1

California Environmental Protection Agency

Department of Pesticide Regulation

Reducing Volatile Organic Compound Emissions from Pesticides:

Analysis of Alternatives for Nonfumigant Pesticide Products

October 15, 2014

Summary

California’s ozone state implementation plan (SIP) for the federal Clean Air Act contains an

element that requires the Department of Pesticide Regulation (DPR) to: (1) develop and 

maintain an emissions inventory to track volatile organic compound (VOC) emissions from 

pesticides, and (2) reduce pesticide VOC emissions by specified amounts in five ozone 

nonattainment areas (NAAs). To estimate VOC emissions, DPR multiples the fraction of a 

pesticide product estimated to be a VOC by the amount of that product applied. The 

calculation is adjusted for fumigants to account for how emissions vary depending on 

fumigation method used, based on monitoring data. 

Two NAAs (Sacramento Metro and South Coast) have achieved their pesticide SIP goals for 

many years, and no further reduction measures are needed, although they are still subject to 

reporting and other requirements. For the other three NAAs, DPR considered seven different 

measures for reducing pesticide VOC emissions, and selected three for implementation: 

using alternative application methods, reducing fumigant usage, and reformulating certain 

pesticide products. Other measures that would reduce pesticide VOC emissions are infeasible 

and not needed at this time to achieve the SIP goals. 

For two NAAs (Southeast Desert and Ventura), DPR adopted a series of regulations for 

fumigants beginning in 2008 that require low-emission fumigation methods. The regulations 

also set up a fumigant emission limit that is triggered if low-emission fumigation methods do 

not result in targeted reductions. The fumigant emission limit is currently in effect for the 

Ventura NAA.

The low-emission fumigation methods required in the 2008 regulations also apply to the fifth 

NAA, San Joaquin Valley. However, nonfumigant pesticide products contribute more VOC 

emissions than fumigants in this NAA. Therefore, DPR evaluated possible regulatory actions 

to require reformulated nonfumigant products, including label changes, regulations, and 

conditions for restricted materials permits. Based on this evaluation, DPR adopted 

regulations for nonfumigant products in 2013. The nonfumigant regulations designate certain 

products containing abamectin, chlorpyrifos, gibberellins, and oxyfluorfen as high-VOC

products. San Joaquin Valley growers must obtain a recommendation from a pest control 

adviser prior to certain uses of these high-VOC products, and pest control advisers are 

required to recommend low-VOC products when feasible. As a backup measure, the 

regulations prohibit certain uses of high-VOC products in the San Joaquin Valley if pesticide 

VOC emissions exceed a trigger level. The fumigant and nonfumigant regulations will keep 

all five NAAs in compliance with the VOC reductions required by the SIP.
2

Table of Contents

Summary................................................................................................................................... 1

Table of Contents...................................................................................................................... 2

Introduction............................................................................................................................... 3

1. Regulatory Background ........................................................................................................ 3

2. Pesticide VOC Emissions Inventory..................................................................................... 6

3. Overview of Final Nonfumigant VOC Regulations ........................................................... 10

4. Options Considered for Reducing Pesticide VOC Emissions............................................ 11

5. Nonfumigant Alternatives Analysis: Selecting Products and Uses.................................... 15

6. Nonfumigant Alternatives Analysis: Regulatory Scope and Approach ............................. 17

7. Nonfumigant Alternatives Analysis: Estimated VOC Reductions..................................... 22

8. Nonfumigant Alternatives Analysis: Enforcing VOC Restrictions.................................... 24

9. Nonfumigant Alternatives Analysis: Estimated Effects, Risks, and Costs......................... 30

10. Nonfumigant Alternatives Analysis: Additional Areas for Research............................... 32

11. Process to Evaluate the Need for Additional Restrictions................................................ 32

12. Conclusions and Justification for Final Nonfumigant VOC Regulations......................... 33

Tables...................................................................................................................................... 40

Figures..................................................................................................................................... 59

Appendix 1: University of California’s Emulsifiable Concentrate Alternatives Analysis

