1. California Department of Pesticide Regulation 1001 I Street, Sacramento CA 95814 October 2015 1 Certification Phase Structural Fumigation Use Monitoring Inspection Training Module

2. WHO SHOULD TAKE THIS TRAINING? 2 This series of training modules is intended for County Agricultural Commissioner (CAC) staff who perform structural fumigation inspections. The procedures described in this presentation are intended solely for the guidance of employees of DPR and CACs. They do not constitute rulemaking by DPR. DPR and CACs may deviate from the procedures and guidance contained in the modules provided deviations do not conflict with law, regulation or policy. This guidance was developed in May 2015 after consultation with the Structural Pest Control Board. If you have any questions, please contact the Department of Pesticide Regulation, Enforcement Branch Liaison serving your county. The procedures described in this presentation are intended solely for the guidance of employees of DPR and CACs. They do not constitute rulemaking by DPR. DPR and CACs may deviate from the procedures and guidance contained in the modules provided deviations do not conflict with law, regulation or policy. This guidance was developed in May 2015 after consultation with the Structural Pest Control Board. If you have any questions, please contact the Department of Pesticide Regulation, Enforcement Branch Liaison serving your county. Structural Fumigation: Certification Phase

3. Inspection Procedures Manual (Vol. 4 of DPR’s “PUE Program Standards Compendium”) http://www.cdpr.ca.gov/docs/enforce/compend/vol_4/inspect_procedures.ht m 3 Before starting this module, have these three manuals available to consult: Before starting this module, have these three manuals available to consult: Laws and Regulations Relating to the Practice of Structural Pest Control (including Business and Professions Code; a convenient booklet format published by Structural Pest Control Board) http://www.pestboard.ca.gov/pestlaw/act.shtml Laws and Regulations (Vol. 2 of DPR’s “PUE Program Standards Compendium”) http://www.cdpr.ca.gov/docs/enforce/compend/vol_2/lawsregs.htm GUIDANCE AND REFERNCES Structural Fumigation: Certification Phase

4. 4 You will also need: Inspection form PR-ENF-107 (revised 1/2010) http://www.cdpr.ca.gov/docs/enforce/prenffrm/prenf107.pdf GUIDANCE AND REFERNCES Structural Fumigation: Certification Phase

5. 5 The three phases of a structural fumigation include: PHASES OF A STRUCTURAL FUMIGATION Structural Fumigation: Observing the Application Application Phase Aeration Phase Certification Phase

6. 6 CERTIFICATION PHASE #REQUIERMENT# 1Registered in county23Structure vacated/ secured against re-entry 2County notified 24 hours prior26Test equipment 7Labeling – Aeration/Certification27Re-entry requirements 8Labeling – bagging, pets removed28Direct supervision 15SCBA worn/ Cont. monitoring /CAP29Warning signs on all sides of structure 18Fume of enclosed spaces /proper entry30Required information on warning signs 19Proper management of treated area31Signs – attic/ under-area 20Connecting structures37Methyl bromide requirements * In total, there are 40 inspection requirements on the Structural Fumigation Use Monitoring Inspection Report form (PR-ENF-107, revised 01/2010) This Certification Phase training module covers 16* requirements on the Structural Fumigation Inspection Form: Structural Fumigation: Certification Phase

7. What and how to inspect: Check SPCB website; Review files at CAC office Structural Pest Control Business: Current company registration issued from SPCB? Registered with CAC prior to work in county? Individuals: Field Reps & Operators currently licensed by SPCB? Field Reps & Operators registered with CAC prior? 7 For more information: FAC § 15204.5 Enforcement letter ENF 07-31 & Addendum For more information: FAC § 15204.5 Enforcement letter ENF 07-31 & Addendum Requirement #1: Registered in county Structural Fumigation: Certification Phase Click for more info FAC 15204.5 (a) lists structural pest control applicators as having to register under Branch 1 requirements. BPC 8505.2 only allows structural pest control operators and field representatives to perform structural fumigations. BPC 8507.1(a) defines the scope of a structural pest control applicator license FAC 15204.5 (c ) requires “in person” registration. ENF 07-31 (pg. 3), and ENF 07-31 Addendum address “in person” registration (click to close)

