UC DANR Pesticide Use and Experimentation

1
UC DANR Pesticide Use and Experimentation

• Rick Melnicoe
• Statewide Pesticide Coordinator
• [phone]
• rsmelnicoe_at_ucdavis.edu

2
Ethical Considerations Rights and
Responsibilities

• Research rights
• As a land grant institution UC has a mandate to
  conduct agricultural research.
• Academic researchers granted the right to conduct
  hazardous chemical research on UC and
  cooperators property.
• Research responsibilities
• To do no harm
• To conduct intellectually honest research

3
Pest Management Chemical Experiments Create Risks
and Potential Liabilities

• Risks
• To Cooperators
• To Consumers
• To the University
• Reputation
• Research rights
• Liabilities
• Individual researcher
• County, DANR and UC

4
Policy on Pesticides and Related Chemicals Use
and Experimentation

• Applies to UC Division of Agriculture and Natural
  Resources.
• All research, published pest management
  guidelines and recommendations relating to
  pesticide use are to be conducted in accordance
  with all applicable laws and regulations.

5
Exemption of UC from Obtaining Written
Authorization

• Title 3, California Code of Regulations (CCR),
  Section 6268, Research Authorization
• University employees are exempt, providing UC has
  a policy covering experimental use which has been
  approved by the Director of DPR.
• UC has such a policy.

6
Scope and Definitions

• Policy applies to all employees of DANR who use
  or handle pesticides for experimental purposes.
  Applies to experimentation with pesticides or
  related substances in any field test or field
  demonstration.

7
Where Does this Apply?

• On any Campus
• On Field Stations
• On Agricultural Research and Extension Centers
• On any other land or treated site (including
  livestock) when used in experimental pesticide
  research field trials and demonstration
  operations that are activities of the University.

8
Noncompliance

• Will result in the loss of the exemption provided
  under Title 3 CCR, Section 6268.
• May be deemed a violation of Section 6260.
• Authorization for Research

9
Exclusions in UC Policy

• If using a registered pesticide with the intent
  to provide pest control according to the
  pesticide label and where the pesticide is not
  being used as an integral part of research.

10
Definitions

• Pesticide
• Any chemical or biotic agent used or intended for
  use for pest control.
• Any chemical or microbial agent that is being
  used with the intent of testing in any field
  test.
• Pesticide includes any substance, or mixture of
  substances which is intended to be used for
  defoliating plants, regulating plant growth, or
  for preventing, destroying, repelling, or
  mitigating any pest which may infest or be
  detrimental to vegetation, humans, animals, or
  households, or be present in any agricultural or
  nonagricultural environment whatsoever.

11
Definitions

• Experimental Pesticide
• Includes new formulations of existing products.
• New products containing old active ingredients.
• Applications to any crop or site not on the
  California-registered label (or no CA label
  exists).
• Use of any spray adjuvant not registered in
  California.
• Use in conflict with the CA registered label.

12
Use in Conflict with Label

• Does not include
• Applications at lower than label rates.
• Less frequent application intervals.
• Tank mixes (unless specifically prohibited on the
  label).
• Use against pests not listed or prohibited on the
  label.
• Providing all other label directions are followed.

13
Intent of Use

• A pesticide can be any substance used to control
  a pest whether or not it is registered as a
  pesticide.
• If that substance is not labeled for the use or
  lacks an exemption it would be illegal to use it
  for pest control
• Exceptions
• Home remedies used by the homeowner for
  non-agricultural sites
• Substances such as steam for weed control

14
Some Materials that are Pesticides

• Disinfectants
• Clorox
• Chemicals to sterilize benches or countertops
• Algaecides
• Animal repellents
• All must be registered and the site listed for
  legal use

15
Experimental Pesticide Use

• Application is made for research purposes only.
• No pest control benefit is intended or expected.
• Applications must conform to State and Federal
  guidelines.
• Pesticide applications that are made for solely
  for pest control purposes rather than research
  purposes cannot be experimental and must be made
  in accordance with CA registered labels and all
  applicable laws and regulations.

16
Employee of UC

• A employee of the UC is defined as any person
  whose current UC position description or Ag
  Experiment Station project description includes
  responsibilities for pest management research and
  demonstration.

17
What About County Employees?

• If working with or under the supervision of a UC
  employee, they should be treated as if they are a
  UC employee.

