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Emerging Issues in Structural Regulatory Enforcement

This report presents key emerging issues in structural regulatory enforcement, as discussed during a training session led by Mike Zeiss of the DPR on June 14, 2012, in Pomona, CA. It highlights ongoing regulatory changes impacting structural pest control companies, including registration standardization, pesticide use reporting requirements, and electronic data management. The report identifies seven major issues affecting compliance, such as locked enclosures during fumigations, the use of chloropicrin, and the evolving role of technology in record-keeping, emphasizing the importance of staying informed about regulatory developments.

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Emerging Issues in Structural Regulatory Enforcement

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  1. Emerging Issuesin Structural Regulatory Enforcement DPR Structural Regulatory Training Pomona CA, 14 June 2012 Mike Zeiss Enforcement Branch, DPR mzeiss@cdpr.ca.gov

  2. You mean the regulations change ? ! ? Yes - - keeping current is part of the job Sources of information about new developments / emerging issues: • Your Deputy or Commissioner • Enforcement Branch Liaison (EBL) for your county • Enforcement Letters from DPR • Meetings of Structural Fumigation Enforcement Program • (southern CA, quarterly) • Meetings of Structural Pest Control Board • (southern and northern CA, quarterly)

  3. Six emerging issues(in no particular order . . . )

  4. 1. County registration by structural pest control companies • Law says registration “in a form prescribed by the Director, after consulting with SPCB and the commissioners” (FAC 15204 and 15204.5) - - but see ENF 07-31 Addendum • SPCB requested DPR to consider standardizing • (at 1/12/2012 SPCB meeting) • DPR consulted with four southern CACs at Structural Fumigation Enforcement Program meeting (March 20, Arcadia CA). • No opposition in principle to DPR standardizing. • DPR will consult with SPCB, and with other CAC’s, before deciding how to proceed. 

  5. 2. Pesticide Use Report: Total number of applications for each pesticide • Law requires structural pest control companies to report number of applications (each pesticide) on Monthly Summary PUR • Existing ENF letters indicate not required • DPR is preparing new ENF letter to require this, • as per B&P Code 8505.17(c)

  6. 3. Structural stamps on use reports: incorporating into CalAg Permits • PUR’s from structural companies, “shall have affixed thereto a pesticide use stamp issued by the Board” B&P Code 8505.17 (c) • CalAg Permits has data field for the stamp number • For paper PUR’s, two options*: 1. Company affix stamp to paper copy; or 2. Company gives CAC their stamps for the year. CAC then includes the stamp number on the PUR. • Long term: find another funding mechanism? • (e.g., registration renewal fees) * 5/18/2012 email from George Farnsworth

  7. 4. Locked enclosures (gun safes / bank cabinets) during application and aeration • Not a new issue (for example, presentation at DPR’s 2011 structural training) • Higher profile recently, due to apparent Pic exposure during October 2010 bank fumigation. CA Dept. of Public Health distributed a factsheet. • PCOC is developing “Best Practices for Challenging Commercial Fumigations” (stewardship training). • DPR considering Enforcement Letter about meaning of “operable” on sulfuryl fluoride labeling.

  8. 5. Electronic methods of retaining orproviding information Current guidance from DPR Legal Affairs: • “Retain” may include on a computer hard drive, • provided records are accessible to inspectors “retain a copy of the occupants fumigation notice” for 3 years – 16 CCR 1970.4 • “Provide” or “deliver” may include via email, • unlessstatute restricts the method for providing “written inspection report shall be delivered to the person requesting the inspection within 10 days” – B&P Code 8516 (b) “leave in a conspicuous location a written notice identifying the name of each pesticide applied” – 16 CCR 1970.4 (c)

  9. 5. Electronic methods of retaining orproviding information (cont.) • Please read the entire statute Homework: notice required by B&P Code 8538 ? ? ? ? • Please ask your EBL for guidance • For electronic signatures, stay tuned . . . • (Enforcement Branch is reviewing with Legal)

  10. You mean the regulations change ? ! ? Yes - - keeping current is part of the job Sources of information about new developments / emerging issues: • Your Deputy or Commissioner • Enforcement Branch Liaison (EBL) for your county • Enforcement Letters from DPR • Meetings of Structural Fumigation Enforcement Program • (southern CA, quarterly) • Meetings of Structural Pest Control Board • (southern and northern CA, quarterly)

  11. 6. Amount of chloropicrin (warning agent): SF labeling versus SF calculator Sulfuryl fluoride labeling allows fumigators two options for determining how much pic to use: • 1 oz pic per 10,000 – 15,000 cubic feet airspace • in the structure, OR • Dosage rate from the calculator for that SF product • NOTE: If calculator is used, amount of pic may be lower than the 1 oz/10-15 k option!

  12. 7. Retirements creating opportunities at DPR

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