Defining Target Area for Vector Control Activities

Vector control districts conduct area wide pest control projects to protect public health from vector borne diseases. These treatments are usually at a low dose and may be made as low volume or ultra low volume applications. To be efficient, these applications commonly utilize swath dispersion to obtain more uniform coverage within the target area.

As with many uses of pesticides, public concern sometimes arises about contamination of people and property. This letter provides guidance to County Agricultural Commissioners on issues related to the deposition of pesticides within the overall treatment zone of the project.

Title 3 of the California Code of Regulations (3CCR) Section 6620 specifically exempts any public agency or its contractor conducting vector control under a cooperative agreement with the Department of Public Health from certain regulatory requirements. Specifically, the consent and notice requirements of 3CCR Section 6616 and 6618 do not apply to these vector control pesticide applications. Section 6620 also specifically exempts these activities from the restriction of 3CCR Section 6614(b)(1) that prohibits applications that could create the reasonable possibility of exposing people (clothing or bodies) to pesticides, provided that the pesticide is registered for use in residential areas for vector control.

Title 3CCR Section 6614(b)(2) and (3) that prohibits contamination or damage to nontarget crops, animals and property still apply to vector control, but should have only very limited impact on such activities or their consequences. If the product is registered for use in residential areas for vector control, there would be no violation of these subsections resulting from pesticide falling anywhere within the boundaries of the area targeted for a vector control application. The vector control district or its contractor conducting the application may agree to take steps to minimize deposition on certain areas within the targeted treatment zone to address general public or specific property owner’s concern or to minimize potential liability for damage caused by the vector control district’s activities. However, deposition that occurs despite these efforts would not constitute a violation of 3CCR Section 6614.

If you have questions about the application of this interpretation of 3CCR Section 6614(b)(2) and (3) please contact the Enforcement Branch Liaison assigned to your county.

Sincerely,