UC Policy For Experimental Pesticide Use

Historically, University of California researchers have had an exemption from the requirement for obtaining a Research Authorization (RA) for experimental pesticide field trials provided they were working under an established policy governing pesticide use and experimentation (CCR 6268).

In the summer of 1998, the University relinquished this exemption for University field trials conducted off University property, thus requiring their researchers to obtain RAs for such trials. This action was prompted by a couple of incidents where crops were harvested when they should have been destroyed in UC field trials. The UC intent was to temporarily interrupt the exemption, allowing them time to review their policy and revise it as needed to insure proper field experimentation procedures were in place.

Over the past two-plus years, UC researchers conducting field trials off University property have been obtaining RAs for those trials. During that time, UC has revised, updated, and clarified their policy for better guidance and direction for field trials for their researchers conducting experimental pesticide applications.

The revisions to the UC Policy have now been finalized, and communicated to the Director and accepted by him. As a result, the University has re-established their exemption from the requirement to obtain RAs as described in CCR 6268. The policy has been nominally in effect since December 1, 2000, but functionally in effect since the latter part of January. While many of the revisions have to do with updating and clarification of wording, certain new features have been added.

1. Personal Protective Equipment (PPE) has been specified for unregistered pesticides where no label and thus no labeling directions would exist for PPE.
2. Field trials in which the treated crop must be destroyed must be posted as requiring crop destruction.
3. A notification form (attached to Policy) has been developed which will be used by researchers conducting experimental pesticide trials off university-controlled property. It will be submitted to the grower and to the agricultural commissioner’s office prior to the initiation of the trial. Among other information regarding the trial, the form also includes the intended final disposition of the treated crop, “to harvest” or “to destroy.”

The notification procedure will establish a closer liaison and communication between UC researchers working in the field and the respective commissioner’s offices. While there is no pre-approval involved with this notification form as there is with an RA, the intent is to provide notification to the commissioner’s office that a trial is taking place. This will allow you to monitor the crop destruct requirements as priorities allow. Should you have questions regarding the intended disposition of the crop, or other issues with the trial, you may contact Don Koehler in the Pesticide Registration Branch at (916) 324-3950.

The next step in this process will be a revision by DPR of the regulations (CCR 6260 et seq.) covering RAs to clarify the enforcement of the UC policy and RAs in general. Language concerning PPE, posting of field plots, and violations of crop destruct requirements will be updated to make the RA requirements and the UC policy consistent with each other.

The University of California field researchers are being notified of the re-instatement of their RA exemption via correspondence from Associate Vice President Henry Vaux to the DANR unit managers.

The UC site for the policy and notification form is:
https://danr.ucop.edu/admin-handbook/200/281pre.html

Copies of the policy are attached. If you have any questions related to this process, please contact me, or Don Koehler.

Sincerely,