Pesticide Use Reporting Data in Pesticide Regulation and Policy: The

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Chapter 5

Pesticide Use Reporting Data in Pesticide Regulation and Policy: The California Experience Nino Yanga,* Pamela Wofford, Christopher DeMars, Emily Bryson, Nathan Desjarlais, and Kimberly Steinmann California Department of Pesticide Regulation, 1001 I Street, P.O. Box 4015, Sacramento, California 95812, United States *E-mail: [email protected]

California is one of a handful of US states that have an existing pesticide use reporting system. The California Department of Pesticide Regulation’s (DPR) full Pesticide Use Reporting (PUR) Program is considered to be one of the best source of pesticide use data in the world. While the most obvious application of pesticide use data is to determine pesticide use trends, DPR also uses PUR data in a variety of programs related to environmental monitoring, human health assessment, protecting worker health and safety, pesticide risk mitigation, pesticide use enforcement, focusing outreach efforts, promoting research, and fostering reduced risk pest management. This chapter will demonstrate - through examples - how the various DPR branches use PUR data to directly or indirectly contribute to the development of policy and regulation that helps fulfill the Department’s mission to protect human health and the environment.

The California Department of Pesticide Regulation and the Pesticide Use Reporting Program The California Department of Pesticide Regulation (DPR) was created in 1991 when the state’s pesticide regulatory program was integrated with the newly created California Environmental Protection Agency. Prior to 1991, pesticides in California were regulated by the California Department of Food and Agriculture © 2018 American Chemical Society

ang et al.; Managing and Analyzing Pesticide Use Data for Pest Management, Environmental Monitoring, Public Health, and Public Pol ACS Symposium Series; American Chemical Society: Washington, DC, 2018.

(CDFA) and before that, by its predecessor, the California Department of Agriculture. DPR’s mission is to protect human health and the environment by regulating pesticide sales and use, and by fostering reduced risk pest management (1, 2). Limited use reporting requirements have been in place in California since the early 1930s but California became the first state to require full reporting of agricultural pesticide use in 1990. The Department of Pesticide Regulation’s Pesticide Use Reporting (PUR) Program has evolved over the years. In earlier days, the California Department of Food and Agriculture (CDFA), through the County Agricultural Commissioners (CAC), required agricultural pest control operators to submit monthly reports of the work they performed (1, 2). Although the reporting requirements in the past differed by county, many required a monthly report for each pesticide application that included the location, date, crop, acres or other units treated, pest, kind of pesticide used, concentration and amount of the spray or dust mixture applied. At that time, only data on aerial pesticide applications were summarized on a state level. Only statistics on aerial pesticide applications were forwarded for statewide tabulation. In 1955, the CDFA asked that ground application acreage be included in reports, however, the requirements for detailed reporting of pesticides used, and commodities treated were discontinued. Regulatory changes in the 1970s resulted in a branched system which required commercial pest control operators to report all pesticides used but farmers to only report their use of Restricted Materials. Both pest control operators and growers filed pesticide use reports with the CAC in the county where they performed the applications. Information in these reports included the pesticide applied, date, time and location (section, township, and range) of the application, and the crop and acres treated if the application was in agriculture. CACs forwarded these use reports to the State where the data was entered into a database and subsequently tabulated and summarized in published annual reports (1, 2). Commercial pest control operators included those ground and aerial applicators engaged in pest control for hire, structural applicators, and professional gardeners. Restricted Materials are pesticides considered to have a high potential to cause harm to public health, farm workers, domestic animals, honeybees, the environment, wildlife, or other crops. Federally restricted-use pesticides have also been designated as restricted materials in California. California has also included additional materials as restricted-use. California allows the use of these materials only through a permit process (1–3). In the late 1980s, there was an increased demand for more realistic and comprehensive data on pesticide use that could be used to more accurately estimate dietary risk, pesticide exposure and the potential risks of these exposures to workers. This demand, and the clear statutory authority given to DPR by the Food Safety Act of 1989, led to the transition to full pesticide use reporting in 1990 (1, 2). Under full pesticide use reporting, all agricultural use must be reported monthly to the CAC who, in turn, reports the data to DPR. California has a broad legal definition of “agricultural use.” That definition includes pesticide applications to parks, golf courses, cemeteries, rangeland, pastures, and 98


