Structural Branch 2 & 3 Inspection Form 108 Dan Weerasekera DPR Southern Regional Office

Structural Branch 2 & 3 Inspections Reference the Inspection Procedures Volume 4 Discus CCR 8505 household pest When to use Form 108 vs. Form 104 Br 2 - General Pest Br 3 - Termites

Pesticide Use Enforcement Compendium – Volume 4 Inspection Procedures Chapter 8 Discuss the importance of the completely and accurately completing the header information.

Annual Registration: FAC 15204 Required for Structural PCBs: Annually, & prior to doing pest control work* in each county For pesticide applications Non-pesticide methods (Definition: BPC 8505) All structural pest control companies must be registered with the SPCB and the CAC prior to conducting structural pest control work in the county. This include non pesticide methods such as structural repairs and replacement due to household pest, use of mechanical devices to eliminate, exterminate, control or prevent infestations. Requirement #1

Written Notice to Occupant: BPC 8538 All pesticide applications by a SPCB registered* structural PCB To owner/agent and occupant Prior to application For Periodic Service Contracts Only prior to initial treatment Interview the occupant if possible to determine compliance. If no occupant available ask the Licensee how notice is given. Requirement # 2

Written Notice to Occupant Must Include Info / How Provided: Pest to be controlled Pesticide(s) to be used/Active Ingredient For contracts – Frequency of Service (Treatment) By first class mail or Posting in a conspicuous place or Personal delivery Commercial or Industrial buildings notice posted in a conspicuous place Multiple dwellings with more than 4 units notice posted at in heavily traffic areas such as mailboxes, laundry rooms, community rooms Multiple dwellings less than 5 units – each unit must be notified. Any pest control done within a tenant’s unit requires direct notification to the tenant. Requirement # 2

Pesticide Disclosure Available: 16CCR 1970.4 (c) – (e) Leave in a conspicuous place Common, generic, or chemical name of each pesticide applied Via: Door hanger, invoice, or billing statement w/company contact information Multi-family structure: to owner or designated agent & posted Applies to all Branch 2 and 3 companies Requirement # 3

Registered Label @ Use Site: 3CCR 6602 Binder in vehicle / on container Substantially similar to the registered label “Specimen Label” Discuss the difference between label and labeling. This requirement also include supplemental labeling, SLN or Section 18 directions. Also could be technical manuals. Commercial advertising does not comply with the requirement even if it contains use directions. Requirement # 4

Labeling: site/rate/conc./other FAC 12973 Watch for label statements “such as”, or “for exterior use only” or “including, but not limited to…” Label requirements can change from time to time so…Ask the handler how much and for what pest, etc. AND read the label Watch for “double mixing” or applying too frequently; spot vs. broadcast spraying Requirement # 5

Label – PPE 3CCR 6738 & 6739 Employer shall provide Protective eyewear Gloves Footwear – chemical resistant Respirators Label required PPE applies to all persons including employers. According CCR 6601, PPE maintenance and storage also applies to everyone including non employees. Requirement # 6

Label – PPE 3CCR 6738 & 6601 Label required PPE applies to everyone Maintenance and Storage standards outlined in regulations applies to everyone per CCR 6601 Requirement # 6

Regulation- specific PPE: 3CCR 6738 Protective eyewear required Mixing, loading, adjusting, cleaning Hand-held equipment Ground application If not label specified, choices = Safety glasses Goggles Face shield Full face respirator Requirement # 7

Regulation- specific PPE: 3CCR 6738 Gloves Mixing, loading adjusting, cleaning Hand held equipment If not label specific Rubber Neoprene Other chemical-resistant Requirement # 7

Respiratory Protection: 3CCR 6739 When required by: Label Regulation Employer Appendix 1 of the Inspection Procedures Manual Verify employees have been provided and are using the appropriate type of respirators as identified in the label. Verify the respirators are appropriately maintained. Requirement # 8

Handlers Trained: 3CCR 6724 Observe how they: Ask open ended questions Mix/Load Apply or Handle Ask open ended questions When How What would you do if…? Certified Applicators are considered trained, check “YES” in the requirement section, per CCR 6000 FR and OPR are considered trained. Observe the applicator, any concerns conduct a HQ and Safety Inspection. Requirement # 9

Emergency Medical Care: 6726 At Work Site: Name Address Phone number Nearest hospital In binder, open? In wallet? Posted In vehicle? Apply to all employees handling pesticides Emploiees working in a wide geographical area Calling 911, Supervisor or Poison Control Center is inadequate Requirement # 10