8. Kilzall Brothers Pest Control SPCB Reg # PR-7777 879 Bug St., Ento City, CA 92234 (999) 222-0000 Qualifying Manager: Joe Kilzall, Address above SPCB License # OPR-9999 Issued: 7/1/2012 Requirement #1: Registered in county CAC Registration: Company CAC Registration: Licensees Jim Kilzall OPR-9998 Jerry Kilzall FR-2345 Jonnie Kilzall FR-1357 Kilzall Brothers Pest Control 879 Bug St., Ento City, CA 92234 (999) 222-0000 Answer: Yes, this registration is in compliance. For required info on registration form – FAC §15204.5(b) Is this registration in compliance (yes or no) ? 8 Structural Fumigation: Certification Phase

9. What and how to inspect: Review Notices of Intent (NOIs) at CAC office. Did the structural pest control company submit its NOI at least 24 hours prior to commencing fumigation? Certification jobs may be found from fume date on NOI: 3 days later, when aerated via CAP 2 days later, when aerated via SF labeling 9 Requirement #2: County notified 24 hours prior For more information: FAC § 15204.5(d) SF Labeling / CAP For more information: FAC § 15204.5(d) SF Labeling / CAP Structural Fumigation: Certification Phase

10. NOI faxed to CAC: Date: June13,13 Time: 4:30 pm Answer: No This NOI is missing the address of the structural pest control operator or company. The address is required by FAC §15204.5(d) Follow up with your supervisor: Based on the criteria in 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) what action (if any) should you take in response to this violation? Follow up with your supervisor: Based on the criteria in 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) what action (if any) should you take in response to this violation? Notice of Structural Fumigation To: Bestest County Ag. From: Kilzall Brothers P.C. Phone: 999-222-0000 Date: June 13, 2013 Fumigant: Vikane Site: 847 Pope St., Bestest City Fume date: June 15, 2013 Requirement #2: County notified 24 hours prior Is this in compliance (yes or no) ? 10 Click for more info Structural Fumigation: Certification Phase Only a single NOI is required (24 hours prior to the start of operations). There is no requirement for an additional NOI for the aeration phase or the clearance phase. (click to close)

11. Requirement #7: Labeling - Certification What and how to inspect: Clearing structure for Re-entry: After minimum 6 or 8 hours; SF Labeling After minimum 12 hours; refer to CAP Table 2 Concentration of SF monitored in “breathing zones” Breathing zones: areas within the structure where individuals typically stand, sit, or lie down Cleared for Re-entry when SF concentration < 1ppm 11 For more information: SF Labeling/ CAP/ 6780/ Check Inspection Procedures Manual For more information: SF Labeling/ CAP/ 6780/ Check Inspection Procedures Manual Structural Fumigation: Certification Phase

12. Requirement #7: Labeling - Certification 12 Answer: No No SCBA worn No SF detection device in hand Warning Signs: posted Question for your supervisor: Based on the criteria in 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) what action (if any) should you take in response to this violation? Question for your supervisor: Based on the criteria in 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) what action (if any) should you take in response to this violation? Structural Fumigation: Certification Phase Is this crew member in compliance (yes or no) ?

13. Requirement #8: Labeling–Bagging, Pets Removed What and how to inspect: Walk through after structure certified for re-entry Which brand of bags being used? Does SF labeling allow? Have items been removed or properly bagged to remain? What kitchen / pantry / bathroom items needed bagging? Mattresses / pillows in waterproof covers; how handled? Occupants/Neighbors notified to confine cats? What are the bagging exemptions? 13 For more information: SF Labeling / ENF 2010-21; 2005-05 / Inspection Procedures For more information: SF Labeling / ENF 2010-21; 2005-05 / Inspection Procedures Structural Fumigation: Certification Phase

14. Set 1: Set 2: 14 Question for your supervisor: Based on the criteria in 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) what action (if any) should you take in response to this violation? Question for your supervisor: Based on the criteria in 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) what action (if any) should you take in response to this violation? Depends on label Yes No Structural Fumigation: Certification Phase Requirement #8: Labeling–Bagging, Pets Removed Are these “sets” in compliance (yes or no) ? Set 3:

15. Requirement #15: SCBA / Continuous Monitoring 15 For more information: CAP / 3CCR § 6780(b) / SF Labeling Check Inspection Procedures Manual For more information: CAP / 3CCR § 6780(b) / SF Labeling Check Inspection Procedures Manual What and how to inspect: Precautions taken to prevent exposure? Is an approved continuous monitoring device being used? By a certified applicator? Ask licensee how fumigant levels are measured; If you suspect levels or protections not sufficient – have licensee test again Verify CAP procedures were followed correctly Structural Fumigation: Certification Phase

16. 16 Answers: 1 3 4 2 Yes: 1, 5 No: 2, 3,4 4 Reference for 1, 5? Purpose for 2 - 4? 5 Requirement #15: SCBA / Continuous Monitoring Structural Fumigation: Certification Phase Can this device be used to certify-(yes or no) ?

