Submission of Inspections – Revision to ENF 2009-24

This letter announces changes to the submission of inspections to the Department of Pesticide Regulation (DPR) and the reporting of inspections and noncompliances on the Pesticide Regulatory Activities Monthly Report (PRAMR) effective September 1, 2010. Revised PRAMR instructions reflecting these changes are enclosed for your reference.

Background

Prior to January 1, 2010, county agricultural commissioners (CACs) submitted only complete inspections. They reported the total number of complete inspections and the total number of noncompliances for all inspections on the monthly PRAMR form. It was difficult to reconcile the numbers reported on PRAMR with the number of inspections and noncompliances in the inspection tracking database.

CAC Letter ENF 2009-24 requested that effective January 1, 2010, CACs discontinue reporting the total number of inspections and total number of noncompliances on their PRAMR, and submit additional types of inspections for entry into the inspection tracking database. The new process was intended to allow a more accurate count of the number of inspections and the noncompliances. Unfortunately, DPR is unable to enter all inspection data at this time and it is necessary to revise portions of the inspection submission procedures and PRAMR instructions.

Revised Instructions for Submitting Inspections – effective September 1, 2010

1. Resume reporting the total number of complete inspections only, including follow-up inspections where all criteria have been completed, on your PRAMR report.
2. Resume reporting the total number of noncompliances for all inspections on your PRAMR including complete, follow-ups, partials, unattended tarp/aeration, and other (rice holding and other governmental) inspections.
3. Resume submitting only complete inspections.
4. Discontinue submitting the following inspections: unattended tarp/aerations (PR-ENF- 107), Pesticide Pre-Application Site Evaluations (PR-ENF-102), partials/follow-ups, and others.
5. If submitting inspections electronically, please submit only complete inspections as indicated above.

Please see the enclosed PRAMR instructions (revised September 2010) for more details on reporting and submission of inspections.

Reconciliation of Inspections Submitted January 1, 2010 through August 30, 2010

The Mill disbursement will be based on the PRAMR. For the inspection types listed in item 4 above, DPR Enforcement Branch staff will reconcile the CAC inspection and noncompliance totals with the inspections entered into the inspection tracking database. DPR will update the PRAMR inspection data and, through the usual process, counties will be asked to review the information.

We apologize for this inconvenience and will continue working toward a streamlined and efficient method of data entry and reporting. The workload associated with the types of inspections, laws and regulations, the criteria that must be met to complete an inspection, and an average of 20,000 inspections per year is extensive. We appreciate your work and thank you for your patience.

If you have questions, please contact Mr. Scott Benson at 916-322-7269 or Ms. Mary Ann Coleman at 916-445-3892, or your Enforcement Branch Liaison

Sincerely,