Revised Pesticide Regulatory Activities Monthly Report Form Instructions

This letter announces the availability of and summarizes revisions to the Pesticide Regulatory Activities Monthly Report (PRAMR) instructions. The update is enclosed and also available online at www.cdpr.ca.gov/docs/enforce/report5.htm.

The Department of Pesticide Regulation (DPR) and the County Agricultural Commissioners (CACs) formed a data evaluation workgroup to assess county data DPR collects and analyzes, and to improve reporting consistency. The following recommendations were made regarding PRAMR, the inspection forms, and mill distribution based on the number of inspections by county:

1. Require the submission of all inspection forms beginning in January 2010 with the monthly PRAMR. This includes partial, follow-up, others (rice holding, etc.), and Branch 1 unattended tarp/aeration inspections. This coincides with the implementation of the newly revised inspection forms as discussed in ENF-2009-025.
   
   The only exception to this requirement to submit inspections is the Pesticide Pre-Application Site Evaluation inspections (PR-ENF-102, Rev. 01/10). At this time, DPR does not have the functionality to enter this inspection type, therefore counties do not need to submit these inspections with their monthly PRAMR.
   
   
2. All inspections will be entered into DPR’s inspection tracking system. All incomplete and/or illegible inspections will not be entered and will be returned to the counties. DPR will prepare and distribute a quarterly inspection report to assist the counties in reconciling their inspection numbers with DPR’s numbers.
3. In lieu of distributing a portion of the mill assessment based on the number of inspections reported on the PRAMR, the mill assessment will be distributed based on the number of inspections by county contained in DPR’s inspection tracking system.

The following highlights the changes that were made to implement the above recommendations, clarify the instructions, and remove overlap of reporting. In addition to the changes listed below, the formatting is more consistent and clear.

Reporting Changes for Inspections and Non-Compliances

With the exception of the Pesticide Pre-Application Site Evaluations (Form PR-ENF-102), the number of inspections and non-compliances are no longer required to be reported on the PRAMR. The data is captured in DPR’s inspection tracking system. Reporting these statistics is optional by the county.

Section I – Use Monitoring Inspections

• Application Method Box – Entering data in the application method box is not required since the information is no longer entered or reviewed by DPR. The information is captured on the inspection forms. This requirement was suspended in July 2004.
• Other (Identify in Remarks) – Now includes inspections conducted by CACs for Light Brown Apple Moth and other emergency project pesticide applications made by the California Department of Food and Agriculture or other government agencies. Document these inspections in the same manner as rice herbicide water holding inspections on page 2.

Section II – Structural Pest Control Inspections

Submit all Branch 1 structural inspections, including application, aeration, certification, unattended tarp/aeration, and those inspections conducted under the Structural Fumigation Enforcement Program. Attach all Branch 1 inspections to PRAMR.

Section IV – Restricted Materials

Expanded explanation of restricted material permits and examples provided for determining and reporting the number of multi-year permits.

Section VI – License/Certification/Registration/I.D. Number

• Clarification of the private applicator certification renewal requirements.
• The structural operator notice has been changed to structural operator registration.
• Examples provided for determining the number of multi-year site IDs in June.

Section X – Focused Activities

This was a pilot program that started in fiscal year 2000/2001 used to consolidate reporting for activities and hours related to documented focused activities. The program ended in 2005 and the information in this box is no longer required/reported.

Making Amendments to PRAMR

When submitting reports that need amending, write or type “Amended” on the top of the report. Highlight the areas you are correcting or revising.

Added Appendices:

• Appendix A: PRAMR, PR-ENF-099 (enclosed): This form has been converted to a fillable Adobe Acrobat PDF version. For data entry purposes, the Application Method Table and Focus Activity field have been removed. The form can be found on our website at www.cdpr.ca.gov/docs/enforce/prenffrm/prenfmnu.htm.
• Appendix B: Timeline for Submitting County Data for the California Statewide Pesticide Regulatory Activities Summary (Enclosed)

Please begin using these instructions and forms on January 1, 2010, and discard all prior year instructions and forms.

If you have any questions, please contact Ms. Mary Ann Coleman at 916-445-3892, Mr. Scott Benson at 916-324-4100, or your Enforcement Branch Liaison.

Sincerely,