Emmett Institute on Climate Change & the Environment

Governance on the Ground: Evaluating the Role of County Agricultural Commissioners in Reducing Toxic Pesticide Exposures

Timothy Malloy; John Froines; Andrea Hricko; Karla Vasquez; and Mason Gamble

CEN_EMM_PUB_Governance on the Ground
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Highly volatile and toxic pesticides are widely used in California agriculture to control soil pests for numerous high-value crops such as strawberries, almonds and citrus. The annual number of pounds applied to California fields in both 2015 and 2016 was higher than for any year since 1998. These pesticides present substantial health risks to farm workers, bystanders and nearby residents, as well as significant ecological impacts.

Primary responsibility for ensuring the safety of pesticides is split between state and county regulators. At the state level, before a pesticide can be sold or used in California, it must obtain registration from the California Department of Pesticide Regulation (DPR). As part of the registration process, DPR must evaluate the potential risks associated with the pesticide, including cumulative risks. The agency must also consider mitigation measures and safer alternatives, if any, needed to protect the health of agricultural workers and of other individuals who live, work or engage in activities nearby. Safer alternatives include alternative farming practices (such as integrated pest management or organic farming methods) as well as safer alternative pesticides.

In two prior reports, the researchers assessed the DPR pesticide registration program, focusing on best practices and deficiencies in how the agency deals with safer alternatives and cumulative exposures. This report shifts focus to the county level.

"On the ground" implementation of the pesticide regulations is performed by the 56 County Agricultural Commissioners (CACs). Farmers (or their representatives) planning to use a restricted pesticide must obtain a restricted material permit from the CAC. The CAC must deny the application where feasible safer alternatives or mitigation measures are available. The CAC is responsible for knowing local conditions and utilizing such knowledge in making these determinations.

This report concludes that the CACs' permitting processes do not include meaningful evaluation of safer alternatives nor consideration of cumulative exposures. (In this report, "cumulative exposure" refers to exposures associated with simultaneous or sequential application of two or more materials at the same field or at adjacent fields.) The report offers proposals for change at the county and state level.

Report Summary