Appendix 2: Air Resources Board’s Economic Analysis of Proposed Regulations and 

Amendments to Reduce VOC Emissions 

Appendix 3: Estimated Number of Pesticide Applications for Major Crops that Will Switch 

from High-VOC Products to Low-VOC Products
3

Introduction

The purpose of this paper is to present and analyze various alternatives to current practices 

and uses of nonfumigant pesticide products in order to reduce volatile organic compound 

(VOC) emissions. In the first section, this document summarizes the Department of 

Pesticide’s (DPR) general authority to regulate the sale and use of pesticides. It also outlines 

DPR’s authority and obligation to regulate VOCs, as part of the state implementation plan 

(SIP) for the Clean Air Act, including regulations to reduce VOC emissions from both 

fumigant and nonfumigant pesticide products. 

Section 2 of this document describes DPR’s pesticide VOC emissions inventory, an essential 

part of DPR’s program to reduce VOC emissions. It describes how DPR estimates VOC 

emissions from products in this inventory, describes emissions trends, and determines 

compliance with SIP obligations. 

Section 3 of this document gives an overview of recently adopted nonfumigant VOC 

regulations, while the fourth section presents options DPR considered for reducing VOC 

emissions from pesticides and discusses whether these options are feasible.

Sections 4 – 10 analyze alternatives for reducing VOC emissions from nonfumigant 

products, including the following areas: selecting products and uses; regulatory scope and 

approach; estimated VOC reduction; enforcing VOC restrictions; estimated effects, risks, and 

costs; and areas where additional research and product development are needed. 

Sections 11 – 12 present DPR’s method for determining if additional restrictions are needed, 

and conclusions and justification for the final nonfumigant regulations. This paper will assist 

the U.S. Environmental Protection Agency (EPA) with its review of the nonfumigant 

regulations.

1. Regulatory Background

DPR has broad authority to regulate sales and use of pesticides under various federal 

and state laws. 

DPR regulates pesticide sales through its registration process. Similar to the U.S. EPA’s 

process, pesticide manufacturers and formulators (registrants) must submit and DPR must 

evaluate studies on toxicity, environmental effects, chemistry, and other pesticide 

characteristics. DPR registers a pesticide product (i.e., approves it for sale) if the studies 

submitted are acceptable and use is not anticipated to result in unacceptable risk to human 

health or the environment. Once registered, DPR can request, through its reevaluation 

process specified in state law, that the registrant to provide additional studies and to take 

specified actions.

Application or use of pesticides is regulated at several levels. All pesticide products must 

have a U.S. EPA-approved label that describes the maximum application rate, methods of 

application, crops that can be treated, safety precautions, and other requirements. Labels are 
4

enforceable documents; making pesticide applications contrary to label directions is a 

violation of both state and federal law. DPR also develops and implements state regulations 

that can be more restrictive than the requirements on the label. Under state law, county 

agricultural commissioners can also impose additional use requirements through the 

permitting process required for certain pesticides (restricted materials), based on an 

evaluation of local conditions. Growers and applicators are required to follow the most 

stringent use requirements, whether specified by labels, state regulations, or county permit 

conditions. County agricultural commissioners are responsible for enforcing all pesticide use 

requirements, under DPR oversight.

DPR has used its authority to regulate VOC emissions from pesticides, as required by 

the SIP. 

VOCs and nitrogen oxides react with sunlight in the atmosphere to create ground-level 

ozone, which is harmful to human health and vegetation when present at high enough 

concentrations. Under the federal Clean Air Act, California must meet national standards for 

airborne pollutants, including ozone, and must specify how it will achieve these goals in a 

federally approved SIP. California’s SIP contains a pesticide element (DPR’s VOC program) 

that requires DPR to develop and maintain an emissions inventory to track pesticide VOC 

emissions, and to reduce emissions by 20% from the 1990 base year in four ozone 

nonattainment areas (NAAs)—Sacramento Metro, South Coast, Southeast Desert, and 

Ventura, and by 12% in a fifth NAA—San Joaquin Valley. These five NAAs are defined as 

areas that do not meet the National Ambient Air Quality Standards for ozone as designated in 

the Clean Air Act. The SIP specifies that DPR is responsible for tracking and reducing 

pesticide VOC emissions from agricultural use and commercial structural use (i.e., 

applications by structural pest control businesses), while the Air Resources Board (ARB) is 

responsible for VOC emissions due to home use of pesticides as part of their consumer 

products program.

