FAQ

Questions and answers from trainings, emails, and phone calls

If your specific question is not among the following please email OPIC@ucanr.edu. 

1. Is the “UC Pesticide Policy Annual Training” a required training for UC personnel applying pesticides for research or demonstration?

No. The training is not required. However, a full and complete understanding of the “Policy on Pesticides and Related Chemicals: Use & Experimentation,” Section 281 of the UC Agriculture and Natural Resources Policy & Procedure Manual is required for all employees applying pesticides for demonstration or research. The training covers the complete policy and offers three hours of continuing education credits.

2. What are the differences between a Qualified Applicator Certificate (QAC) and a Qualified Applicator License (QAL)?

A QAL is required only if you wish to be the qualified person for a pest control business. Either a QAC or a QAL with a relevant subcategory should allow you to supervise or perform whatever applications of restricted pesticides are required for your research. Application fees and renewal fees are also lower for a QAC versus a QAL, but both licenses require the same amount of Continuing Education Units (CEUs) for renewal. 

3. If I have a QAL or QAC, can I be in an area (field, orchard, etc.) that is actively being treated with pesticides? What if I am in the same area but a large distance away from the application?

Yes, but you should avoid entering the area being treated unless you are directly involved with the pesticide application. If you have another very good reason to enter the area, wear personal protective equipment as if you are involved in the pesticide application, not just what a fieldworker would wear. Fieldworkers should not be in the field or orchard during an application no matter how far away they are, so you also should not be anywhere in the area without the proper protection.

4. Do I need a research authorization or experimental use permit to field test genetically transformed insects carrying a knockout gene and using CRISPR-CAS9?

Yes. The University of California exemption to the requirements of research authorization and experimental use permits do not apply in this case. You will need to consult the Coordinated Framework to determine which federal agency will need to be consulted in obtaining permission. At the very least, USDA-APHIS will need to issue a permit for this release. In addition, you will want to coordinate the release with the California Department of Pesticide Regulation to obtain the appropriate permissions. Finally, it probably would not hurt to let your county agricultural commissioner's office know about the release as well.

5. Where do I get pesticide safety training?

Your supervisor is responsible for providing annual training by a qualified trainer. UC ANR provides pesticide safety training for supervisors (train-the-trainer) and information about these sessions is available at http://ipm.ucanr.edu/IPMPROJECT/workshops.html#DPR. Additionally, the California Department of Pesticide Regulation has a list of train-the-trainer workshops throughout the state (available at https://www.cdpr.ca.gov/docs/whs/trainers.htm).

6. Can I use a Ziploc™ bag to carry small measures of pesticides to field plots?

No. You may not place pesticides in any food container. There are other types of resealable containers that are made for non-food items that are allowable.

7. Can I use an ice chest to protect pesticide containers in the back of my pick-up truck?

No. An ice chest is a food container. Therefore, this is not allowed because it could become contaminated with pesticide residues. There are other types of plastic storage containers available that are not designed for food.

8. Do I have to follow buffer zone requirements for experimental plots on or off UC property?

Yes, all label or regulations requirements must be followed related to buffer zones.  However, you may be able to obtain a waiver from the buffer zone requirements for small amounts of fumigants or small plots from the local county agricultural commissioner.

9. What type of label do I need to put on rodent or insect bait stations containing a toxicant?

Whether it is a ground squirrel or an ant bait station, if you can open it to fill it with a pesticide, the bait station is considered a service container. The only bait stations that do not require labeling are bait stations used by farmers on their farm property, and manufacturer sealed bait stations.

According to CCR Section 6678, service containers must be labeled with the following:

1. The name and address of the person or firm responsible for the container.
2. The identity of the pesticide
3. Signal word ("Danger", "Warning" or "Caution") in accordance with the label on the original pesticide container.

10. What is the UC policy for use of potential groundwater contaminating chemicals?

A Research Authorization is required for atrazine, bentazon, bromacil, diuron, norflurazon, prometon and atrazine.  See CCR Section 6800(a) for any additional materials added to the list. This requirement applies to any UC conducted research on or off UC property.

11. Who needs to be licensed as a Qualified Applicator?

Anyone supervising the use of pesticides and/or handling pesticides.  UC policy recommends that researchers and their technicians obtain a Qualified Applicator Certificate in the Research and Demonstration category.

12. Where do I get fit tested for respirators?

Contact your unit’s safety coordinator.  He or she can either provide the fit testing or direct you to someone who can.

13. How much wash water is required to be on-site?

U.S. EPA guidelines recommend at least three gallons of water for each handler. The employer must determine how much water is sufficient.

14. What do I do if I suspect someone may be poisoned by exposure to pesticides?

Seek immediate medical treatment. Do not let the exposed person drive himself or herself for medical attention. Decontaminate the person with water and/or by removing contaminated clothing.  Read the label for first aid procedures. Do not induce vomiting, unless the label states. Take the label, but not the container, to the medical facility or provide to responding EMTs.

15. Where can I find information on the impacts of pesticides on beneficial insects?

The UCIPM web site has data in the Pest Management Guidelines for each crop: http://www.ipm.ucdavis.edu/PMG/crops-agriculture.html

16.  What are the requirements for using cultured native single celled microorganisms in pest control experiments?

The use of microorganisms for pest control experiments follows the same rules as those applicable to the use of conventional pesticides.  (This would not be true if they were genetically modified.)  Therefore, the UC Policy on Experimental Use of Pesticides applies to this type of research. A Research Authorization is not needed from DPR or a EUP from the USEPA.  You do have to follow crop destruct rules.  This means that any use will have to be designated for crop destruct.  There are no exceptions to this unless the material has EPA registration and has been fully characterized and given a tolerance or exemption from tolerance.  If the application is made to a grower's field, you will have to notify the CAC with the “Pesticide Application and Notification Requirements for Trials Conducted off University Property form.”