along roadside and railroad rights-of-way. Postharvest pesticide treatments of agricultural commodities and all pesticide treatments in poultry and fish production, as well as some livestock applications, must also be reported. The primary exceptions to the full pesticide use reporting requirements are home and garden use, and most industrial and institutional uses (1, 2). Full pesticide use reports must include the date and location (section, township, and range) where the application was made in agricultural fields, and specify the kind, and amount of, pesticides used. When a pesticide is applied to a crop, the type of commodity must also be reported. A significant addition to the reporting program was the issuance of site and operator (pesticide user) identification numbers. Before an operator can purchase or use pesticides, he or she is required to obtain a unique operator ID from each county in which pest control work will be performed. Growers also obtain a site ID from the CAC for each location and crop/commodity where pest control work will be performed, and this identification number is recorded on the restricted material permit or other approved form. The number of acres to which a crop is planted is an additional reporting requirement. This information, in combination with the treated acres, is valuable in conducting pesticide risk assessments (1, 2). Requirements for structural pest control operators, professional gardeners, and other non-agricultural pest control operators – who already had to report all pesticide use under the earlier regulations - did not change under the full pesticide use reporting program (1, 2). This chapter will focus on the various ways that some of the branches in DPR’s Pesticide Programs Division utilize PUR data, and will provide examples of how these uses directly or indirectly contribute to the development of effective policy and regulations that fulfill DPR’s mission.

PUR Data and Human Health Assessment DPR’s Human Health Assessment Branch (HHA) assesses health risks associated with pesticide exposure in humans, specifically farm workers (i.e. mixers/loaders/applicators and reentry workers), occupational and residential bystanders (e.g. neighbors of agricultural lands), and the general public (e.g. consumers of California’s agricultural commodities). The spatiotemporal accuracy of the PUR database is essential for accurately estimating the exposure to these specific groups of individuals. Since 1990, pesticide use reports have recorded the time and the 1 x 1 square mile section of all commercial agricultural pesticide applications. This temporal and spatial resolution allows HHA to generate scientifically defensible exposure estimates that are subsequently entered into risk characterization equations. These risk characterization equations determine if a given pesticide poses a significant or potential risk to human health. One of the main focuses of pesticide exposure assessment is the potential contamination of drinking water supplies derived from surface and ground water sources. In the past, the drinking water exposure assessment was based only on available sampling data. This methodology has some limitations. One limitation 99


is whether existing sampling cover the time and place of use of a pesticide. For example, if the sampling locations have low to no use, then exposure is likely underestimated. Concerns related to a monitoring-based exposure assessment methodology may be alleviated by using PUR data to overlay spatial usage patterns from the PUR database with sampling locations and comparing time series usage patterns with sampling dates. This increases the confidence in the current sampling data and also identifies areas where additional sampling must be conducted. For collecting ground water samples, time of use versus time of sampling is less of a concern since infiltration and percolation to the aquifer modulate any sudden concentration increases from seasonal application of pesticides. However, pesticide concentration in surface water is highly transitory such that sampling a day before, or a week after, use can seriously affect the exposure estimate and therefore, the anticipated risk. The temporal accuracy of the PUR data is crucial in assessing the potential health risk associated with consumption of the contaminated surface drinking water. Another concern related to the use of any available sampling data is whether sampling corresponds with the extraction location of drinking water. When collecting groundwater samples, DPR’s Groundwater Protection Program collects specific samples for a given pesticide in regions of high use with highly permeable soil, and focus on shallow wells that would be the most likely to have contamination problems. However, when collecting surface water samples, DPR’s Surface Water Protection Program identifies areas of the greatest potential for the environmental threat (e.g., ecological impacts) of pesticide runoff, and thus focus their resources on areas of specific biological concern. These areas may or may not coincide with drinking water extraction points for use in human consumption. For example, any estimates of risk to drinking water will be excessively inflated if the only sampling data available is from non-potable sources (e.g., agricultural sloughs). By contrast, any risk estimate could be far lower than reasonable if there is no sampling data within the watersheds feeding a drinking water extraction point that contain pesticide use. Additionally, pesticides may be detected in natural waterways downstream from the drinking water extraction point, but a spatial analysis of pesticide use within the contributing watershed of the extraction point may show no use in that area. In this instance, it can be assumed that there is minimal to no risk to that drinking water source. PUR spatio-temporal accuracy is even more crucial when modeling the exposure from spray drift. Pesticides applied by fixed-wing aircraft, rotary aircraft, or ground-based equipment (e.g., airblast and ground boom) along with untarped fumigants can possibly drift off-site with the wind and expose bystanders. Compared to groundwater and surface water exposure assessments, spray drift exposure assessments have the greatest sensitivity to both time and space. Even worst-case drift scenarios rarely result in significant mass traveling more than a few thousand feet off-site. Likewise, timing of the risk is rarely more than a few days post application. In many cases, there is a need for a finer spatial discretization than PUR’s native PLSS section. When downscaling is needed, PUR records are associated with vector polygons from agricultural spatial land use layers acquired from each county. Downscaled use maps are then combined with wind data and non-agricultural land use spatial layers to assess the exposure 100