DPR maintains an annual emissions inventory, which tracks pesticide VOC emissions, based 

on the amount of pesticide products applied (from pesticide use reports) and the VOC content 

(emission potential) of pesticide products. Most pesticide VOC emissions are from fumigants 

and products formulated as emulsifiable concentrates. Fumigants are gaseous pesticides, 

applied in relatively high amounts. Emulsifiable concentrates (nonfumigants) contain 

solvents that keep pesticides in liquid form to make mixing and applying the product easier. 

To DPR’s knowledge, no other state requires measures to reduce VOC emissions from 

pesticides, and if one did these measures would likely be different from DPR’s measures due 

to California’s unique pesticide use permit program. DPR’s VOC program is a hybrid air 

pollution and pesticide regulatory program. Hence, it shares some features with other air 

pollution and pesticide programs, but differs in several respects, which are listed below. 

(1) Pesticides are considered area sources of air pollution, as opposed to mobile 

sources (e.g., motor vehicles) or stationary sources (e.g., oil wells). 

(2) Additionally, pesticides are intentionally introduced into the environment to 

control harmful pests, as opposed to waste discharges (e.g., smokestacks).
5

(3) Most pesticide regulatory programs focus on potential toxic effects from the 

active ingredients in pesticide products. In contrast, DPR’s VOC program does not 

consider toxic effects, but does consider both active and inert ingredients in pesticide 

products, and generally classifies the products as fumigants or nonfumigants.

Fumigant pesticide products usually contain 95% or more active ingredients (some 

contain a small percentage of a warning agent or emulsifier), and the active 

ingredients are gases under normal environmental conditions. Nonfumigant pesticide 

products are liquids or solids containing both active and inert ingredients and many 

such products include VOC solvents as inert ingredients, particularly products 

formulated as emulsifiable concentrates.

In October 2012, U.S. EPA approved DPR’s amendments to the pesticide SIP element for the 

San Joaquin Valley NAA. DPR committed to managing pesticide VOC emissions so they do 

not exceed 18.1 tons/day in the San Joaquin Valley NAA. The 18.1 tons/day limit is 

equivalent to a 12% reduction from the 1990 base year, and “freezes” DPR’s emissions 

estimation methodology and pesticide emissions for 1990. That is, DPR’s VOC emissions 

estimate for the 1990 base year can only be changed with a SIP amendment. The SIP 

amendment also requires DPR to reduce VOC emissions by implementing restrictions on 

fumigant as well as nonfumigant pesticide products. DPR fulfilled these requirements by 

implementing several sets of regulations. The following web page contains the complete 

pesticide SIP and supporting documents: 

<http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/voc_state_imp_plan.htm>.

Between January 2008 and May 2011, DPR adopted a series of regulations to reduce 

VOC emissions from fumigant pesticides. 

Title 3 of the California Code of Regulations (3 CCR), section 6452.2, includes specific 

emission target levels (or VOC regulation benchmarks) for each of the five NAAs, equivalent 

to the SIP obligation of a 12% or 20% reduction. The regulations reduce VOC emissions by 

requiring low-emission fumigation methods in certain NAAs, such as post-fumigation water 

treatments, tarping, or application through drip irrigation systems. If use of these required 

application methods does not maintain pesticide VOC emissions below specified trigger 

levels, then DPR regulations achieve the benchmark by establishing a fumigant emission 

limit. The fumigant limit is determined by subtracting the estimated nonfumigant emissions 

from the regulatory benchmark, basing the nonfumigant emissions estimate on VOC 

emissions inventory data from previous years. DPR and county agricultural commissioners 

have several options for enforcing a fumigant limit. The following web page contains all of 

the fumigant VOC regulations and supporting documents: 

<http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/reg_actions.htm>.