17. We have identified at least three parasitic nematodes that could be applied in a soil drench or through irrigation systems. What is the registration needs or federal tolerances?

Non-genetically engineered multi-cellular organisms are not regulated by EPA or Cal-EPA. There are no registration requirements. Importing exotic nematodes would require appropriate permits from APHIS and, possibly CDFA.

18. What requirements are in place for using a single celled organism, Bacillus popilliae, which could be applied in the soil, and would be alive?

Bacillus popilliae is a single cell organism and when used as a pesticide does require EPA and Cal-EPA registration. Currently, there are no products containing this active ingredient registered in California. B. popilliae is exempt from tolerance requirements. Therefore, conducting research on any crop under the UC guidelines is permitted without worry of crop destruct.

19. We need to test Admire (imidacloprid) as a soil drench or irrigation treatment on almonds.  There is a federal tolerance, but am sure the application method is not registered (soil injection). Is there a limit on the acreage or what we can do?

Under UC guidelines, you may conduct research with materials using methods not on the registered label. There is a tolerance of 0.05 ppm for almond nuts and 4.0 ppm for almond hulls for imidacloprid. As long as these tolerances are not exceeded, crop destruct is not necessary. Post harvest applications of imidacloprid should not result in illegal residues the following year. There is a 100 acre limitation for products federally registered, but not California registered.

20. Is it legal to use food coloring in pesticide mixes to determine coverage?

Yes.

21. A prune grower in Yuba County is interested in learning more about the use of titanium ascorbate as a foliar fertilizer.  If I could find a source of this material, can I use it on prune trees in California?  Would this be crop destruct? 

Since this material will be used as a nutritional supplement and no pest control is expected or intended, it does not fall under the category of a pesticide.  Therefore, there is no requirement for tolerances and crop destruct would not be required.

Commercial fertilizers must be licensed in CA through CDFA.  I don't think that you would have any problems doing a research plot with an unlicensed mineral supplement.  However, it would be best to either make sure the product is licensed (if it is commercially sold in CA) or clearly identify the material as experimental and not for sale.

22. Do I have to destroy ornamental crops experimentally treated with an unregistered pesticide?

No, as long as there is no possibility that plant parts would be used for animal feed. 

23. Do experimental plots using fumigants require a research authorization from DPR?

No.  However, it may be useful to obtain a RA in circumstances that would provide documentation to a professional applicator that an off-label use is okay.          

24. If U.S. EPA has registered a pesticide product and established a tolerance, but the product is not yet registered in CA, is crop destruct required?

No.  When the U.S. EPA registers a product for food uses, they establish a pesticide tolerance. This tolerance is valid for any legal use of the active ingredient. Experimental uses are legal and as long as the commodities do not contain residues higher than the tolerance, the product may enter the channels of trade, regardless of the status of registration in California. Be sure that the cooperator understands that s/he may not use the product for routine pest control until DPR issues a license for sale of the pesticide in California.

25. What are the pesticide use reporting requirements when conducting experimentation/research on and off Davis campus property?

Each department using pesticides on the Davis campus must complete and return the State of California Monthly Summary Pesticide Use Report to the Yolo or Solano County Agricultural Commissioner's Office by the tenth of each month following application. For other locations, report via applicable Research and Extension Centers or county offices.

The above clarifies reporting requirements for uses on UC property.  For use on cooperators' property, the landowner is responsible for reporting uses made under "research commodity" when a tolerance does not exist or under the crop name, if the use is labeled.

26. May a holder of a QAC in Plant Agriculture apply maintenance insecticides in a building?

Yes, as he or she is not required to be licensed as long as the materials to be sprayed are not “restricted use.” If the materials are “restricted use” the employee must have a QAC in the Residential, Industrial, Institutional category.

A license is not required for an employee to apply a non-restricted pesticide in normal pest control situations.  He or she is required to be trained prior to handling any pesticide and have annual pesticide training. 

27. If counties have "extra" requirements for treated field posting (e.g. Monterey) are these requirements applicable to UC research plots?

Yes.

28. Are closed systems required for category 1 non-liquid pesticides?

No.  However, some devices allow metering of measured amounts of gopher baits or zinc phosphide pellets.  These devices are not considered “closed systems” as defined for liquid pesticides.

29. Is it legal to kill burrowing rodents with vehicle exhaust?

No. California Penal Code Section 597u prohibits the killing of any animal with carbon monoxide.

30. What is the definition of a greenhouse?

A greenhouse is defined as a structure or space, of sufficient size to permit entry, that is enclosed with a nonporous covering and used in the commercial or research production of an agricultural plant commodity. A structure constructed of porous cloth or other porous material is not considered a greenhouse. If a greenhouse has sides or significant portions of the structure removed during the application and the restricted entry interval (REI), it is not considered a greenhouse. Simply opening doors or windows does not alter the structural status as a greenhouse. ENF 97-076 Questions Regarding Implementation of the Amended California Worker Safety Program Questions 7-9.

31. Are particulate masks considered respirators?

The short answer is “yes” they are considered respirators.  However, the requirements for medical supervision vary between mandatory use (on the label) and voluntary use.  If the label requires the use of a particulate respirator all the general requirements for medical review and fit testing are required.  If the user wants to wear one because of dusty conditions the following is straight out of the new regulations:

“Under the employer-supplied voluntary respirator provision, the employer shall establish and implement the provisions of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. Employers are not required to include a written respiratory protection program for those employees whose only use of respirators involves the voluntary use of filtering face pieces (dust masks).”