Decontamination Facility: 6734 Pesticides: “Danger” & “Warning” Signal word Within 100 feet of Mix/load site Applies to Non Ag setting. Must have Suffiecent water, soap, single use towels and one clean change of coveralls USEPA recommends at least 3 gallons of water provided to each handlers – water quality, temperature that would not cause illness or injury Requirement 11

Safe Equipment: 3CCR 6742 Openings on tanks shall have covers that prevent spills and splashes Applies to all employees that use equipment to apply or mix load pesticides Three requirements: proper tank cover (all applications and mix load) shut off devices (mix / load Warning and Danger material pesticides) sight gauge ( mix / load Warning and Danger material pesticides that has a tank capacity over 49 gallons Check “NA” if no equipment is used Requirement 12

Coveralls: 3CCR 6736 Employees “Danger” or “Warning” signal words Can be 1 or 2 piece Requirement 13

Certified Applicator Supervising Restricted Materials: 3CCR 6406 Federal & California RMs Availability of the certified applicator shall be related to the actual or potential hazard Physical and visual presence Requirement 14

Accurate Measurement: 3CCR 6604 Calibrated to the smallest unit in which the pesticide is being weighed or measured - estimates - uncalibrated - unmarked Requirement 15

Protection of Person / Animals/Property: 3CCR 6614 Requirement 16

Backflow Prevention Air Gap 3CCR 6610 Draw water from an outside source Double check valve Requirement 17

Equipment Identified: 3CCR 6630 Engaged for Hire - pest control Business Name Licensed Pest Control Operator Signs readable from 25 feet Requirement 18

Containers Labeled / Securely Closed: 3CCR 6676 Registrant’s label Lids securely tightened When stored or transported Requirement 19

Service Container Labeling: 6678 Name and address of responsible party Identity of the economic poison Signal word Requirement 20

Proper Container: 3CCR 6680 No pesticide shall be in: Food Drink Household product Requirement 21

Proper Pesticide Transport : 3CCR 6682 Not in the same compartment with: People / pets or Food or Feed Requirement 22

Proper Pesticide Transport : 3CCR 6682 Secured to prevent spillage Covered to protect against moisture Requirement 22

Containers Properly Rinsed: 3CCR 6684 All containers Except refillable containers Triple rinsed at time of use Rinsate in spray tank Requirement 23

Pesticide Handling / Use / Storage : 16CCR 1983 Properly: out of reach of children labeled/stored Bait station Oil based insecticide near flames Requirement 24

Wellhead Protection : 3CCR 6609 Within 100 feet of a well No mixing, loading or storing any pesticides No rinsing of spray equipment or pesticide containers No maintaining equipment that could spill pesticides UNLESS Slope, berm Requirement 25

Suitable Methods / Manner / Climate 3CCR 6600 Each person performing pest control: Use Equipment in Good Repair Careful and Effective Manner Methods and Equipment Suitable Suitable Climatic Conditions Requirement 26

Suitable Methods / Manner / Climate 3CCR 6600 Leaks Worn hoses Requirement 26

Suitable Methods / Manner / Climate 3CCR 6600 Requirement 26

Suitable Methods / Manner / Climate 3CCR 6600 Requirement 26

“EXEMPT” Pesticides FIFRA 25b / CCR 6147 Label Requirements Active Ingredients (A.I.) & Minimal Risk Inerts (4A) to qualify for “exempt from registration” status per US EPA Federal tolerance (or exemption) for use on food products Label Requirements List all A.I. & % by weight for each All inerts listed No comparisons to other pesticides, no efficacy claims No claims “endorsed by govt agencies as safe or nontoxic”

Inappropriate label claims “EXEMPT” Pesticides Inappropriate label claims “EPA approved as safe & non-toxic to humans/pets” “Controls pests as effectively as more toxic pesticides” Exempt products can’t state any claim linking control of a pest and/or microorganisms to implying a threat to human health/disease “Repels Mosquitoes that transmit malaria” “Also repels ticks that cause Lyme Disease”

“Exempt” or “Unregistered” ?? Phyta-Guard® Citronella Natural Insecticide / Repellent Oil ACTIVE INGREDIENTS: Soybean Oil . . . .. . . . . . . . . 45.0% Citronella. . . . . . . . . . .. . . . 40.0% INERT INGREDIENTS: Lecithin . . . . . . . . . . . . .. . . 15.0% CAUTION: KEEP OUT OF REACH OF CHILDREN Use eye protection and gloves. Harmful if swallowed. Avoid breathing spray mist. May cause irritation of nose… It’s unregistered if: Doesn’t list all inerts Active Ingredient(s) NOT on 25b approved list Any public health or disease control claims Doesn’t meet other specific requirements (see section 6147)

Questions ?