In May 2013, DPR completed the rulemaking process to reduce VOC emissions from 

nonfumigant products used in the San Joaquin Valley. 

Effective in November 2013, these regulations prohibit use of high-VOC nonfumigant 

products on certain crops in the San Joaquin Valley during May 1 through October 31 if a 

VOC trigger level is exceeded. Also, when purchasing or using high-VOC products, the 
6

regulations require a written recommendation from a licensed pest control adviser and 

require pest control dealers to provide VOC information to the purchaser. To assist U.S. EPA 

with its review of these regulations, this document contains detailed information on DPR’s 

evaluation of nonfumigant products, and information on other potential pesticide VOC 

reduction measures. The following web page contains the nonfumigant VOC regulations and 

supporting documents: 

<http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/reduce_nonfumigant.htm>.

2. Pesticide VOC Emissions Inventory

DPR maintains a pesticide emissions inventory for May-October to track VOCs and 

determine compliance with the SIP reduction goals.

DPR’s emissions inventory and regulations are based on the peak ozone-forming season of 

May 1 through October 31 because they implement the pesticide element of the 1-hour ozone 

SIP. That SIP is based on seasonal inventories. Under that SIP, as approved by U.S. EPA, 

VOC reductions are, and always have been, measured over the 6-month ozone season. 

Likewise the VOC reduction goals of the pesticide element of that SIP apply, and always 

have been applied to that time period. The VOC reduction measures of the 1-hour ozone SIP 

are seasonal so that the reductions needed during the peak ozone season are required. 

VOC emissions from pesticide products are estimated based on the fraction of a 

pesticide product estimated to be a VOC (its “emission potential”) and the amount of 

that product applied, and an adjustment for fumigation methods.

DPR prepares an annual estimate of VOC emissions from agricultural and commercial 

structural pesticide applications. DPR maintains an emissions inventory for each year since 

1990, the base year, and it includes pesticide applications in five NAAs—Sacramento Metro, 

San Joaquin Valley, South Coast, Southeast Desert, and Ventura (Figure 1). Only agricultural 

and commercial structural pesticide applications are included. ARB tracks emissions from 

pesticides in consumer products. DPR uses data on VOC content and pesticide use to 

estimate emissions from reported applications in each NAA. The inventory focuses on May 1 

through October 31, the peak ozone season in California. 

To estimate the VOC emissions contributed by individual agricultural and structural use 

pesticides, DPR multiples the fraction (by weight) of a pesticide product estimated to be due 

to VOCs (its “emission potential”) by the amount of that product applied, as shown in 

Equation [1]. 

Estimated VOC emissions = (Emission potential of the product) X (Pounds of pesticide [1]

product applied)

Pesticide use reports provide the amount of product used. California requires full reporting of 

all agricultural pesticide use and the use of pesticides by pest control businesses. The reports 

document the product applied, the amount applied, date applied, location (within a one 

square mile section), crop treated, number of acres treated, and other information.
7

DPR uses several methods to determine the emission potential. The preferred way is through 

laboratory analysis, using a standardized method approved by DPR (thermogravimetric 

analysis). When it is not available, DPR uses other approaches to decide emission potentials, 

listed below.

• Use the VOC emission potential already measured in thermogravimetric analysis of 

an identical or nearly identical pesticide product. 

• Use the confidential statement of formula on file with DPR to find out the percentage 

of water and other inorganic chemicals in the product. This percentage is subtracted 

and the remainder is assumed to produce emissions that must be included in the 

inventory. 

• Assign an estimated value based on an evaluation of a product’s unique chemistry 

and composition. DPR takes this approach for high-use products with well-known 

chemical properties. 

• Assign a default emission potential at a representative level, based on measured data 

that reflect the behavior of similarly formulated products (Table 1). 