17. What and how to inspect: Unprotected employees are prohibited from entering a fumigated enclosed space unless SF is <1ppm 17 Requirement #18: Enclosed Space / Entry For more information: 3CCR § 6782(d) / SF Labeling re: aeration & reentry Check Inspection Procedures Manual For more information: 3CCR § 6782(d) / SF Labeling re: aeration & reentry Check Inspection Procedures Manual Structural Fumigation: Certification Phase Is approved SF detection device on site? Does licensee know how to use it? Is device calibration current? Is device listed on SF labeling? Is respiratory equipment listed on SF labeling? What is purpose for entering enclosed space?

18. 18 Requirement #18: Enclosed Space / Entry Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take in response to this violation? Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take in response to this violation? 1.Yes, licensee checking concentration using Interscan 2. No, employees are in enclosed space without SCBA or continuous monitoring device Are these in compliance (yes or no) ? 1 2 Structural Fumigation: Certification Phase

19. What and how to inspect: After completion of the fumigation: How does the licensee prevent employees from entering the structure prior to it being certified safe to reenter? What precautions are taken to protect employees from being exposed to a concentration in excess of the Permissible Exposure Limit (PEL)? 19 Requirement #19: Proper Management of Treated Area For more information: 3CCR § 6782(f) Check Inspection Procedures Manual; SF Labeling For more information: 3CCR § 6782(f) Check Inspection Procedures Manual; SF Labeling Structural Fumigation: Certification Phase

20. 20 Requirement #19: Proper Management of Treated Area Answers: 1) Yes, employee wearing SCBA to repair blowout 2) No, employee entering post fume, prior to clearance Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) What action (if any) should you take for this violation? Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) What action (if any) should you take for this violation? Employee entering; Signs up 1 2 Are these employees in compliance (yes or no) ? Tarps dropped; unknown PEL Structural Fumigation: Certification Phase

21. What and how to inspect: Is the fumigated structure connected to any nearby structure via construction elements, drains, conduits, or vacuum systems that could allow the fumigant to enter? 21 Requirement #20: Connecting Structures For more information: 16 CCR § 1970.6 / FAC § 12973 Check Inspection Procedures Manual For more information: 16 CCR § 1970.6 / FAC § 12973 Check Inspection Procedures Manual Licensee should have checked prior to fumigation, but for safety, you should double-check at aeration. If so, is the nearby structure being aerated? Structural Fumigation: Certification Phase Click for more info Conduits The fumigated structure should be inspected for pipes, conduits, ducts, or others features which would result in fumigant loss outside of the fumigated space. These features should be sealed to stop excessive gas loss. (click to close)

22. 22 Requirement #20: Connecting Structures Answers: Depends 1. Any conduits identified between house and garage? 2. Is drain at the gutter connected to the fumigated home? Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), What action (if any) should you take for this violation? Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), What action (if any) should you take for this violation? Is this in compliance (yes or no) ? Click for more info 1 2 How do you know what might be connected? How can you tell which drain system belongs to the fumigated structure? How do you determine that the fumigator asked the right questions? (click to close) Structural Fumigation: Certification Phase

23. 23 Requirement #20: Connecting Structures Examples Structural Fumigation: Certification Phase Click for more info Conduits The fumigated structure should be inspected for pipes, conduits, ducts, or others features which would result in fumigant loss outside of the fumigated space. These features should be sealed to stop excessive gas loss. (click to close)

24. 24 Requirement #20: Connecting Structures Examples Structural Fumigation: Certification Phase

25. Requirement #23: Structure Vacated/Secured What and how to inspect: 25 For more information: BPC § 8505.7 / CAP / SF Labeling Check Inspection Procedures Manual For more information: BPC § 8505.7 / CAP / SF Labeling Check Inspection Procedures Manual Entry, illegally, into fumigated structures has risen Longer aeration period of opened windows (CAP Sophistication of burglars – Masks, SF dissipated Entry during dark; from hidden side Structural Fumigation: Certification Phase Secondary locks bypassed; forced entry; other Ask licensee what extra security measures are in place – alarms, lights, guards, pic dosage at higher allowable rate

