable to a person with normal vision, from a distance of 25 feet. Signs will remain in place until treated crop is destroyed. Photo: Bennie Fouche

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62 Requirements for Trials Conducted off UC Property At least 24 hours prior to commencement of any experimental pesticide trial on property not owned or controlled by the UC, the supervisor shall submit to the county agricultural commissioner and grower a copy of a document that shall include the information on the following slide. At least 24 hours prior to commencement of any experimental pesticide trial on property not owned or controlled by the UC, the supervisor shall submit to the county agricultural commissioner and grower a copy of a document that shall include the information on the following slide. This serves as the equivalent of a Notice of Intent (NOI) This serves as the equivalent of a Notice of Intent (NOI)

63 Supervisor name, address, phone number and date of report Supervisor name, address, phone number and date of report Qualified Applicator Certificate Number Qualified Applicator Certificate Number Experimental pesticide to be applied and USEPA Registration number. If USEPA number is not available, use the chemical name or experimental number from the MSDS Experimental pesticide to be applied and USEPA Registration number. If USEPA number is not available, use the chemical name or experimental number from the MSDS Location of experimental trial (grower or ranch name, address and site ID number) Location of experimental trial (grower or ranch name, address and site ID number) Size of trial (acres or rows) Size of trial (acres or rows) Commodity or site to be treated Commodity or site to be treated Anticipated date of first and last applications Anticipated date of first and last applications Intended disposition of treated crop (harvest or destruction) Intended disposition of treated crop (harvest or destruction) Date of anticipated harvest or destruction of commodity Date of anticipated harvest or destruction of commodity Signature of supervisor responsible Signature of supervisor responsible

64 APPENDIX I PESTICIDE 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 by the 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 di sposition is necessary Date of anticipated harvest or destruction of treated commodity:_________________________________ Signature of Supervisor of Research Trial ______________________________ DATE______________

65 Reporting Crop Destruct Some CACs require a 24 hour notice of crop destruct for trials off UC property. Some CACs require a 24 hour notice of crop destruct for trials off UC property. Best to check with CAC when submitting Appendix I to determine if they want a crop destruct notice, too. Best to check with CAC when submitting Appendix I to determine if they want a crop destruct notice, too. It is helpful to submit a detailed map of the crop destruct site. It is helpful to submit a detailed map of the crop destruct site.

66 Pesticide Use Reporting Requirements Must report pesticide use on or off UC property Must report pesticide use on or off UC property On UC Property: Either directly as the person responsible or through other means such as a monthly summary of the REC On UC Property: Either directly as the person responsible or through other means such as a monthly summary of the REC Off UC Property: Provide information to operator of property for his monthly summary report Off UC Property: Provide information to operator of property for his monthly summary report Must be reported within 7 days for restricted materials or 30 days for other materials Must be reported within 7 days for restricted materials or 30 days for other materials Some CACs may request other forms for reporting such as DPRs RA reporting form Some CACs may request other forms for reporting such as DPRs RA reporting form

67 ENF DPR issued an enforcement letter to CACs clarifying crop destruct requirements, particularly as they relate to UC research. DPR issued an enforcement letter to CACs clarifying crop destruct requirements, particularly as they relate to UC research. rs/penfltrs/penf2007/ htm rs/penfltrs/penf2007/ htm rs/penfltrs/penf2007/ htm rs/penfltrs/penf2007/ htm

68 What Happens if Treated Commodity is Potentially Made Available for Human or Animal Consumption? Persons conducting the research shall IMMEDIATELY notify: Persons conducting the research shall IMMEDIATELY notify: CAC CAC Grower Grower DPR DPR UC ANR UC ANR Department Chair (CE Specialists and AES faculty) Department Chair (CE Specialists and AES faculty) County Director (Farm Advisors) County Director (Farm Advisors)

69 Violations of UC Crop Destruct Policy Experimental plots harvested and marketed Experimental plots harvested and marketed PeachesReliable source; no direct costs PeachesReliable source; no direct costs Kiwi Fruits Reliable source; no direct costs Kiwi Fruits Reliable source; no direct costs Pumpkins Documented; minor direct costs Pumpkins Documented; minor direct costs Cherries Documented; no direct costs Cherries Documented; no direct costs Tomatoes Documented; Quietly settled Tomatoes Documented; Quietly settled No known violations for over 11 years!!! No known violations for over 11 years!!!