18
Supervisor

• For purposes of this policy, supervisor shall
  be defined as an employee of the UC working as a
  researcher, project leader, Principal
  Investigator or designated representative
  responsible for execution of any pesticide
  research project, employee training, or pest
  control procedure.

19
University Property

• Is land owned or controlled by the UC and
  includes only property over which the UC
  maintains day-to-day control to such an extent
  that a reasonable presumption can be made that
  experimentally treated commodities will not be
  harvested or removed from the premises without
  authorization of the supervisor.

20
Non-UC Property

• Property under the day-to-day control of
  individuals and institutions other than the UC is
  not included in the definition of UC property.

21
Pesticide Research and Pesticides used for
Experimentation

• Research using pest control chemicals can consist
  of either experimental pesticide applications or
  applications made strictly in accordance with CA
  registered labels, or both. If experimental
  pesticide uses are involved, the use must follow
  either this policy or the requirements and
  procedures of the DPR Research Authorization
  Program.

22
Destroyed

• Destroyed means rendered unfit for utilization as
  human or animal feed.

23
Tolerance

• Tolerance is the maximum pesticide residue level
  that can legally remain on a commodity at the
  time of harvest, as defined in Title 40 Code of
  Federal Regulations, Part 180.

24
Field Test

• Field test means any pesticide experimentation
  outside of the research laboratory or research
  greenhouse.

25
Responsibilities Incurred by Employees of UC

• Supervisor
• Provide a safe work environment and provide
  training to persons working under their
  direction.
• Ensure that pesticides are used in accordance
  with State and Federal laws, regulations, and
  label requirements.
• Make employees aware of the hazards of the
  chemicals and pesticides being used for
  experimentation
• Use the pesticide label as a guide to employee
  training.
• In absence of a registered label, use the MSDS as
  guide to training and personal protective
  equipment requirements.

26
Training

• Must include information on pesticide hazards and
  safety.
• Laws and regulations applicable to all activities
  they may perform.

27
Where do I Find Training Resources?

• Research Extension Centers Web Site
• http//danrrec.ucdavis.edu/ehs/guides/index.html
• Brian Oatman, RE Centers Environmental Health
  Safety Coordinator
• [phone]
• baoatman_at_ucdavis.edu

28
Information Available at RE Centers Web Site

• Ag Worker Protection Program
• Confined Space Program
• Disposal of Chemical Waste
• Employee Health Safety Training
• Experimental Use of Pesticides
• Emergency Eyewash Shower Placement/Design

29
Information Available at RE Centers Web Site
(Cont.)

• Firearms
• Health Safety Training Library
• Pesticide Use Handling
• Respiratory Protection Program
• Storage and Removal of Regulated Waste

30
Environmental Health Safety Notes
Agricultural Operations

• Bloodborne Pathogen Standard
• Pesticide Glove Use
• General Tractor Safety
• PTO Safety
• Pinch Point Hazards
• High-Pressure Washer Safety

• All-Terrain Vehicles
• Flail Mower and Shredder Safety
• Shear and Cutting Point Hazards
• Fence Safety
• And Many More!

31
Safety Requirements

• Entry after Application
• No person shall enter any area treated with a
  pesticide unless he or she follows the labeling
  directions for entry activities. State
  restricted entry regulations (3 CCR Section 6772)
  may be more restrictive than those stated on the
  label. In all cases the most restrictive reentry
  regulations shall be followed.

32
Pesticides with State Specific REIs

• Azinphos-methyl (Guthion)
• Chlorpyrifos (Lorsban)
• Diazinon
• Endosulfan (Thiodan)
• Methidathion (Supracide)
• Methomyl (Lannate)

• Parathion-methyl (non-encapsulated)
• Phorate (Thimet)
• Phosmet (Imidan)
• Propargite (Omite/Comite)
• Sulfur (not specific to formulation)

33
No Restricted Entry (REI) Listed on Label

• Do not enter treated areas for 4 hours after
  application unless protected. After 4 hours,
  anyone entering the area must wear shoes and
  socks, a long sleeved shirt, and long pants.
• Non-Ag and Urban areas Persons shall not enter
  areas treated with liquid formulations for 2
  hours and until the treated area has dried. When
  using baits, dusts and other dry formulations,
  persons should not enter the area during the
  application.
• Standard industry care and practice should be
  observed.

34
When do I post a Restricted Entry Interval (REI)
sign?

• Whenever the label requires posting (Federal
  regulation)
• If REI is 7 days or longer (CA regulation)
• Label may require posting of the REI for less
  than 7 days.

