Department of Pesticide Regulation logo
Brian R. Leahy
Director
California State Seal
Edmund G. Brown Jr.
Governor
02/21/2017
ENF 17-06
To: County Agricultural Commissioners

Update to Volume 4, Inspection Procedures Compendium, Including Worker Protection Standard (WPS) Revisions

This announces the availability of, and summarizes updates and revisions to Volume 4, Inspection Procedures, one of the volumes of the Pesticide Use Enforcement Program Standards Compendium. Updates are enclosed and will also be available online. Please have your staff begin using this update as soon as possible. Hard copies of the revised manual will be distributed to attendees at the upcoming training sessions. Later in 2017, DPR will provide an updated CD for each county.

Most of these updates are the result of revisions to the Title 3 California Code of Regulations (3 CCR) worker safety requirements to comply with the newly revised federal Worker Protection Standard WPS, effective January 2017. Also included are other recent regulatory changes such as for personal protective equipment (PPE) and closed systems.

Highlights of the revisions to compendium volume:

  • Generally, chapters were revised to
    • -Incorporate new or revised 3 CCR 6000 definitions for Application Exclusion Zone, Enclosed Cab, Enclosed Space (including greenhouse), Fieldworker Housing Area.
    • -Incorporate 3 CCR 6764 Fieldworker Training amended and subsection added; time between training was reduced, specifies location of training, additional record requirements, and record keeping requirements.
    • -Incorporate 3 CCR 6744 Equipment Maintenance expanded; employer shall provide information to businesses providing cleaning, servicing, or repairing of pesticide equipment used for production
    • -Incorporate 3 CCR 6722 Minimum Age new requirement, handlers of pesticides for production agriculture and early entry workers must be at least 18 years of age.
    • – Deleted 3 CCR 6720(d) Safety of Employed Persons exemption for employees of Pest Control Advisors and Registered Foresters.
  • Chapter 1, General Inspection Procedures – In the section on Complete Inspections page12, expanded the use of “N/A” to include inspection requirements which cannot be confirmed or verified.
  • Chapter 2, Pre-Application Site Evaluation – various edits
  • Chapter 3, Fieldworker Safety – Form Requirements –
    • 6618(a) Notice of Application: added information and instruction requirements.
    • 6761 Hazard Communication A-9: added locations for displaying PSIS A-9, additional information requirements, and procedures for requesting employee information.
    • 6761.1 Application Specific Information display: added information and required to be maintained for two years.
    • 6762 Field Work During Pesticide Application uses: Enclosed Space to replace Greenhouse, and adds requirements for application exclusion zone.
    • 6766 Emergency Medical Care Knowledge: requires employer to provide information to medical personnel treating an employee.
    • 6768 Decontamination Facility: amended and added decontamination supply requirements for workers and early entry activities. Employer is required to inform employees of the decontamination facility location.
    • 6769 Greenhouse (Enclosed Space) Ventilation Criteria: term Greenhouse changed to Enclosed Space.
    • 6770 Field Entry after pesticide application: removed operating tractors or other equipment from no contact activity. Enclosed space replaces the term greenhouse. Restriction added to short-term, limited-contact activities.
    • 6771 Early Entry Requirements: added the employer shall orally provide employee with information prior to performing early entry activities.
    • 6776 Posting Compliance: reduced REI for field and enclosed space posting and added posting requirements near worker housing.
  • Chapter 4, Pesticide Use Monitoring – Form Requirements –
    • 6734 Decontamination Facilities: for production agriculture added specific water requirements for washing and eye flush.
    • 6726 Emergency Medical Care Posting: requires employer to provide information to medical personnel treating employee(s).
    • 6434 Notice of Intent Submitted: deleted licensed PCA since PCA does not have authority to submit an NOI for the grower unless the PCA is an authorized representative.
    • 6730 Employees Working Alone “Danger”: Changed from “N/A” to “Yes” in compliance when two or more handlers are working together.
    • 6738 Regulations –
      • – PPE Gloves: Added storage requirement for chemical-resistant gloves inside of an aircraft.
      • – PPE Exemption: Deletion of the exemption and substitution for chemical-resistant gloves and protective eyewear when operating an aircraft.
