Department of Pesticide Regulation logo
Teresa Marks
Director
California State Seal
Gavin Newsom
Governor
Jared Blumenfeld
Secretary for Environmental Protection
05/24/2019
ENF 19-06
To: County Agricultural Commissioners

Updates to Investigation Procedures Compendium Volume 5

This announces the availability of, and summarizes updates and revisions to Volume 5, Investigation 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.

Highlights of the revisions to compendium volume:

Generally, chapters were revised to clarify or expand upon the roles, expectations, and guidance for pesticide related investigations. Also throughout the volume, recommended investigation questions and guidance for response regarding odor have been incorporated where applicable.

Chapter I:  General Information

  • Updated and summarized State and County investigation authority and include a link to the recently issued Compendium volume General Administration of the Pesticide Use Enforcement Program which contains a more complete description.
  • Amended to remove categorization of use-related and not use-related exposures and to remove categorization of non-occupational episodes, including deletion of the flow chart.
  • Added the term Bureau of Indian Affairs.
  • Added a section on incident complaints about the CAC.
  • Moved the section on Investigative Plan to Chapter II.
  • Moved the section on Timely Submission of Investigation Reports to Chapter II.

Chapter II: Investigation Objectives and Procedures

  • Added DPR’s role and the medical professional’s role in the collection of information.
  • Added the availability of environmental monitoring modeling and bilingual staff.
  • Added items such as environmental conditions and pesticide accessibility to help determine exposure
  • Added the suggestion to obtain a copy of the CalOSHA Employee’s Report of Injury.
  • Added the requirement for a copy of the Medical Supervision Program written agreement between the employer and the physician.
  • Include odor to be considered when investigating field worker cluster incidents.
  • Added a new section Structural Pest Control Incidents.
  • Added a new section Government Agency Sponsored Pest Control Operations Incidents.
  • Retitled and updated Incidents Involving Antimicrobial Pesticides with information on dual purpose pesticides and to provide a handout titled ‘What You Need to Know About Using Disinfectants, Sanitizers, Medical Sterilants, and Other Antimicrobials in the Workplace.”
  • Deleted the need to obtain Coroner’s report for suicide/self harm incidents.
  • Deleted specific section on Complaints/Illnesses related to Odor to incorporate associated investigation questions and guidance into applicable sections throughout the volume.
  • Include consideration of odor when investigating complaints.
  • Expanded section on Property Loss regarding bee/pollinator incidents.
  • Moved the Investigative Plan and the Timely Submission of Non-Priority Investigation Reports from chapter I. Retitled to identify non-priority investigative reports.
  • Include consideration of odor when conducting witness interviews.

Chapter III: Evidence Collection

  • Updated and reworded Purpose and Goals
  • Added DPR guidance when formulating an Investigative Sampling Plan.
  • Deleted lab footnotes.
  • Changed the term weight to mass.
  • Added respirator and goggles or approved safety glasses to the section on Personal Protective Equipment.
  • Revised bee sample collection amount.
  • Revised section on Tank Mix Samples to request trained handlers to collect samples. Added information regarding shipping a hazardous material.
  • Updated instructions for the Completing the Investigative Sample Analysis Report/Custody Record Form (Rev. 3/16).

Chapter IV- The Investigative Report

  • Clarified workdays lost regarding workdays and normal days off.
  • Updated the EPA Registration Number to include California Registration Number and adjuvants that are not federally registered.
  • Added activities performed outside of work to Exposure Information and Medical History.
  • Deleted the Antimicrobial Exposure Episode Report form (PR-ENF-182).

Chapter V- Disposition of the Episode Investigative Report

  • Added information regarding uploading Priority Episode Investigation documents into the CalPEATS system.
  • Added information regarding uploading Non-priority human effects episode illness reports, into the CalPEATS system, including HIPAA protected information.
  • Moved section on Records Requests to Compendium Volume 1.

Chapter VI- Appendices

  • Appendix E has additional questions regarding exposures and illnesses.
  • Appendix E, section c and d, has added odor-related investigative questions.
  • Appendix G, renamed
  • Appendix H, deleted to move section on Federal Facilities to Compendium Volume 1.
  • Appendix I, deleted to move Sample Letter to Compendium Volume 1.

Chapter VII- Associated Forms

  • The forms are now listed as web links to the most current version of each form.
  • The Antimicrobial Exposure Episode Report form (PR-ENF-182) has been removed and replaced with the Pesticide Episode Investigation Report form (PR-ENF-127).

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

CC:
Mr. Joe Marade, DPR Agricultural Commissioner Liaison
Enforcement Branch Liaisons