Minnesota Department of Agriculture Corinne du Preez ACIRochester

Minnesota Department of Agriculture Corinne du Preez, ACI-Rochester Inspection & Permitting Unit

Inspections are based on State and Federal Pesticide Laws: • Minnesota Statute 18 B, 18 C and 18 D • Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) • Pesticide labels • Inspections may be routine or for cause (investigations/complaints)

Use Observation Inspections • Routine and unannounced • Where? Where the work is being done • When? When work is being done • May also be done as a Post-Use Inspection after the work is completed.

Who? • All applicators of pesticides and fertilizers • Right of Way • Forestry

Use Observation Inspections Purpose – To determine compliance with: • Application site • Use directions • Restrictions /Caution statements • Rate of application • Personal Protective Equipment, etc.

Purpose: • Determine company & applicator license status • Obtain copy of application record

Inspection Process What should the applicator expect? • Inspections are performed during normal working hours • The work being performed will stop during the inspection • The inspector will be as efficient as possible

Inspection Process • Official credentials • Introduction and explanation of inspection • Notice of Inspection (copy provided to applicator) • Questions about the application being made

Inspection Process • Inspectors will look at • License • Application equipment • Personal Protective Equipment (PPE) • Product label/s • Application site • Environmental conditions • Take photographs • Issue orders if any non-compliance is documented

Application Record The Inspector may request a copy of the application record • Keep complete and accurate records •

Application Record Requirements ROW • Date of application • Start and end time • Pesticide brand name • EPA Registration # • Dosage used • Site treated • Update the following • • every 2 hours Temperature Wind speed Wind direction Units treated • Name and address of customer • Name and address of firm • Applicator name, signature and license number

Common Non-Compliance Issues • Inadequate Personal Protective Equipment (PPE) • Off label application site • Incomplete application records

It All Starts With the Label

Personal Protective Equipment (PPE) Label Language • Shoes plus socks, long sleeved shirt , long • • pants and chemical resistant gloves Respirator as specified on label Protective eye wear (with brow & temple protection) Coveralls over long sleeved shirt and pants Face shield, goggles or safety glasses

Common level of ROW PPE What’s missing?

Safety Glasses with brow protection Safety Glasses with temple protection

PPE Label Language • PPE can vary on each label • Mixers and loaders may be required to wear different PPE than applicators • Applying in an enclosed cab? Check the label for the Engineering Controls section

Label Language, Weather and Environmental Restrictions

Know your Label Language • The most restrictive label must be followed when using a tank mix • Spray when air temperature is less than 90 degrees F • Avoid drift of spray mists to non-target susceptible plants. . . • Do not apply when conditions favor drift from target area • Do not spray when wind speeds exceed 10 mph • Do not contaminate… with equipment wash waters

Prevent Off Site Movement

Prevent Off Site Movement Use hand held wind meter at time of application & document every 2 hours • Be aware of inversion signs • Dust suspended in air along gravel roads or smoke flowing laterally usually early evening/morning • Sensitive areas • Wetlands • Waterways • Organic growers and sensitive crops like grapes, ornamentals, etc. . •

Wind Meters

Alleged Tordon drift onto grapes from ROW application.

Be aware of adjacent landowner concerns–gardens, organic crops, etc.

Be aware of endangered species in ROW Many areas are unmarked

Environmental Hazards • Most common Environmental Restrictions on ROW herbicide labels: • Do not apply directly to water or to areas where surface water is present… • Do not contaminate water when disposing of equipment washwaters or rinsate.

Alleged overspray into surface water

Alleged improper disposal of glyphosate-contaminated rinsate.

Use products labeled for the application site

The Label is the Law • All labels read: It is a violation of Federal law to use this product in a manner inconsistent with it’s labeling. • Review labels often • Majority of misuse investigation violations are label violations.

Inspection Closing • Review of inspection questions • Order/s issued to applicator • Applicator signs Receipt of Documents • Questions answered • Additional contact information provided

Order to Comply and Cease & Desist Order/NOV: • Orders issued in the field outline documented non-compliance • You may have to stop applications until label requirements are fulfilled (Ex: PPE) • Orders are required to be followed from the time they are issued • Inspections are reviewed at the MDA office in St Paul

Transportation of Pesticide • Pesticides must be tied down/secured to prevent unreasonable adverse effects on the environment

Unsecured loads Purdue University

Secure Loads - Use Tie-downs & Load Bars Purdue University

Service Containers • Must be for the firm’s own use • Can not be for sale • Mark your service containers with the product name

Secondary Containment

Minnesota Duty Officer 800 -422 -0798

Any ? ’s contact MDA www. mda. state. mn. us

Thank You ! Contact Information: Corinne du Preez 651 -201 -6303 Corinne. du. Preez@state. mn. us