Department of Pesticide Regulation logo
Brian R. Leahy
Director
California State Seal
Edmund G. Brown Jr.
Governor
09/20/2017
PML 17-03
ENF 17-22
To: County Agricultural Commissioners

Site Code Changes in Pesticide Use Reporting for Cannabis

Background

The Department of Pesticide Regulation (DPR) has determined that cannabis meets the definition of an “agricultural commodity” in 3 CCR § 6000. Therefore, requirements for the production of an agricultural commodity listed in Divisions 6 and 7 of the Food and Agricultural Code and its implementing regulations, including those related to pesticide use reporting, apply to cannabis. One significant impact of this determination on pesticide use reporting is that cannabis growers will be subject to reporting requirements under 3 CCR § 6626-as opposed to 3 CCR § 6627.

Pesticide Use Reporting Changing

SITE CODE

To facilitate pesticide use reporting, DPR will be making the following changes to site codes related to cannabis:

  • Delete Site code 21003: HEMP (Fiber Crop)
  • Delete Site Code 70 : MARIJUANA
  • Modify Site Code 26010: from MARIJUANA/HEMP to HEMP/CANNABIS

Site Code 26010 will be the only site code for reporting pesticide use on cannabis. This site code applies all types of cannabis including marijuana and hemp.

All previously submitted Pesticide Use Reports that used either site codes 21003 (Hemp (Fiber Crop)) or 70 (Marijuana) will be automatically changed to site code 26010 (Hemp/Cannabis) in the PUR database and CalAgPermits.

Counties will need to add site code 26010 to their active commodities list if they previously used site codes 70 or 21003.

FORMS

With the determination that cannabis is a production agricultural commodity, pesticide use must be reported on these forms:

  • DPR-PML-025: Pesticide Use Report
  • DPR-PML-017c: Production Agriculture Monthly Pesticide Use Report
  • DPR-PML-183: Production Agriculture Monthly Pesticide Use Report: Multiple Site Commodity

The Monthly Summary Pesticide Use Report Form, DPR-PML-060, will be revised to remove Code 70 marijuana from the site code list in the instructions. Pesticide use on cannabis should not be reported on DPR-PML-060. Hard copies of the revised DPR-PML-060 forms will be sent to the counties as soon as they are available. An electronic copy of the revised form will also be available at www.cdpr.ca.gov/docs/pur/forms/purforms.htm. Once you’ve received the revised DPR-PML-060 forms, please discontinue using, and discard/ recycle the old forms.

Additional Information

For Enforcement Letter 17-03, Preliminary Guidance on County Pesticide Enforcement Related to Commercial Cannabis Cultivation and Cannabis defined as an Agricultural Commodity, please visit www.cdpr.ca.gov/docs/county/cacltrs/penfltrs/penf2017/2017003.htm.

For Pesticide Use Reporting forms, please visit www.cdpr.ca.gov/docs/pur/forms/purforms.htm

Sincerely,

Original signature by:
Donna Marciano
Chief, Enforcement Branch
916-324-4100
Joseph Damiano
Chief, Pest Management and Licensing Branch
(916) 324-4265
CC:
George Farnsworth, Assistant Director, Pesticide Programs Division
Mr. Joe Marade, DPR Agricultural Commissioner Liaison
Ann Pritchard, Branch Chief, Registration Branch
Donna Marciano, Branch Chief, Enforcement Branch
John Gless, CACASA Project Manager
Michael Wanser, Data Processing Manager III, Information Technology Branch
Rachel Kubiak, Senior Environmental Scientist, Cannabis Program
S.Yanga, Environmental Program Manager I, Pest Management and Licensing Branch
Kimberly Steinmann, Research Scientist II, Pest Management and Licensing Branch