of neighbors to pesticide drift. If the time or space discretization of PUR was any coarser, it would not be feasible to identify, much less quantify, specific households, businesses, or community facilities that are at risk of pesticide drift exposure. Dust with sorbed pesticides that has been transported from agricultural fields to inside nearby residences constitutes another source of potential bystander exposure. Available household dust sampling data is far more limited than other exposure media (e.g. surface water or groundwater). However, what little sampling exists can be compared to nearby pesticide usage, soil types, and weather patterns. PUR data can then be used to extrapolate those patterns to other regions and time periods. By using PUR data in their risk assessment, DPR’s HHA Branch applies assumptions and estimations that can be related to the actual time, location, and amount of pesticides applied. This minimizes severely overestimating or underestimating actual risk which in turn increases confidence in the final risk assessments.

PUR Data and Environmental Monitoring Pesticide Use Report data is an integral part of the work conducted in DPR’s Environmental Monitoring Branch. The Branch continues to find creative ways to analyze and use PUR data to support its objectives. The Surface Water Protection Program (SWPP) has utilized PUR data in a variety of ways. For example, SWPP staff use PUR data in the program’s Surface Water Monitoring Prioritization Model to determine active ingredients and watersheds for monitoring in both urban and agricultural areas (4). Staff also use PUR data to identify key pollution sources within watersheds to help strategically target mitigation efforts (5, 6). Data have been summarized and presented at outreach events to help stakeholders understand how agricultural and urban pesticide use patterns can lead to exposures of aquatic organisms in surface waters (7–9). PUR data have also been used in modeling to predict pesticide fate and transport, and in data assessments to investigate and potentially explain the status and trend of pesticide concentrations in aquatic systems (10, 11). In some cases, data can be used to help determine the effectiveness of mitigation measures or regulatory actions (12). Furthermore, use data have been used in the development of permit conditions, regulations and label changes to help protect surface water quality (13–15). The Air Program staff utilize PUR information to conduct a variety of analyses including: selection of air monitoring locations in areas of highest pesticide use, establishment of appropriate limits on use of specific pesticides to mitigate longterm exposure, and to maintain a volatile organic compound inventory to mitigate ozone levels in air basins that are out of attainment of ozone standards. Additional PUR analysis conducted by the Air Program include statistical analysis of PUR data with measured air concentrations, estimation of potential pesticide exposure, and to answer complex questions on the use trends and environmental impacts of pesticides. 101