26. 26 Requirement #23: Structure Vacated/Secured Question for supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for this violation? Question for supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for this violation? Answers: 1. No, pet door not secured 2. No, opening 3” minimum, but not secured 3. No, secondary lock allows gap; door not used as airway Are structures in compliance (yes or no) ? Structural Fumigation: Certification Phase 1 23

27. Requirement #26: Test Equipment What and how to inspect: Review SF Labeling prior to inspection: What SF detection (test) equipment is specified? Is equipment calibration current? What is the proper way to use equipment? Have licensee: Demonstrate proper use of equipment Provide current calibration documentation 27 For more information: 16CCR § 1970.6 / FAC § 12973 Check Inspection Procedures Manual For more information: 16CCR § 1970.6 / FAC § 12973 Check Inspection Procedures Manual Structural Fumigation: Certification Phase

28. 28 Answers: Yes 1.Interscan warmed up; “ready” light on; <1ppm calibration current 2. Spectros SF-ExplorIR “ready” held at waist in Breathing Zone 1 2 Structural Fumigation: Certification Phase Requirement #26: Test Equipment Are these in compliance (yes or no) ?

29. Requirement #27: Re-entry Requirements What and how to inspect: After structure is cleared, licensee must: Post “Notice of Re-Entry” Posting must be placed at main entry 29 For more information: 16 CCR § 1973 SF Labeling Check Inspection Procedures Manual For more information: 16 CCR § 1973 SF Labeling Check Inspection Procedures Manual Structural Fumigation: Certification Phase

30. Answer: No 1.Completeness ? 2.Colors? 30 Question for supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for this violation? Question for supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for this violation? Requirement #27: Re-entry Requirements Structural Fumigation: Certification Phase Are this notice in compliance (yes or no) ?

31. What and how to inspect: 31 Structural fumes require direct supervision: By licensed Branch 1 OPR or FR On-site During clearance of structure for re-entry Requirement #28: Direct Supervision For more information: CAP: B & P Code 8505.2, and 8505.3 SF labeling: BPC 8505.2/16 CCR 1970.5 Inspection Procedures Manual entry for this requirement. For more information: CAP: B & P Code 8505.2, and 8505.3 SF labeling: BPC 8505.2/16 CCR 1970.5 Inspection Procedures Manual entry for this requirement. Structural Fumigation: Certification Phase Click for more info BPC § 8505.2 requires that structural fumigations only be performed under the direct and personal supervision of a Branch 1 operator (OPR) or field representative (FR) licensed by the SPCB. “Direct and personal supervision” means that the licensee responsible for the supervision shall be present at the site of the fumigation during the entire time the fumigants are being released, the time the ventilation is commenced, and at the time property is released for occupancy. (click to close)

32. 32 Answer: Yes Image meant to convey presence of licensee during key elements of certification process Is Direct Supervision in compliance (yes or no) ? Requirement #28: Direct Supervision Structural Fumigation: Certification Phase

33. What and how to inspect: 33 Requirement #29: Warning Signs – all sides For more information: 16CCR § 1974 Check Inspection Procedures Manual for posting specifics For more information: 16CCR § 1974 Check Inspection Procedures Manual for posting specifics Prior to commencing fume, post warning signs: On structure On tarps At all joint seams Are warning signs posted at required locations? Are warning signs too weathered to read? Torn? Posted for required duration? Visible? Any missing? Structural Fumigation: Certification Phase Click for more info Warning signs posted: On structure, under tarps, until structure is posted safe for re-occupancy On each side of structure, at or near all entrances On tarps, visible from all accessible sides of structure, from any direction site is approached, At all joint seams of tarp at 1st floor level. (click to close)

34. 34 Question for supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for the violation? Question for supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for the violation? 1. Warning sign not readable. What about others? 2. Window is not an entrance; placement of other signs? Answer s: Depends 1 2 Requirement #29: Warning Signs – all sides Are these signs in compliance (yes or no) ? Structural Fumigation: Certification Phase

