Department of Pesticide Regulation

Pesticide Research Authorization Updates, Forms, and Database

This letter provides information about the Department of Pesticide Regulation (DPR) Pesticide Registration Branch's efforts to implement changes to its research authorization (RA) program to include clarity, transparency, safety, and enforceability.

• DPR modified its RA application form to:
  • Clarify that the authorization does not apply to use of the pesticide on Federal or tribal lands and that use on such lands requires Federal or tribal authorization, and
  • More clearly state all required conditions. Conditions are now listed on a separate form to ensure that the conditions stand out and are not overlooked. This separate page also includes a reminder that "Failure to comply with any of the conditions of this authorization could result in its revocation and an administrative fine up to $5,000 for each time a condition is violated."
• Current regulations require that researchers provide a notice of intent (NOI) to the local County Agricultural Commissioner (CAC) at least 24 hours prior to beginning application of a pesticide under an RA. In order to provide CACs with more time to fully consider local conditions, by policy, DPR now requires researchers, conducting research with fumigants and products containing some new active ingredients, to provide the NOI to the CAC at least 72 hours prior to beginning the application.
• In August 2013, DPR completed development of a more robust and accurate RA database. As part of the redesign, DPR revised its RA application and experimental pesticide use report forms to add a few new data elements. The purpose of the form revision is to facilitate data entry into DPR's newly redesigned RA database.

Implementation Timeframe of New RA Forms
Researchers must request authorization of 2014 research trials on the new Pesticide Research Application form PR-REG-027a (Est. 12/12) and, if needed, on the new Pesticide Research Authorization (Additional Pesticides) form PR-REG-027b (Est. 12/12).

Effective January 1, 2014, following the final application of a pesticide requiring a research authorization in a particular trial location, and at least 24 hours prior to either harvest or crop destruction, experimental trial reports will be submitted by the researcher to the appropriate County Agricultural Commissioner(s) using Experimental Trial Report form, PR-REG-029 (Rev. 12/12).

Within two weeks following the expiration date of the research authorization, an experimental pesticide use report will be submitted by the researcher to DPR using the new Experimental Pesticide Use Report PR-REG-028a (Est. 12/12) and, if needed, Experimental Pesticide Use Report (Continued) PR-REG-028b (Est. 12/12).

New Form Data Elements
DPR's previous research authorization application form [PR-REG-027 (Rev. 2/12)] allowed a researcher to list multiple products. However, the new Pesticide Research Authorization Application Form [PR-REG-027a (Est. 12/12)] only allows for the listing of a single pesticide product test material. If additional research pesticide test materials are to be used, each product must be identified separately using the Pesticide Research Authorization (Additional Pesticides) PR-REG-027b (Est. 12/12). Additionally, if research is intended to be conducted on multiple formulation types and commodities/crop groups, each combination must be listed using the Pesticide Research Authorization (Additional Pesticides) PR-REG-027b (Est. 12/12) form. The use of California registered products (as standards or controls), in accordance with label directions, is not considered a research test material and should not be included on any of the research authorization application forms.

Application form [PR-REG-027a (Est. 12/12)] contains a space for the identification of each active ingredient present in that product. If the researcher substantiates that the chemical to be tested is pre-patent, DPR will use code names to identify the active ingredients in its database, and will maintain the actual active ingredient names in a confidential file. The new form also contains a space where researchers identify the county or counties in which they intend to conduct the research, if known. Any conditions placed by DPR on the research will appear on a separate page, entitled Pesticide Research Authorization Requirements [PR-REG-027c (Est. 12/12)], and will be attached to the signed approved research authorization application form.

The new Experimental Pesticide Use Report Form [PR-REG-028a (Est. 12/12)] provides for more detail about the research trial. Each product test material must be reported separately by formulation, commodity or site treated, and county. In other words, if a single test material is applied to three different commodities, each test material/commodity combination must be reported separately on the form. The same applies to the county in which the trial was conducted. If trials were conducted in multiple counties, then each test material/county combination must be reported separately.

The use report form also identifies the active ingredient(s) in the product test material and requires the researcher to calculate the total pounds of active ingredient used in the trial. As stated above, if the chemical is pre-patent, DPR will keep the active ingredient name confidential. Additional information may be submitted on Experimental Pesticide Use Report (Continued) PR-REG-028b (Est. 12/12). The use of California registered products (as standards or controls), in accordance with label directions during the course of the research, must be reported to the Agricultural Commissioner in the county where trials were conducted on grower/applicator pesticide use reporting forms.

DPR Web Site for Location of Existing RA Forms and New RA Forms
All research authorization forms are available as fillable PDF documents on DPR's Web site at www.cdpr.ca.gov/docs/registration/regforms/ra/ramenu.htm.

Conversion of Existing RAs Granted in 2013 and Set to Conclude in 2014
In January 2014, DPR plans to amend those RAs with trials approved and initiated in 2013 and concluding in 2014. DPR will close out its current approval of the research trial effective December 31, 2013, and reissue a new approved RA with a 2014 RA number to use in finishing up the trials.

Proposed Training Microsoft PowerPoint Presentation
DPR plans to develop a training presentation, which is expected to be available in December 2013, to assist researchers in filling out the new RA forms.

Contact for Questions
If you have any questions or comments regarding the RA process, please email the RA account at RAs@cdpr.ca.gov or contact Mr. Don Antonowich of the Pesticide Registration Branch by telephone at 916-445-3686 or email at Donald.Antonowich@cdpr.ca.gov. All other questions, please contact the Enforcement Branch Liaison assigned to your county. DPR plans to develop a Frequently Asked Questions (FAQ) document which will be posted to DPR's Web site.

cc:    Mr. Don Antonowich, DPR Senior Environmental Scientist
         Mr. Joe Marade, DPR Agricultural Commissioner Liaison
         Enforcement Branch Liaison