The PUR database is often used to determine areas of high use of a pesticide(s) of interest to determine the appropriate locations to monitor ambient air concentrations for evaluation of exposure to pesticides in the air. As part of DPR’s Air Monitoring Network development, DPR evaluated over 1,200 communities for possible site selection based on the use density of selected pesticides surrounding the communities. This information was obtained from the PUR database (16). The selection procedure ensured that the communities with the highest exposure potential were selected for the network. PUR information is also used to develop mitigation measures when it is determined that potential exposure to a pesticide of concern may need to be reduced. As an example, to mitigate potential cancer risks, a township limit on the use of 1,3-dichloropropene (1,3-D) was established through intensive statistical comparisons of measured air concentrations to reported 1,3-D use (17). Under the federal Clean Air Act, California must meet national standards for airborne pollutants and must specify how it plans to achieve these goals in a federally approved State Implementation Plan (18). As part of California’s State Implementation Plan (SIP), DPR must track and control Volatile Organic Compounds (VOC) emissions from pesticide products in five regions that do not attain the federal air quality standard for ozone (ozone Nonattainment Areas(NAA)). DPR tracks estimated VOC emissions based on PUR information from pesticide applications made between May 1 and October 31 (the peak ozone season) to ensure California complies with the federal SIP. DPR’s Ground Water Protection Program (GWPP) analyzes PUR data to identify pesticides that have the potential to pollute ground water. If identified pesticides are detected in ground water or as a result of the ground water monitoring program, then a formal review is conducted to determine whether the agricultural use of the detected pesticide can be allowed or must be modified to protect ground water (19). As part of the pesticide product registration process, DPR obtains environmental fate data for each agricultural use pesticide. This data, along with application instructions from the product label regarding use rate and methods, determines if a pesticide will be added to the Ground Water Protection List as a potential contaminant (20). Prioritizing these pesticides for monitoring is based on a PUR data analysis and the computer modeling of each pesticide’s potential to move to ground water (21). The PUR data utilized in the model are sites of application, estimated proportion of soil applications, annual state-wide use, and average annual rate of change in use. Pesticides with high and increasing use, especially in irrigated sites or direct soil applications, receive higher ranking and thus, higher priority for monitoring. DPR then focuses groundwater monitoring for priority pesticides in areas of high agricultural use. This gives DPR the greatest probability of detecting contamination by focusing monitoring studies in highly vulnerable areas where the pesticide is used most. When a pesticide or pesticide degradate is found in the groundwater of the state, DPR analyzes PUR data to see where and how the detected pesticide is applied and compares that to the locations of the detections (22). If the detections are not from a point source and are the result of agricultural use, DPR is required to begin a formal regulatory review process. During the regulatory review 102


process, information, such as registrant reports, public comments, and PUR data, is reviewed to determine whether pollution has occurred and whether agricultural use modifications are necessary to protect the groundwater in California.

PUR Data and Worker Health and Safety DPR’s Worker Health and Safety (WHS) Branch frequently uses PUR data to guide and inform research projects and tasks related to human health mitigation, exposure monitoring, industrial hygiene, and pesticide illness surveillance. Within WHS, the Human Health Mitigation program develops and conducts studies designed to quantify worker exposure. The results of these studies are used to develop protective measures and mitigation aimed at reducing occupational risks associated with agricultural work. PUR data provides information on seasonal use trends, crop use trends, and upper limits of use on specific acreage, all of which are used to determine how, when, and where to conduct exposure studies. In 2017, DPR’s WHS Branch began developing a protocol to quantify pilots’ pesticide exposure in open and closed helicopter cockpits during aerial pesticide applications. PUR data provided critical insight into which active ingredients and products were most often applied aerially to identify target analytes to assay during the exposure monitoring study. PUR data was also used to determine seasonal trends in aerial applications in order to generate a timeline for the study. The Human Health Mitigation program also uses PUR data throughout the mitigation process. After a pesticide of concern has been identified through DPR’s Human Health Assessment Branch risk assessment process, scientists within the Human Health Mitigation program use PUR data to propose risk mitigation procedures. These procedures include mitigation scoping documents that evaluate pesticide use and illness data to assess whether or not an active ingredient poses unacceptable human health risks to workers and to determine if mitigation is required (23). Examples of some pesticides for which the WHS Branch has prepared mitigation scoping documents include phosphine, simazine, propargite, and carbaryl (24–27). Mitigation scoping documents include a section on pesticide use and sales. PUR data is used to identify how these pesticides are used as well as locations in the state where they are used. WHS scientists take a similar approach of analyzing PUR data to develop risk mitigation measures in response to proposed regulations. When mitigation is proposed in response to an active ingredient’s scoping document, PUR data is used to ensure that proposed measures are appropriate based on actual pesticide use, to determine which counties and agricultural commodities would be impacted by mitigation, and to assess the economic impact of the proposed measures. PUR data is also used by the Human Health Mitigation program to create mitigation completion memorandums. In creating these memorandums, PUR data provides critical information about the various uses of the pesticide active ingredient in California (i.e. structural use, specific crop use). The data is also used to determine if further mitigation is required based on annual trends of total active ingredient applied. Examples of some pesticides for which WHS 103