35
Posting Treated Plots

• Post in accordance with any applicable pesticide
  label.
• For non-ag and urban areas, notify the owners or
  residents of the treated property with
  information indicating the nature of the
  treatment, time and date of treatment, and any
  special instructions regarding restricted entry
  or use after treatment
• In plots treated with materials requiring
  restricted entry intervals under CCR Section
  6772, reentry intervals must be posted.

36
Personal Protective Equipment for Unregistered
Pesticides

• Equivalent to Category I for eye or skin damage.
  Potentially exposed persons must wear protective
  eyewear and chemical resistant gloves when
  handling Category I chemicals.
• Equivalent to Category I for systemic toxicity.
  Potentially exposed persons must use PPE as
  described in 3 CCR Section 6793 and applicable
  portions of Section 6738, as revised.

37
Unidentified or Unlabeled Pesticides

• Shall be stored, transported, handled, and
  disposed of according to the standards
  established by State and County regulations for
  Category I pesticides.

38
Environmental Considerations in Determining Plot
Locations

• The supervisor shall consider the potential
  consequences of any proposed experimental use of
  pesticides, paying particular attention to
  proximity to
• Areas of frequent human activity or habitation
  (especially schools)
• Bodies of sources of water
• Wildlife management areas
• Critical habitats of rare or endangered species
• Livestock and crops
• All research applications will be made in a way
  that minimizes adverse environmental impacts.

39
Pesticide Use Record Keeping and Reporting

• Supervisor shall keep a record for each
  application
• Location of site
• Plot size and total area treated
• Each commodity, crop, or site treated
• Pest species of concern
• Date of application
• Application method
• Concentration and volume of pesticide applied
• Date commodity was destroyed (when required)
• Name of grower, where applicable

40
Records Retention

• Retained by supervisor, the supervisors campus
  departmental office, or the appropriate county CE
  office.
• For at least 2 years after the final pesticide
  application.
• Records shall be made available upon request to
  the county agricultural commissioner or DPR.
• Note Policy makes records public requires they
  be available on request by agency.

41
Crop Control, Disposition, and Destruct
Notification Requirements

• Commodities treated with any experimental
  pesticide for which there is no pesticide residue
  tolerance or tolerance exemption cannot enter the
  channels of trade or in any way be made available
  for use as a human or animal food or feed.
• Supervisor has primary responsibility to ensure
  that the treated commodity is posted and
  destroyed.

42
Posting Requirements

• Prior to application, a sign shall be posted at
  each corner of the experimental plot with the
  words, Commodity treated with experimental
  pesticide, do not harvest. The signs shall be in
  English and Spanish, and of a size so the wording
  is readable to a person with normal vision, from
  a distance of 25 feet. Signs will remain in
  place until treated crop is destroyed.

43
(No Transcript)
44
Remaining Plant Parts

• All parts of the treated commodity potentially
  suitable for use as human or animal food or feed
  and not removed from the site for research
  purposes shall be destroyed.

45
Requirements for Trials Conducted off UC Property

• At least 24 hours prior to commencement of any
  experimental pesticide trial on property not
  owned or controlled by the UC, the supervisor
  shall submit to the county agricultural
  commissioner and grower a copy of a document that
  shall include the following information

46

• Supervisor name, address, phone number and date
  of report
• Qualified Applicator Certificate Number
• Experimental pesticide to be applied and USEPA
  Registration number. If USEPA number is not
  available, use the chemical name or experimental
  number from the MSDS
• Location of experimental trial (grower or ranch
  name, address and site ID number)
• Size of trial (acres or rows)
• Commodity or site to be treated
• Anticipated date of first and last applications
• Intended disposition of treated crop (harvest or
  destruction)
• Date of anticipated harvest or destruction of
  commodity
• Signature of supervisor responsible

47
APPENDIX I PESTICIDE APPLICATION AND NOTIFICATION
REQUIREMENTS FOR TRIALS CONDUCTED OFF UNIVERSITY
PROPERTY At least 24 hours prior to commencement
of any experimental pesticide trial on property
not owned or controlled bythe University, submit
this completed form to the local county
agricultural commissioner and grower. County 
______________________________                   
         Research Supervisor                      
                                  