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

71 Federally, but Not CA Registered Pesticides If product has federal registration and tolerance, may be used experimentally in CA without crop destruct. If product has federal registration and tolerance, may be used experimentally in CA without crop destruct.

72 Pesticides Applied above Label Rates Experimental applications may include those above the label rate Experimental applications may include those above the label rate The tolerance must not be exceeded at the time of harvest The tolerance must not be exceeded at the time of harvest Laboratory analysis may be required to assure the researcher and grower Laboratory analysis may be required to assure the researcher and grower The pesticide use report can be for the site or “research commodity” The pesticide use report can be for the site or “research commodity”

73 Qualifications of Persons Supervising Pesticide Applications Persons directly supervising pesticide applications shall hold the Qualified Applicator Certificate (QAC). Persons directly supervising pesticide applications shall hold the Qualified Applicator Certificate (QAC). It is recommended that employees whose responsibilities include applying pesticides be certified as a Qualified Applicator (QAC). It is recommended that employees whose responsibilities include applying pesticides be certified as a Qualified Applicator (QAC).

74 QAC License Categories Laws, Regulations and Basic Principles Laws, Regulations and Basic Principles Residential, Industrial and Institutional Residential, Industrial and Institutional Landscape Maintenance Landscape Maintenance Right-of-Way Right-of-Way Plant Agriculture Plant Agriculture Forest Forest Aquatic Aquatic Regulatory Regulatory Seed Treatment Seed Treatment Animal Agriculture Demonstration and Research Health Related Wood Preservative Antifouling Tributyltin Sewer Line Root Control Field Fumigation Microbial Pest Control Maintenance Gardener

75 Licensing and Certification Fees

76 Exam Schedule

77 Study Materials

78 Continuing Education for QAC/QAL Accumulate at least 20 hours of approved continuing education every 2 years before certificate renewal. Accumulate at least 20 hours of approved continuing education every 2 years before certificate renewal. A minimum of 4 of the 20 hours must cover the topic of pesticide laws and regulations A minimum of 4 of the 20 hours must cover the topic of pesticide laws and regulations

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81 The primary license location is Department of Pesticide Regulation Pesticide Enforcement Branch Licensing and Certification Program 1001 I Street Sacramento, CA Department of Pesticide Regulation Pesticide Enforcement Branch Licensing and Certification Program 1001 I Street Sacramento, CA Questions call (916) Questions call (916)

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

83 Storage and Delivery The supervisor is responsible for all containers or equipment on the work site that hold or have held a pesticide. The supervisor shall either: The supervisor is responsible for all containers or equipment on the work site that hold or have held a pesticide. The supervisor shall either: Store all containers or equipment in a locked enclosure, or Store all containers or equipment in a locked enclosure, or Provide a responsible person to maintain control over the containers at all times. Provide a responsible person to maintain control over the containers at all times.

84 Storage and Delivery When not being used, all pesticide containers (regardless of the amount of pesticide they contain) shall have lids and closures securely fastened. When not being used, all pesticide containers (regardless of the amount of pesticide they contain) shall have lids and closures securely fastened. Pesticides shall not be delivered to any property unless they are stored or controlled as required. Pesticides shall not be delivered to any property unless they are stored or controlled as required.

85 Posting of Pesticide Storage Areas All areas where pesticides or their used containers are stored shall be posted with warning signs as required by 3 CCR, Section 6674 in English and any other appropriate language. All areas where pesticides or their used containers are stored shall be posted with warning signs as required by 3 CCR, Section 6674 in English and any other appropriate language. For unregistered pesticides and related chemicals, the MSDS shall be used to determine the appropriate warning sign for posting. For unregistered pesticides and related chemicals, the MSDS shall be used to determine the appropriate warning sign for posting.

86 POISON STORAGE AREA ALL UNAUTHORIZED PERSONS KEEP OUT KEEP DOOR LOCKED WHEN NOT IN USE Pesticide Storage Area Sign

87 Container Label Requirements The manufacturer’s label shall not be removed from any pesticide container. The manufacturer’s label shall not be removed from any pesticide container.

88 Service Containers Service containers are those other than those bearing the registered pesticide label. Service containers are those other than those bearing the registered pesticide label. Regardless of size, shall be labeled with the following information: Regardless of size, shall be labeled with the following information: Signal word from the pesticide label, if available Signal word from the pesticide label, if available Name of pesticide Name of pesticide Name of manufacturer Name 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 responsible for the demonstration, application or research. Name, address, and telephone number of the person responsible for the demonstration, application or research. This includes backpack sprayers! This includes backpack sprayers!

