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Emerging Issues in Structural Regulatory Enforcement

Emerging Issues in Structural Regulatory Enforcement. DPR Structural Regulatory Training Pomona CA, 14 June 2012. Mike Zeiss Enforcement Branch, DPR mzeiss@cdpr.ca.gov. You mean the regulations change ? ! ?. Yes - - keeping current is part of the job. Sources of information about

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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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