has developed mitigation completion memorandums include azinphos-methyl, carbofuran, cycloate, endosulfan, S-ethyl-dipropylthiocarbamate (EPTC), hydramethylnon, and methidathion (28–35). Once the proposed mitigation measures have gone into effect, PUR data is also used to measure their efficacy and success. Analyzing and comparing the total pounds of active ingredient applied before and after mitigation allows the branch to identify the impact of the mitigation measures on the overall use of the pesticide. Additionally, PUR data is used to identify high use counties to help determine where to focus outreach efforts once new measures have been put into place. For example, when DPR receives a request to provide guidance and training on pesticide handler safety at a commodity group meeting, the industrial hygienist giving the presentation can use PUR data to determine the specific pesticide products most applied to the commodity and use crop specific product label requirements to customize their presentation. By using pesticide use data applicable and relatable to the target audience, the efficacy and impact of outreach efforts are maximized. WHS also houses DPR’s Pesticide Illness Surveillance Program (PISP) that investigates, tracks, and evaluates pesticide related illnesses. Scientists in the illness surveillance program evaluate investigative reports to determine the likelihood of a pesticide exposure resulting in illness symptoms. Scientists are in a better position to establish a relationship between exposure and illness when they have a complete investigative report that includes pesticide use data. In the event that there are data gaps in the investigation, PUR data is used to augment the report by providing essential information on the specific product and formulation applied at the time of the incident or the exact date of the application. PUR data is also used to verify information related to pesticide applications presented in illness investigation reports. Scientists within the PISP also analyze PUR data to track temporal and spatial trends in the use of a specific product and/or active ingredient to ascertain if correlations exist between use trends and the number of illnesses associated with the corresponding product. When PISP scientists observe high incidence of illness related to a single active ingredient, they use PUR data to determine if the product is a low use product and to identify whether the majority of associated illnesses can be attributed to a single product formulation in order to guide and prioritize mitigation. In 2013, PISP scientists observed higher rates of illness incidents associated with an emulsifiable concentrate formulation of a pyrazole insecticide product compared to flowable concentrate and pellet/tablet formulations of the same active ingredient. WHS scientists were able to use this analysis to develop product and formulation-specific mitigation measures that targeted the product of concern. Currently, scientists in the Pesticide Illness Surveillance and Human Health Mitigation programs are collaborating to geocode and overlay pesticide illness incidents with PUR data to identify illness clusters in relation to high pesticide use areas and to determine if rates of illness correlate with use. This project is described in further detail by Wroblicky et al. in another chapter of this book. Oftentimes, individual incident reports do not provide adequate or specific site information to accurately map in GIS, so PUR data is used to supplement any descriptive information within the report in order to identify the exact site of an 104


exposure event. For example, an illness investigative report may indicate that an exposure occurred in a field southeast of two cross streets while an individual was applying a specific product to a specific crop. By querying the PUR database to identify and geolocate fields southeast of the aforementioned cross streets, it would be possible to determine who was applying the product to the specific crop within the same timeframe. In the future, WHS will use the overlaid pesticide illness and PUR data to focus outreach efforts by targeting areas experiencing higher rates of illness and catering outreach efforts toward contributing active ingredients and products.

PUR Data and Pesticide Use Enforcement In order to understand how PUR data is used at the local level by the County Agricultural Commissioners (CAC), it is important to understand the structure of California’s pesticide regulatory program, as well as CalAgPermits, California’s web-based system for submitting pesticide use reports. DPR, under State law and by delegation of authority by the U.S. Environmental Protection Agency (U.S. EPA) under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), is responsible for evaluating and registering all pesticides before sale or use in California, as well as for regulating and controlling their use. DPR works closely with the CACs to perform enforcement activities at the local level (2). This relationship between the state (DPR) and all 58 counties and their respective agricultural commissioners, has proven to be a necessary and successful structure for carrying out an effective pesticide regulatory program. In 2011, using residual mill funding from DPR, the California Agricultural Commissioner and Sealer Association (CACASA) contracted with a vendor to replace three legacy systems (including a MS/DOS-based program provided by the Department in 1990) for pesticide use reporting with a single statewide web-based system, CalAgPermits. CalAgPermits allowed all CAC staff to issue restricted material permits, operator identification numbers, and create GIS mapping for agricultural commodity production sites down to the field level. A core feature of the system was electronic acceptance of agricultural and non-agricultural PUR data from industry, and electronic transmittal of the data to DPR. CalAgPermits also greatly enhanced data quality assurance by automating data validation and error checking of submitted pesticide use reports before transmission to DPR. As part of the launch of CalAgPermits, CACs were encouraged to increase electronic submission of PUR data from growers and businesses into CalAgPermits. By 2015, more than 73% of over 3 million lines of agricultural PUR data were electronically submitted to CACs (note that each pesticide in a tank mix represents a single line of PUR data). With the GIS capabilities available through CalAgPermits, CACs can better use the operator and site identification numbers and PUR data for a variety of local regulatory tasks, including but not limited to, estimating how many acres of crops are grown in the county, the location of crops grown in the county, the location of pesticide applications in the county, which growers should get a crop survey, and 105


