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

2. 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

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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

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

14. 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

15. 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

16. 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

17. 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

18. 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

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

20. 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

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

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

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

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

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

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

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

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

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

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

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

32. 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

33. 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

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

35. Suitable Methods / Manner / Climate 3CCR 6600
Requirement 26

36. Suitable Methods / Manner / Climate 3CCR 6600
Requirement 26

37. “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”

38. 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”

39. “Exempt” or “Unregistered” ??
Phyta-Guard®
Citronella Natural Insecticide
/ Repellent Oil
ACTIVE INGREDIENTS:
Soybean Oil %
Citronella %
INERT INGREDIENTS:
Lecithin %
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)

40. Questions ?