The simple answer to any question that you might have about a particular pesticide label, however, is to ask questions. I know how hard that can be because most of us feel we can handle it on our own. I also know this because my wife loves to give me a hard time about not wanting to ask for directions, if we are having trouble finding some place. Of course, I won't let her forget when she called me to ask if she was going the right way on the 91 Freeway after she was all the way in San Bernardino, but on her way to Westminster. Heehee.

If you are having a hard time deciphering a label or needing an interpretation, the county ag commissioner's office has several staff dedicated to pesticide enforcement, and they are the best ones to ask when you need an answer to a pressing question. In fact, Ag Weights and Measures have listed some of the most common agricultural pesticide violations on their web site (http://www.sdcounty.ca.gov/awm/violations.html). If they are listed, then it should be easier to avoid them.

The top five most common agricultural pesticide violations in San Diego County are:

1.   Failure to ensure PPE, required by regulation, is worn by   employees handling pesticide(s)

2.   Failure to post emergency medical care information for employees handling pesticide(s)

3.   Failure to use all PPE required by the pesticide label

4.   Failure to follow pesticide label requirements regarding site, rate, or concentration

5. Failure to have a complete copy of the pesticide label available at the use site.

I only want to highlight two issues that have come up recently. One of the first issues that I had to deal with as a farm advisor was with growers that were using a pesticide that was registered for landscape use, and they were using it for a field nursery application. That violates number 4 above, the failure to follow the 'site' requirement. This is easily ignored when people issue recommendations to treat, but it is very important.

The 'site' can be found in the "Directions for Use" section of the label. In 2006, the California Department of Pesticide Regulation (CDPR or DPR) sent out a notice to all county ag commissioners giving them guidance on interpreting label related "sites" that can be treated. In the notice the DPR noted that some written recommendations indicated that there was some confusion with respect to the wording of the site requirements. The DPR says that in general it is unlawful to use a pesticide on a site not listed under the "Directions for Use" section. For instance if the labeling statement is structured to indicate that the list is exclusive, i.e. "apples and pears" then only apples and pears can be legally treated. Another example is if it says "Citrus (oranges, grapefruit and lemons)" then only oranges, grapefruit and lemons, can be legally treated, not all citrus. However, if the statement is "deciduous fruit orchards such as apples and pears" then it is not exclusive and can be legally used on other orchard species covered by the general term "Deciduous fruit orchards".

In ornamental production, if the "site" is indicated by a broad crop grouping such as "ornamentals", the specific sites/plants or plant groupings will be listed on the label in the "Directions for Use" section of the label. For example, "Ornamentals: Christmas tree plantings, conifer seed orchards, and rhododendrons". In this example, you are restricted to using the product only on those three use sites, Christmas tree plantings, conifer seed orchards, and rhododendrons. Notice that the words such as are not in the sentence structure.

The second issue I want to make you aware of is a recent one. For those of you using Orthene 97, you should be aware that there are specific spray equipment requirements. Under the "Ornamental Trees and Shrubs" site it says, "For foliar applications, do not apply with a low pressure hand wand", and under "Further Use Instructions" it says use a hydraulic sprayer. What this means is that if you are using Orthene 97 in a hand pump sprayer or even a backpack sprayer, it is not a legal application. I have been told that there have been recent violations for this use in the county. Be aware and read the label.

Remember, ignorance is no excuse, and if you know the label like the back of your hand, then you probably write labels for a living or work for DPR. Seek help when you need it, and attend "Laws" CE training when you can.