trends in local pesticide use (i.e. Why are there fewer Notices of Intent to apply restricted materials this year as compared to the previous three years?). The CACs also use PUR data when they conduct investigations into all allegations of pesticide misuse occurring in the county. These investigations may include illegal residues found on produce, pesticide drift complaints, complaints of crop loss due to pesticides, employee or bystander illnesses, and bee kills. The GIS capabilities of CalAgPermits, combined with electronic PUR data, are also critical in assisting CACs to determine what pesticides were applied near the site of the incident. In addition, PUR data is also an essential tool for both CACs and DPR’s Enforcement Branch staff to determine the effects a new law or proposed regulation may have on growers, and the potential increase or decrease in pesticide use or a switch to an alternative pesticide. Some examples of when PUR data can be used to evaluate the potential effects of new laws or proposed regulations include: • • •

A previously non-restricted pesticide becoming a California Restricted Material (i.e. Chlorpyrifos in 2015), Proposed restrictions in DPR’s suggested permit conditions for Restricted Materials (e.g., determining which commodities are impacted), or The new regulations related to pesticide use near schools (i.e. annual notification and ¼ mile buffer) (36, 37).

PUR data may also be used to assess the effects, specifically on pesticide use, of regulatory changes made by other state agencies such as California’s Regional Water Control Boards. DPR’s Enforcement Branch and the CACs also use PUR data to verify compliance with pesticide laws and regulations, including, but not limited to: •

Recordkeeping. Using PUR data to ascertain what pesticides are applied by a grower helps the CAC determine what records the grower or applicator are required to keep (38, 39). Knowing the types of pesticides a grower or business applies before a record inspection facilitates the inspection process. For example: •

•

Handler and fieldworker training, hazard communication and application-specific information (i.e. Do they apply pesticides themselves, or are all applications conducted by a pest control business? If they have handlers, are some applications unreported? What kind of application information is displayed for employees?) Organophosphate/carbamate employee exposure records and medical supervision (i.e., Do they apply Danger/Warning pesticides included in the cholinesterase monitoring program? Do they maintain the required records? Do their employees fall under the medical supervision program for cholinesterase blood testing?) (40) 106


•

•

•

•

•

•

Respiratory protection program requirements (i.e., Do they apply pesticides which require a respirator? What type of respiratory protection is required: filtering face piece, half-face, full face? Are the required elements of the respiratory protection program in place?) Pesticide use record keeping requirements, including applications by pest control businesses and fumigation management plans (i.e., If there are applications by a pest control business, does the grower maintain completion notices? Do they apply pesticides which require a fumigation management plan?) Pesticide storage requirements, including any Restricted Materials they may have in storage (i.e. What pesticides are expected to be present during a storage inspection?) Pest Control Advisor recommendations on file for applications of high-volatile organic compound non-fumigant products in a specific ozone Nonattainment Area (NAA) on specified crops from May 1 to October 3 (i.e., Has the grower applied any of specified pesticides during the given time frame and on listed crops?)

To assure compliance with quarantine requirements. Growers or shippers of nursery stock/other commodities from a quarantined area may be able to move their product from the quarantine area if they abide by the terms of a compliance agreement set by a regulatory agent (i.e. the CAC, the California Department of Food and Agriculture, an/or the US Department of Agriculture). These compliance agreements may include pesticide applications. CACs, who may not be physically presnt to witness the actual application, use PUR data to verify that growers or shippers complied with the terms of the agreement, and are allowed to move the commodity out of the quarantine area (41). To monitor pesticide applications near sensitive sites (including near cities, houses, schools, rivers or endangered species habitats).

