Proposed “Revised” Inspection Forms and Procedures Manual Pilot Project

The “Train-the-Trainer” program for Pesticide Use Enforcement Deputy Agricultural Commissioners of the 12 counties participating in the Inspection Forms/Procedures Pilot Project was conducted on July 17, 2002. (See Enforcement Letter 02-27).

Attendees were given a “working draft” of the Revised Inspection Procedures Manual with appendices (approximately 200 pages) and a set of the “draft” Revised Inspection Forms, including the Pesticide Regulatory Activities Monthly Report (Report 5). These have all been included on the CD-ROM attached to this Enforcement Letter for your review.

Several key items were highlighted and discussed during the training program. These are:

1. The inclusion of 6702(b) and 6702(c) “Employer-Employee Responsibilities” on the various “Use Monitoring Inspection” forms.
2. The inclusion of 6702(b)(5) “Written Workplace Disciplinary Policy” on the two Pest Control Records Inspection forms.
3. The inclusion of 6761.1 “Application-Specific Information” on the Fieldworker Safety Inspection (failure to address that item would result in an “incomplete” inspection; only hours could be recorded on Report 5).
4. The adoption of several worker protection items in the General Procedures (required to comply with the Federal Worker Protection Standard), such as interviewing supervisor and handlers/fieldworkers, asking handlers/fieldworkers about retaliation, refusals, and exposure incidents.
5. Adoption of DPR policy that all inspections must be signed by a representative of the firm/person inspected to be recorded on Report 5.
6. Stricter guidelines on targeting inspections.

Please submit your comments or questions regarding the Inspection Procedures Manual to your Senior Pesticide Use Specialist by October 18, 2002. Direct any comments or questions regarding the various inspection forms to Ms. Kathleen Boyle, of my staff, at (916) 445-3909 by October 18, 2002. Comments will be addressed during a presentation about the various inspection forms and procedures manual by Department of Pesticide Regulation staff to the Pesticide Regulatory Affairs Committee during the California Agricultural Commissioners and Sealers Association Winter Conference, November 4-8, 2002. Changes to forms/procedures will be considered at that time.

Sincerely,