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

90 Allowed Service Containers Those designed for pesticide storage. Those designed for pesticide storage. Zip lock type bags not labeled for food storage. Zip lock type bags not labeled for food storage. Other containers not sold as food storage Other containers not sold as food storage Nalgene jars Nalgene jars Screw top test tubes Screw top test tubes

91 Available at Craft Stores

92 Transportation Requirements Pesticides shall not be transported in the same compartment with persons, food, or feed. Pesticides shall not be transported in the same compartment with persons, food, or feed. Containers shall be secured to vehicles during transportation in a way that will prevent spillage. Paper, cardboard, and similar containers shall be covered when necessary to protect them from moisture. Containers shall be secured to vehicles during transportation in a way that will prevent spillage. Paper, cardboard, and similar containers shall be covered when necessary to protect them from moisture.

93 MSDS Is the MSDS required to be in the vehicle when transporting pesticides from a warehouse to the storage area? Is the MSDS required to be in the vehicle when transporting pesticides 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, it must be available. If an employee wants to review the MSDS, it must be available. MSDSs must be available at a central location. MSDSs must be available at a central location.

94 MSDS in Vehicle Are MSDSs required to be in the vehicle when transporting pesticides to the application site? Are MSDSs required to be in the vehicle when transporting pesticides to the application site? No. Unless the product is not registered and lacks a label, then the MSDS may being used in lieu of a label. No. Unless the product is not registered and lacks a label, then the MSDS may being used in lieu of a label.

95 Container Rinsing Requirements Each emptied container that has held less than 28 gallons of a liquid pesticide diluted for use shall be rinsed by the user at the time of use by the triple-rinse method or another rinse method approved by DPR. Each emptied container that has held less than 28 gallons of a liquid pesticide diluted for use shall be rinsed by the user at the time of use by the triple-rinse method or another rinse method approved by DPR. For containers less than 5 gallons, each rinse shall be at least ¼ of volume. For containers less than 5 gallons, each rinse shall be at least ¼ of volume. For containers 5 gallons and For containers 5 gallons and larger, each rinse shall be at least 1/5 of volume.

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

97 Getting Rid of Surplus Pesticides Dilute mixes and rinsates should be applied to application site Dilute mixes and rinsates should be applied to application site Concentrates in original containers Concentrates in original containers Return to registrant/manufacturer, if willing to accept Return to registrant/manufacturer, if willing to accept Give registered products to Give registered products to cooperator, if s/he can legally use Dispose of as hazardous waste Dispose of as hazardous waste

98 Closed Pesticide Transfer System Must be used when required by State regulation. Must be used when required by State regulation. If handling over one gallon of pesticides in toxicity Category I, a closed system must be used to transfer, mix, or load in accordance with 3 CCR, Section 6746, Closed Systems. If handling over one gallon of pesticides in toxicity Category I, a closed system must be used to transfer, mix, or load in accordance with 3 CCR, Section 6746, Closed Systems. Does not apply if employees handle one gallon or less of such pesticides per day in the original container. Does not apply if employees handle one gallon or less of such pesticides per day in the original container.

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

100 Respiratory Protection - Employer Responsibilities Provide a written Respiratory Protection Program (see Administrative Guidelines at Provide a written Respiratory Protection Program (see Administrative Guidelines at Provide a medical evaluation when required. Provide a medical evaluation when required. Initial evaluation is required prior to use. Regulations only require when medical professional requires. UCD policy is annually. Initial evaluation is required prior to use. Regulations only require when 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 training. Conduct initial and annual required respiratory protection 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 other related information to assist with respirator, cartridge and filter selection. Provide labels, Material Safety Data Sheets (MSDS) and any other related information to assist with respirator, cartridge and filter selection. Provide medical service if required. Provide medical service if required.

101 Respiratory Protection - Employee Responsibilities Be familiar and understand the written Respiratory Protection Program. Be familiar and understand the written Respiratory 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 respirator. Perform a positive and negative fit check prior to using the respirator. Replace the cartridges and filters when necessary or required. Replace the cartridges and filters when necessary or required. Care, maintenance and storage of the respirator, cartridges and filters. Care, maintenance and storage of the respirator, cartridges and filters. To know which cartridge(s) and filter(s) to use for the hazard. To know which cartridge(s) and filter(s) to use for the 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 hazardous substance. To notify the employer if suspected of being exposed to a hazardous substance.