PUR Data and Pest Management DPR’s Pest Management and Licensing (PML) Branch manages the Pesticide Use Report (PUR) database. Each year, PML scientists work with farm advisors and other experts to author a Pesticide Use Annual Summary Report which analyzes a variety of pesticide use trends over time. Farm advisors are integral in this analysis as they provide important insights on crop specific pest pressures, pesticide resistance, climatic conditions, crop economy, etc. that help explain pesticide use trends seen in PUR data. The annual report includes use trends a) by crops, b) of pesticides of regulatory concern, c) by county, and d) over time across the entire state. These analyses assist the Department in identifying areas with 107


the greatest use of higher risk pesticides, and facilitates the effective allocation of resources to promote reduced risk pest management solutions. PML scientists use the PUR database to identify areas in need of effective Integrated Pest Management (IPM) programs. This is accomplished by determining where the largest uses of higher risk pesticides occur, and then encouraging the use of reduced risk pest management practices, including IPM. These reduced risk pest management practices minimize economic, health, and environmental risks while still allowing effective management of pests. IPM combines biological, cultural, physical, and chemical tools and emphasizes an understanding of pest biology to allow the pest manager to determine a balanced pest management approach that combines multiple control methods (42). Voluntary adoption of IPM can reduce the use of high-risk pesticides without resorting to regulations (43). One of the many ways that DPR allocates resources to advance reduced risk pest management is through its grants, contracts, and the IPM achievement award programs. DPR’s IPM Research Grant funds research to develop IPM systems that can prevent the unanticipated effects of pesticide use on human health and the environment. Analysis of PUR data helps identify problem areas with the greatest need for research. Through these research grants, reduced-risk pest management strategies are developed, refined and incorporated into comprehensive and effective IPM programs (43–45). The Alliance Grant Program is complementary to the Research Grants Program as it promotes IPM systems through outreach and implementation. Key to the Alliance Grants Program is the formation of the “alliance”, a team of individuals representing state, local, public, private, educational, and other stakeholders collaborating on the project. Recipients of DPR’s Research Grants have the option to apply for an Alliance Grant to demonstrate and promote the adoption of the IPM system that they developed (43, 46). In addition to the IPM Research and Alliance Grant Program, DPR also establishes contracts, funds research projects, and coordinates working groups to address a wide variety of pest management issues (47). PUR data allows the Department to identify these issues related to crops (e.g. citrus, cotton, orchard crops, almonds), commodities (e.g. bedding and color container plants), specific pesticides (e.g. chlorpyrifos) or pesticide groups (e.g. fumigants) (48–55). Many of these contracts, projects and workgroups have led to research on newer, lower risk pest management techniques. An analysis of PUR data can help assess the potential effects of regulations on key stakeholders. One example of assessing effects would be the determination of effective buffer zone sizes based on spatial distribution and proximity of specific pesticide uses and potential vulnerable groups of concern. To assist with this task, new pesticide use information may occasionally be added to the pesticide use reports. For example, a fumigation methods data field was added to the PUR database in 2008 when the Department began requiring that PURs from ozone Nonattainment Areas (NAA) include fumigant application methods and emission mitigation strategies. These added fields allow the Department to monitor the use of fumigant pesticides that contribute to emissions of VOCs in these NAAs (56). 108


Similarly, with the passage of the Healthy School Act (HSA, AB 2260) in 2000, companies that applied urban and landscape pesticides on public K-12 school property were soon required to report details of each application to the Department. The School Pesticide Use Report (SPUR) Program began in 2002 and maintains a separate database solely intended for pesticide use reports on schools and child care facilities. The SPUR has the distinction of being the only PUR database in the nation that captures this specific information. DPR’s School and Child Care IPM Program uses SPUR data to fine-tune an outreach strategy to promote the use of effective reduced risk pest management at schools state wide. The SPUR Program is discussed in a separate chapter of this book.

Conclusion The California Department of Pesticide Regulation takes full advantage of the wealth of information found in the pesticide use reports that they are mandated to collect. In addition to determining pesticide use trends, the branches of the Department use PUR data in a variety of ways geared towards meeting their respective branch responsibilities and functions. These functions include environmental monitoring, human health assessment, protecting worker health and safety, pesticide risk mitigation, pesticide use enforcement, focusing outreach efforts, promoting research, and fostering reduced risk pest management. All of these functions directly or indirectly contribute to developing policy and regulation that help fulfill the Department’s mission to protect human health and the environment.

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