Because DPR has monitoring data, the calculation is adjusted for fumigants to account for 

how emissions vary depending on the fumigation method (Application Method Adjustment 

Factor [AMAF] or emission rating) used. AMAFs have been determined from field study 

data and are active ingredient and application method specific. Since the AMAFs are based 

on field measured data for specific application methods and fumigants, they yield more 

refined estimates of fumigant VOC emissions than the previous unadjusted emission 

estimates (Eq. [1]).

Estimated fumigant VOC emissions =Pounds of product used x EP x AMAF [2]

Nonfumigant product emissions are not currently adjusted for application method or other 

field factors due to a lack of data to support such adjustments. 

Usually there are several different types of application methods used for a particular 

fumigant in any particular NAA. Each application method used (e.g., drip, sprinkler, shank, 

or tarp) represents a fraction of the total number of methods used and is referred to as the 

method use fraction. The sum of all method use fractions for any particular (NAA/fumigant) 

combination equals one. Use practices change over time so that different method use 

fractions are used for the base year (1990) as opposed to more recent inventory years. For 

1990, 2005, 2006, and 2007, method use fractions were determined in a number of different 

ways. For 1,3-dichloropropene the method use fractions are determined from use data 

collected by the registrant in support of DPR’s township application caps; for metam sodium 

and metam potassium grower/applicator surveys were conducted to determine types of 

applications for different crops and areas. Methyl bromide and chloropicrin method use 

fractions are based on expert opinion and regulatory history. Finally, method use fractions for 

dazomet and sodium tetrathiocarbonate each equal one because the AMAFs for each of these 

two fumigants are constant, independent of application method. DPR’s memorandum from 

Barry, Spurlock and Segawa to Sanders, dated September 29, 2007 contains a detailed 
8

discussion of how method use fractions and AMAFs were determined.

<http://www.cdpr.ca.gov/docs/emon/pubs/ehapreps/analysis_memos/1955_sanders.pdf>

The 2008 fumigant VOC regulations included a change to pesticide use reports (3 CCR 

sections 6624 and 6626) that requires recording the specific application method for each 

fumigation within an NAA. The method use fractions for 2008 and later years are calculated 

using the fumigation method documented in pesticide use reports rather than using the 

surrogate data described above. Some pesticide use reports for 2008 and later years are 

missing the identification of the application method. In these cases, DPR assumed that the 

application method with the highest AMAF allowed by the regulations for that fumigant was 

used. See the following web page for more details on the methodology to calculate pesticide 

VOC emissions: <http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/voc_method_est.htm>.

Pesticide VOC emissions have met the SIP goals for the last five years in all NAAs, with 

one exception.

The 2008 fumigant VOC regulations (3 CCR section 6452.4) require DPR to publish its 

emissions inventory annually. The annual reports are available at: 

<http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/voc_data_analysis.htm>. The most recent 

data are for 2012; Figure 2 shows the pesticide VOC emissions relative to the SIP goals for 

2012 and earlier years. The 2012 pesticide VOC emissions for all five NAAs complied with 

the SIP goals, except for Ventura and ranged from 19 to 59% less than emissions in the 1990 

base year. The following highlights some other results for 2012.

• Sacramento Metro NAA: VOC emissions have increased steadily since 2008, by less than 

8 percent in each year until 2012, where emissions rose from 1.004 tons per day in 2011 

to 1.311 tons per day in 2012, an increase of 30 percent. Pesticide VOC emissions in 

2012 were 53 percent lower than the 1990 base year and remain well in compliance with 

the SIP goal and the VOC regulation benchmark. In 2012, 94 percent of emissions were 

derived from nonfumigants.

• San Joaquin Valley NAA: VOC emissions decreased between 2011 and 2012, from 

16.376 tons per day to 15.899 tons per day. Pesticide VOC emissions in 2012 were 23 

percent lower than the 1990 base year and comply with the SIP goal and VOC regulation 

benchmark. Approximately three quarters of pesticide emissions are derived from 

nonfumigants, consistent with values observed since 2007.