Grower                                        Name
  _________________________________              
     ___________________________________ Address 
_______________________________                  
___________________________________ _____________
__________________________                  
___________________________________ Phone
_________________________________       
           ___________________________________ Q
AC Certificate Number (of supervisor of
application)______________________________________
___ Pesticides to be applied, including product
name, chemical name, experimental number, or U.S.
EPA registration number, as appropriate (Attach
list if needed) Location of trial and site
identification number  __________________________
____________________ _____________________________
__________________________________________________
___ Size of trial  ______________________________
__________________________________________ Commodi
ty to be treated  _______________________________
_______________________________ Anticipated dates
of first and last applications 
______________________________________________ Int
ended crop disposition                           
                                                  
 ___      Harvest - Crop can enter channels of
trade                                             
                      ___      Destroy crop or
use for research purposes only   
                                                  
             ___      Non-crop use or non-bearing
crop -                                           
                     no crop disposition is
necessary              Date of anticipated
harvest or destruction of treated
commodity_________________________________ Signa
ture of Supervisor of Research Trial
______________________________  
DATE______________
48
What Happens if Treated Commodity is Potentially
Made Available for Human or Animal Consumption?

• Persons conducting the research shall IMMEDIATELY
  notify the county agricultural commissioner, the
  grower, DPR and the UC DANR. CE Specialists and
  AES faculty shall notify the Dept. Chair. CE
  Advisors shall notify the County Director. Chairs
  or County Directors will then notify appropriate
  Deans or Regional Directors.

49
Violations of UC Policy Known to OPIC

• Experimental plots harvested and marketed
• Peaches Reliable source no direct costs
• Kiwi Fruits Reliable source no direct costs
• Pumpkins Documented minor direct costs
• Cherries Documented no direct costs
• Tomatoes Documented Quietly settled?
• No known violations for over 4 years!!!

50
Registered Uses

• Food or feed treated with pesticides registered
  for application on the test site and applied at
  or below the registered label rates may be
  harvested and allowed to enter the food marketing
  chain, provided all other label and State
  regulatory conditions are met.

51
Microbial Pesticides

• The USEPA generally requires a notification or a
  Federal EUP for any experimental program
  involving the deliberate release into the
  environment of living, genetically engineered
  microbial pesticides, irrespective of the acreage
  involved.
• The DPR Pesticide Registration Branch must also
  be notified of any proposed field testing (on or
  off UC property) by UC personnel involving
  genetically engineered microbial pesticides.

52
Qualifications of Persons Supervising Pesticide
Applications

• Persons directly supervising pesticide
  applications shall hold the Qualified Applicator
  Certificate (QAC).
• It is recommended that employees whose
  responsibilities include applying pesticides be
  certified as a Qualified Applicator (QAC).

53
How to Obtain a QAC

• Submit application and fee of 40
• Submit 50 for each exam category
• Pass Laws, Regulations and Basic Principles
  exam and at least one pest control category exam

54
QAC License Categories

• Residential, Industrial and Institutional
• Landscape Maintenance
• Right-of-Way
• Plant Agriculture
• Forest
• Aquatic
• Regulatory
• Seed Treatment
• Animal Agriculture
• Demonstration and Research
• Health Related

55
Continuing Education

• Accumulate at least 20 hours of approved
  continuing education every 2 years before
  certificate renewal.
• A minimum of 4 of the 20 hours must cover the
  topic of pesticide laws and regulations

56
Annual Renewal Fee

• The license renewal fee is 30 per calendar year,
  to be paid to DPR every 2 years for a total cost
  of 60.
• Each renewed license is valid for 2 years.
• UC should pay this fee for those handling
  pesticides

57
Other Fees

• PCA
• 70/year renewal (140 every 2 years)
• QAL
• 80 application fee
• 60/year renewal (120 every 2 years)

58
The primary license location is

• Department of Pesticide RegulationPesticide
  Enforcement BranchLicensing and Certification
  Program1001 I StreetSacramento, CA 95814-2828
• http//www.cdpr.ca.gov/docs/license/liccert.htm
• Questions call [phone]

59
Storage, Transportation, Disposal of Pesticides

• Containers or equipment that hold or have held
  pesticides shall not be stored, handled, emptied,
  disposed of, or left unattended in such a manner
  that they may present a hazard to persons,
  animals, food, feed, crops, or property.

60
Storage and Delivery

• The supervisor is responsible for all containers
  or equipment on the work site that hold or have
  held a pesticide. The supervisor shall either
• Store all containers or equipment in a locked
  enclosure, or
• Provide a responsible person to maintain control
  over the containers at all times.