      • – PPE Exemption: Revised closed system PPE exemption to include dry formulation of pesticides packaged in water-soluble packets and amended respirator exemptions while inside an enclosed cab. Amended PPE substitution while in an enclosed aircraft cockpit.
    • 6746 Closed System used/criteria: Revised to reflect regulatory changes.
    • 6776 Field Postings: Reduced REI for field and enclosed space posting and added posting requirements near worker housing.
    • 6884 San Joaquin Valley Ozone Nonattainment Area Use Prohibitions : Added requirement for applications of high-volatile organic compound (VOC) products used in agricultural sites in San Joaquin Valley Ozone Nonattainment area.
  • Chapter 5, Commodity Fumigation – Form Requirement –
    • 6782 Fumigation of Enclosed Areas: Terminology change to Enclosed Area and additional requirement to maintain contact with employees in an enclosed area for production agriculture.
  • Chapter 6, Field Fumigation Use Monitoring – Form Requirement –
    • 6734 Decontamination Facilities Eyewash Available: for production agriculture added specific water requirements for washing and eye flush.
    • 6726 Emergency Medical Care Posting: requires employer to provide information to medical personnel treating employee(s).
    • 6434 Notice of Intent Submitted: Deleted NOI submitted by licensed PCA since PCA does not have authority to submit an NOI for the grower unless the PCA is an authorized representative.
    • 6776 Field Postings: Reduced REI for field and enclosed space posting and added posting requirements near worker housing.
  • Chapter 7, Structural Branch 1 Use Monitoring – Form Requirements –
    • 6782 Fumigation of Enclosed Areas: Terminology change to Enclosed Area and added requirement to maintain contact with employees in an enclosed area for production agriculture.
  • Chapter 8, Structural Branch 2/3 Use Monitoring – various edits
  • Chapter 9, Pest Control Headquarters – Form Requirements –
    • 6618 Notice Prior to Application: added information and instruction requirements.
    • 6619 Application Completion records/2years: amended to include additional information.
    • 6723 Hazard Communication for Pesticide Handlers expanded to include addition locations to post information, additional information requirements, and procedures for requesting employee information.
    • 6723.1 Application-Specific Information for Handlers added information and required to be maintained for two years.
    • 6724(b-e) Handler Training: amended to include training location, additional information on training records such as training materials and trainer qualifications.
    • 6726 Emergency Medical Care Planned: requires employer to provide information to medical personnel treating employee(s).
    • 6732 Change Area: Decontamination supplies were added to the requirement.
    • 6761 Hazard Communication for Field Workers: Added locations for displaying PSIS A-9, additional information requirements, and procedures for requesting employee information.
    • 6761.1 Application Specific Information (ASI) for Fieldworkers added information and to be maintained for two years.
    • 6726/6766 Emergency Medical Care Planned: requires employer to provide information to medical personnel treating an employee.
  • Chapter 10, Pest Control Business Headquarters – Form Requirements –
    • 6618 Notice of Application: added information and instruction requirements.
    • 6723 Hazard Communication for Pesticide Handlers: expanded to include addition locations to post information, additional information, and procedures for requesting employee information.
    • 6724 Handler Training: amended to include training location, additional information on training records including training materials and trainer qualifications.
    • 6726 Emergency Medical Care Planned: requires employer to provide information to medical personnel treating employee(s).
    • 6886 San Joaquin Valley Ozone Nonattainment Area: Dealer Requirement, added dealer responsibility to provide information to purchaser.
  • Appendix 1 Personal Protective Equipment – Incorporates latest PPE regulations and renumbering, including requirements for gloves and eyewear when operating an aircraft; incorporates closed systems requirements and exemptions.
  • Appendix 2 Inspection Interviews – minor edits.
  • Appendix 3 Backflow Prevention and Chemigation -various edits.
  • Appendix 7 Fumigation Methods for VOC Nonattainment Areas – various edits to link to DPR websites for more current information.

If you need further assistance, please contact the Enforcement Branch Liaison assigned to your county.

Sincerely,

Original signature by:
Donna Marciano
Chief, Enforcement Branch
916-324-4100

Enclosures

  • PUE Program Standards
CC:
Mr. Joe Marade, DPR Agricultural Commissioner Liaison
Enforcement Branch Liaisons