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PESTICIDE USE REPORTS (PUR)
 When filling out Monthly Summary Pesticide Use Reports, many pest control operators in California only fill out the total number of applications for Restricted Use Materials and category 1 pesticides, excluding category 2 and 3 pesticides. This practice is in following with enforcement letter 90-13 issued in January of 1990 (see below – pertinent areas are italicized, bold and underlined).ENF 90-13 (Enforcement Letter) Jan. 12 ,1990: To: County Agricultural Commissioners Subject: 100% Pesticide Use Reporting (Policy Letter No. 5) Recent meetings between the Pesticide Use Enforcement Branch, Worker Health and Safety Branch (WH&S) and the Pest Control Operators of California (PCOC) have resulted in the following agreement and policy (attached): - Structural Pest Control Operators (SPCO) will continue to complete the Total Number of Applications Box. (Located at the top of the Monthly Summary Pesticide Use Report.) - SPCOs will continue to identify the number of applications for each restricted and category 1 pesticide(s) applied (Located in column D of the Month Summary Pesticide Use Report.) - SPCOs will not be required to identify the number of applications for each non-restricted category 2 and 3 pesticide applied (Located in column D of the Monthly Summary Pesticide Use Report.) PCOC has agreed to the requirements of this policy which are a stricter standard than the new use reporting requirements. Under the terms of the policy PCOC in co-operation with WH&S will conduct actual studies of exposure to workers. These studies are expected to provide information in greater detail than could otherwise be obtained through the requirements of California Code of Regulations Section 6627. Therefore, the Department is rescinding the statement in ENF Letter 89-75 that states in part: "require that all monthly pesticide reports include the number of applications for each type of pesticide applied." Please continue to refer to ENF Letter 89-75 to assist you in determining the toxicity category and restricted use status of pesticide(s) listed on the Monthly Summary Pesticide Use Report. The listing provides the names, toxicity categories and restricted use status. However, the Department of Pesticide Regulation is looking into requiring SPCB-registered companies to comply with the Structural Pest Control Act 8505.17. (see below) From the Structural Pest Control Act: 8505.17. (c) Registered structural pest control companies shall prepare and submit to the county agricultural commissioner a monthly report of all pesticides used in that county. The report shall be on a form approved by the Director of Pesticide Regulation and shall contain the name and registration number of each pesticide, the amount used and the number of applications made. The report shall be submitted to the commissioner by the 10th day of the month following the month of application. Each pesticide use report or combination of use reports representing a registered structural pest control company's total county pesticide use for the month shall have affixed thereto a pesticide use stamp issued by the board in the denomination fixed by the board in accordance with Section 8674 as the pesticide use report filing fee. The board shall provide for the sale of these stamps and for the refund of moneys paid for stamps which are returned to it unused. When a registered structural pest control company performs no pest control during a month in a county in which it has given notice pursuant to Section 15204 of the Food and Agricultural Code, the registered company shall submit a use report stating this fact to the commissioner. No pesticide use stamp is required on negative use reports. This shift in policy will require all companies throughout California to put the number of applications for all pesticides no matter what the category into their monthly summaries. This will also allow DPR to better track pesticide usage throughout California. A few counties in California have already started adopting this practice. Companies that file electronically should make sure their software allows for tracking pesticide usage in all categories just to be ready in case the change is implemented. If and when this modification will happen is uncertain at this time. Representatives of PCOC have been conversing with DPR on the matter. INACCURATE PESTICIDE USE REPORTING The pest control industry is being scrutinized by government agencies, activist groups, media and the public. With environmental and water quality concerns, the industry needs to be careful now more than ever. One such area of scrutiny is accurate reporting of pesticide usage. In recent years, there has been an over-reporting of usage compared to materials actually purchased. This over-reporting reflects badly upon PCOs. Steps you can take to improve accuracy: - Ensure that all customer accounts are identified with their counties. - Have service technicians report daily pesticide uses in each county in which they make applications. - Ensure applicators make accurate measurements of amount applied (not approximations). - Fill out service reports after applications are made. - Report amount of concentrate used, not finished solution. - Ensure unit of measurement is consistent with package. - Report the smallest amount that can be measured. Accurate Inventory Management - Have one person responsible for issuing material and documenting distribution. - Take inventory monthly including storage area(s) and service vehicle(s). - Take accurate measurements of partially filled containers. - Make sure all materials are accounted for. - Compare ending inventory with beginning inventory in both the storage at the business and on the service vehicles. |
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