61
Storage and Delivery

• When not being used, all pesticide containers
  (regardless of the amount of pesticide they
  contain) shall have lids and closures securely
  fastened.
• Pesticides shall not be delivered to any property
  unless they are stored or controlled as required.

62
Posting of Pesticide Storage Areas

• All areas where pesticides or their used
  containers are stored shall be posted with
  warning signs as required by 3 CCR, Section 6674
  in English and any other appropriate language.
• For unregistered pesticides and related
  chemicals, the MSDS shall be used to determine
  the appropriate warning sign for posting.

63
Is This Sign Legal in California for Pesticide
Storage Areas?
64
How About This Sign?
65
Or This Sign?
POISON STORAGE AREA ALL UNAUTHORIZED PERSONS
KEEP OUT KEEP DOOR LOCKED WHEN NOT IN USE
66
Container Label Requirements

• The manufacturers label shall not be removed
  from any pesticide container.

67
Service Containers

• Service containers are those other than those
  bearing the registered pesticide label.
• Regardless of size, shall be labeled with the
  following information
• Signal word from the pesticide label, if
  available
• Name of pesticide
• Name of manufacturer
• Name of active ingredient (or mfg. Code no.)
• Name, address, and telephone number of the person
  responsible for the demonstration, application or
  research.

68
MSDS

• Is the MSDS required to be in the vehicle when
  transporting pesticides from a warehouse to the
  storage area?
• No. Only the labels are required.
• If an employee wants to review the MSDS, it must
  be available.
• MSDSs must be available at a central location.

69
MSDS in Vehicle

• Are MSDSs required to be in the vehicle when
  transporting pesticides to the application site?
• No. Unless the product is not registered and
  lacks a label, then the MSDS may being used in
  lieu of a label.

70
Prohibited Service Containers

• Pesticides shall not be placed or kept in any
  container commonly used for food, drink,
  household products, or feed.

71
Transportation Requirements

• Pesticides shall not be transported in the same
  compartment with persons, food, or feed.
• Containers shall be secured to vehicles during
  transportation in a way that will prevent
  spillage. Paper, cardboard, and similar
  containers shall be covered when necessary to
  protect them from moisture.

72
Container Rinsing Requirements

• Each emptied container that has held less than 28
  gallons of a liquid pesticide diluted for use
  shall be rinsed by the user at the time of use by
  the triple-rinse method or another rinse method
  approved by DPR.
• For containers less than 5 gallons, each rinse
  shall be at least ¼ of volume.
• For containers 5 gallons and larger, each rinse
  shall be at least 1/5 of volume.

73
Pesticide Disposal

• All undiluted, excess pesticides will be disposed
  of in accordance with State and Federal laws and
  regulations, or in accordance with the
  requirements stated on the label.

74
Closed Pesticide Transfer System

• Must be used when required by State regulation.
• Does not apply if employees handle one gallon or
  less of such pesticides per day in the original
  container.
• If handle over one gallon of pesticides in
  toxicity Category I, a closed system must be used
  to transfer, mix, or load in accordance with 3
  CCR, Section 6746, Closed Systems.

75
Unregistered Pesticides

• All experimental and unregistered pesticide
  chemicals shall be stored and transported in
  labeled containers of a type appropriate to
  assure safety in handling.

76
Personal Safety

• Age. Persons under the age of 18 shall not mix,
  load, or apply pesticides
• Instruction and training. The supervisor shall
  provide training for each employee handling
  pesticides. This shall include
• Potential hazards involved for each pesticide
• Safety procedures to be followed
• Clothing and protective equipment
• Common symptoms of pesticide poisoning and ways
  poisoning can occur
• Medical supervision requirements
• Applicable laws, regulations and label
  requirements

77

• Timing and record of instruction and training.
  Instruction shall be completed before the
  employee is allowed to handle pesticides and at
  least annually thereafter. The supervisor shall
  maintain a permanent record of the date and
  extent of instruction given.
• Emergency medical care. The supervisor shall make
  prior arrangements for emergency medical care as
  required by 3 CCR Section 6726.
• Medical Supervision. The supervisor shall provide
  medical supervision in the form of a written
  agreement with a licensed physician for any
  employee who regularly handles any Category I or
  II pesticide containing an organophosphate or
  carbamate. This shall meet the requirements of 3
  CCR Section 6728.