35. What and how to inspect: 35 Requirement #30: Information on Warning Signs For more information: B&P Code § 8505.10 / *16CCR § 1974(c) Check Inspection Procedures Manual For more information: B&P Code § 8505.10 / *16CCR § 1974(c) Check Inspection Procedures Manual Warning Signs: specific dimensions, colors, statements, and images In addition to English, is Spanish required? Do letters / images meet required height? Color? Warning Signs shall include specific information Include fumigant trade name & active ingredient? Fumigator info complete? “Time shot” included? Difference between signs on structure vs on tarp? Structural Fumigation: Certification Phase Click for more info Note: 16CCR 1974(c) is not in the 2010 Structural Act. It can be found on SPCB’s website: http://pestboard.ca.gov/pestlaw/pestact.pdf http://pestboard.ca.gov/pestlaw/pestact.pdf Neither BPC 8505.10 nor 16CCR 1974 require inclusion of Spanish text on the Warning Sign; however, the sign image included in the regulation is enforceable. The image contains the text required to be in Spanish. Companies can include other text in Spanish. (click to close)

36. 36 Requirement #30: Information on Warning Signs Answer: Yes Time not required on signs placed inside a tarp Signs must remain posted until structure cleared for Re- Entry Datelisted Time Not Given Is this Warning Sign in compliance (yes or no) ? Structural Fumigation: Certification Phase Click for more info BPC 8505.10 requirements: 1)Warning sign (letters/images) printed in red on white background 2)Contains “Danger-Fumigation” statement 3)Danger-Fumigation statement is >2” tall 4)Skull & Crossbones present 5)Skull & Crossbones >1” tall 6)Fumigant name present 7)Date present 8)Item 6 & 7 letters >.5” 9)Registered company name 10)Registered company address 11)Registered company phone numbers (day & night) 12) Items 9, 10, 11 letters >.5” *13) Time fumigant introduced (shot) – Not Required since sign is obviously posted on the structure (underneath the tarp). Time is required on Warning Signs posted on the fumigation tarp. (click to close)

37. Requirement #31: Signs – Attic / Under- area What and how to inspect: After structure cleared: Licensee must post: Durable Sign; > 5” x 7” Adjacent to entrances of Attic & Sub-area 37 For more information: BPC 8505.11 / 16CCR 1996.1 For more information: BPC 8505.11 / 16CCR 1996.1 Structural Fumigation: Certification Phase Signs to include: Company name Date of Fumigation Fumigant used & Brand

38. Requirement #31: Signs – Attic / Under- area 38 Answers: Yes: 1, 3 No signs required: no attic or sub-area No: 2 No sign adjacent to attic entrance 1 2 3 2 View Inside: Attic Floor Question for supervisor: Based on §6128 & §6130, or §1922, what action (if any) should you take for this violation? Question for supervisor: Based on §6128 & §6130, or §1922, what action (if any) should you take for this violation? Structural Fumigation: Certification Phase Are these in compliance (yes or no) ?

39. The use of Methyl Bromide (MB) is a rare occurrence. Not applicable would be checked on the inspection form if MB is not used. If MB is used, consult with your supervisor. 39 For more information: 3CCR 6454 Inspection Procedures Manual For more information: 3CCR 6454 Inspection Procedures Manual Requirement #37 Methyl Bromide Requirements Structural Fumigation: Certification Phase

40. 40 CONGRATULATIONS! * In total, there are 40 inspection requirements on the Structural Fumigation Use Monitoring Inspection Report form (PR-ENF-107, revised 01/2010) * In total, there are 40 inspection requirements on the Structural Fumigation Use Monitoring Inspection Report form (PR-ENF-107, revised 01/2010) #REQUIERMENT# 1Registered in county23Structure vacated / secured 2CAC - 24 hour prior notice26Test Equipment 7Labeling - Aeration27Reentry Requirements 8Labeling - Bagging28Direct Supervision 15SCBA / monitoring29Warning signs – all sides 18Enclosed space / entry30Required info warning signs 19Management of area31Signs – Attic / Sub-area 20Connecting structures37Methyl Bromide Requirements Structural Fumigation: Certification Phase You have completed the Certification Phase training module that covers 16* requirements on the Structural Fumigation Inspection Form:

41. Common Violations to look for: Secondary locks: missing, not secured Warning signs: missing, incorrect info Continuous monitoring equipment: not calibrated, used incorrectly Unbagged food/medicinals: check labeling “Notice of Re-Entry:” pre-posted, incomplete, incorrect Attic / Sub-area Completion signs: not posted, incorrect, incorrect version (check form date) 41 Structural Fumigation: Certification Phase

42. California Department of Pesticide Regulation 1001 I Street, Sacramento CA 95814 October 2015 42 FOR MORE INFORMATION, CONTACT: Structural Fumigation: Certification Phase