102 Respiratory Protection Cartridge change-out requirements are complicated! Cartridge change-out requirements are complicated! You must do a fit test annually as per California Code of Regulations (CCR 6739). You must do a fit test annually as per California Code of Regulations (CCR 6739). Contact Brian Oatman for scheduling annual fit testing. Contact Brian Oatman for scheduling annual fit testing.

103 Buffer Zones Must be adhered to Must be adhered to Labeled Labeled Regulation Regulation Waivers for small plots or small amounts of fumigants are possible Waivers for small plots or small amounts of fumigants are possible Must obtain approval from local CAC Must obtain approval from local CAC

104 Fumigation Requirements UC employees are not completely exempt from fumigation requirements UC employees are not completely exempt from fumigation requirements Training Training PPE PPE Buffer zones Buffer zones Other label and regulation requirements Other label and regulation requirements QAL/QAC category “Research & Demonstration” does cover fumigation. Category “O” is not needed QAL/QAC category “Research & Demonstration” does cover fumigation. Category “O” is not needed A Fumigation Management Plan is NOT required A Fumigation Management Plan is NOT required For training materials: migants/ For training materials: migants/

105 Recommendations Recommendation means the Recommendation means the giving of any instruction or advice on any agricultural use as to any particular application on any particular piece of property. A person making a written recommendation does not incur an obligation to ensure that the actual use follows his or her recommendation. A person making a written recommendation does not incur an obligation to ensure that the actual use follows his or her recommendation.

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

107 Pesticide Recommendations Pesticide use recommendations shall conform to usage prescribed by labels registered by the USEPA and DPR Pesticide use recommendations shall conform to usage prescribed by labels registered by the USEPA and DPR Recommendations must be in writing Recommendations must be in writing Written recommendations should identify pesticides by official common name; when necessary, brand names may Written recommendations should identify pesticides by official common name; when necessary, brand names may be used (UC/DPR agreement).

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

109 Newsletters, Other Publications & Presentations You must ensure that any published statements in newsletters, bulletins, other written material or presentations regarding pesticide use are legal. If in doubt, contact the UC Statewide Pesticide Coordinator. You must ensure that any published statements in newsletters, bulletins, other written material or presentations regarding pesticide use are legal. If in doubt, contact the UC Statewide Pesticide Coordinator.

110 Organic Research Issues Always verify with grower that material(s) to be used in research plot are compliant with the National Organic Program (NOP) and their certifier. Always verify with grower that material(s) to be used in research plot are compliant with the National Organic Program (NOP) and their certifier. Best not to make written recommendations for organic plots, unless you are absolutely certain that the material is compliant. Best not to make written recommendations for organic plots, unless you are absolutely certain that the material is compliant. Even exempt materials must be NOP compliant and approved by the certifier. Even exempt materials must be NOP compliant and approved by the certifier. Any material must be a part of the grower’s approved organic farm plan - before using. Any material must be a part of the grower’s approved organic farm plan - before using.

111 Chemicals Exempt from Registration Castor oil Castor oil Cedar oil Cedar oil Cinnamon & Cinnamon oil Cinnamon & Cinnamon oil Citric acid Citric acid Citronella & Citronella oil Citronella & Citronella oil Cloves & clove oil Cloves & clove oil Corn gluten meal Corn gluten meal Corn oil Corn oil Cottonseed oil Cottonseed oil Dried Blood Dried Blood Eugenol Eugenol Garlic & garlic oil Garlic & garlic oil Geraniol Geraniol Geranium oil Geranium oil Lauryl sulfate Lauryl sulfate Lemongrass oil Lemongrass oil Linseed oil Linseed oil Malic acid Malic acid Mint & mint oil Mint & mint oil Peppermint & peppermint oil Peppermint & peppermint oil 2-Phenethyl propionate 2-Phenethyl propionate Potassium sorbate Potassium sorbate Putrescent whole egg solids Putrescent whole egg solids Rosemary & rosemary oil Rosemary & rosemary oil Sesame & sesame oil Sesame & sesame oil Sodium chloride Sodium chloride Sodium lauryl sulfate Sodium lauryl sulfate Soybean oil Soybean oil Thyme & thyme oil Thyme & thyme oil White pepper White pepper Zinc metal strips Zinc metal strips Note: A tolerance or exemption from tolerance is still required. Many of the above do not have either.

112 Lisa Blecker


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