78
Regularly Handle Pesticides

• Applies only to cholinesterase inhibiting
  pesticides.
• Employee handles pesticide any part of a day for
  more than 6 days in any 30 consecutive days.
• Excluding days where solely using closed mixing
  system or water soluble bags.

79
Other General Requirements

• The supervisor shall meet the requirements of
  state regulations for
• Working alone with pesticides (Category 1)
• Contact every 2 hours by day, 1 hour at night
• Clothing change area
• Mixing and loading site requirements
• Work clothing
• Protective equipment
• Adequate light
• Servicing equipment
• Equipment specifications
• Availability of MSDSs

80
Restricted Materials Permit

• Required of UC employees when possessing, using,
  or applying any restricted material for pest
  control purposes.
• No permit is required for restricted materials
  used only for experimental or research purposes,
  when possessed or used by or under the
  supervision of research personnel from UC.

81
Potential Groundwater Contaminating Chemicals

• Listed in 3 CCR Section 6800(a)
• May be applied by UC for research and
  experimental purposes only pursuant to a valid
  research authorization. The UC research
  exemption form the requirement for a Research
  Authorization does not apply when these
  potentially groundwater polluting chemicals are
  used for research and experimentation purposes.

82
6800 (a) List

• Atrazine
• Simazine
• Bromacil
• Diuron

• Prometon
• Bentazon
• Norflurazon

83
Pesticide Recommendations

• Pesticide use recommendations shall conform to
  usage prescribed by labels registered by the
  USEPA and DPR
• Recommendations must be in writing
• Written recommendations should identify
  pesticides by official common name when
  necessary, brand names may be used (UC/DPR
  agreement).

84
Recommendations

• Recommendation means the giving of any
  instruction or advice on any agricultural use as
  to any particular application on any particular
  piece of property.
• A person making a written recommendation does not
  incur an obligation to ensure that the actual use
  follows his or her recommendation.

85
Recommendations

• No person shall act as an agricultural pest
  control advisor without first having secured an
  agricultural pest control advisor license. UC
  personnel engaged in official duties relating to
  agricultural use are exempt from the requirement
  for an agricultural pest control advisor license,
  provided that any recommendation by any such
  person as to any particular application on any
  particular piece of property shall be in writing.

86
Recommendations

• A written recommendation is required when UC
  personnel are engaged in official duties relating
  to agricultural use of pesticides and when they
  give any instruction or advice on a particular
  application on a particular piece of property.

87
Recommendations

• UC employees exempt from the PCA license
  requirements who are familiar with the property
  and are in doubt as to whether or not a written
  recommendation is needed should write a
  recommendation. Those who are in doubt whether or
  not they are familiar with the property should
  either visit the property or state that their
  knowledge of the property is not adequate to make
  a pesticide use recommendation for that
  particular property.

88
Recommendation Definition

• Food and Agricultural Code, Section 11411
• Recommendation means the giving of any
  instruction or advice on any agricultural use as
  to any particular application on any particular
  piece of property. Recommendation does not
  include any summary that does not specify the use
  to be made for any designated pest, provided that
  such summary is not in conflict with any
  registered pesticide label or with the
  supplementary printed direction delivered
  therewith or with any rule or regulation of the
  director.

89
Published or Presented Results

• Published or otherwise presented results,
  descriptions and demonstrations of experiments in
  which pesticides are used in a manner that does
  not conform with registered uses shall be clearly
  identified as experimental results only. Where
  appropriate, a warning shall be included that
  similar uses may result in contaminated crops
  with illegal pesticide residues.

90
Newsletter and Other Publications

• You must ensure that any published statements in
  newsletters, bulletins or other material
  regarding pesticide use are legal. If in doubt,
  contact the UC Statewide Pesticide Coordinator.

91
Oral Presentations

• You must ensure that any oral statements made
  during presentations regarding pesticide use are
  legal. If in doubt, contact the UC Statewide
  Pesticide Coordinator.

92
Organic Research Issues

• Always verify with grower that material(s) to be
  used in research plot are compliant with NOP and
  their certifier.
• Best not to make written recommendations for
  organic plots, unless you are absolutely certain
  that the material is compliant.
• Even exempt materials must be NOP compliant and
  approved by the certifier.
• Any material must be a part of the growers
  approved organic farm plan - before use.

93
Rick Melnicoe530-754-8378rsmelnicoe_at_ucdavis.edu
www.envtox.ucdavis.edu/research/opic.html