• Southeast Desert NAA: VOC emissions increased slightly from 0.215 tons per day in 

2011 to 0.470 tons per day in 2012, close to levels observed in 2010 (0.460 tons per day). 

Emissions in 2012 were 59 percent lower than the 1990 base year and continue to comply 

with the SIP goal and VOC regulation benchmark. Increased emissions from fumigants 

accounted for about over one-half of the total.

• Ventura NAA: The SIP goal and VOC regulation benchmark has been phased in over 

several years for this NAA. VOC emissions increased by 2 percent in 2011 to 3.063 tpd, 

which is 0.063 tpd above the SIP goal for 2012. Pesticide VOC emissions in 2012 were 

19 percent lower than the 1990 base year. Eighty-eight percent (88%) of emissions are 

derived from fumigants. Ventura exceeded its SIP goal due to an error in the DPR system 

the county agricultural commissioner uses to track fumigant emissions, allowing 
9

fumigant emissions to inadvertently exceed the specified limit. This error has been 

corrected.

• South Coast NAA: VOC emissions, which had decreased in 2011 by more than 35 

percent compared to 2010, rose to 1.387 tons per day in 2012, and continue to remain 

well below the emission targets. Pesticide VOC emissions in 2012 were 87 percent lower 

than the 1990 base year. More than 70 percent of emissions are derived from 

nonfumigants.

The emissions inventory indicates that DPR will consistently achieve the SIP reduction 

goals for four of the five ozone NAAs due to the 2008 fumigant regulations.

As shown in Figure 2a – e, most pesticide VOC emissions are from fumigants and products 

formulated as emulsifiable concentrates. Fumigants are volatile pesticides, applied in 

relatively high amounts. Emulsifiable concentrates often contain volatile solvents that keep 

pesticides in liquid form, so that mixing and applying the product are easier. Figure 2a – e 

also shows that the Sacramento Metro and South Coast NAAs have consistently achieved the 

SIP goal of a 20% reduction from the 1990 base year. Prior to 2008, the San Joaquin Valley, 

Southeast Desert, and Ventura NAAs did not always meet the final SIP reduction goals.

The VOC reductions in the San Joaquin Valley, Southeast Desert, and Ventura NAAs 

beginning in 2008 were primarily due to regulations DPR implemented that year for 

fumigants. The regulations require “low-emission” fumigation methods in those three NAAs 

during the May-October peak ozone season. The low-emission methods reduce the MayOctober fumigant VOC emissions by approximately one-third, and some users shifted 

applications outside the May-October ozone season, contributing additional reductions 

(Tables 2 and 3). The regulations also establish a fumigant emission limit as a backup

measure because the low-emission methods may be insufficient to achieve the SIP reduction 

goal. The fumigant emission limit is triggered for the upcoming year if the annual report 

shows that the emissions inventory exceeds 95% of the SIP goal for fumigants. DPR and 

county agricultural commissioners enforce the fumigant limit through an emissions 

allowance program or other means. A fumigant emission limit is currently in effect for the 

Ventura NAA. Since fumigants contribute the majority of the pesticide VOC emissions in the 

Southeast Desert and Ventura NAAs, the fumigant limit backup measure will keep these

NAAs in compliance with the SIP reduction goals. Although unlikely to be needed, the 

fumigant limit is also the backup measure for the Sacramento Metro and South Coast NAAs.

The emissions inventory indicates that DPR’s fumigant regulations may not result in 

VOC emissions consistently below the SIP reduction goal for the San Joaquin Valley

NAA due to nonfumigant VOC emissions.

A fumigant limit program is a less efficient reduction measure for the San Joaquin Valley 

because a majority of its pesticide VOC emissions are from nonfumigants. Pesticide VOC 

emissions in the San Joaquin Valley NAA exceeded the SIP goal in 2005 and 2006. While 

the fumigant regulations reduce emissions, the SIP goal would likely still have been 

exceeded had the fumigant regulations been in effect at the time. Additionally, the 2011

pesticide VOC emissions for the San Joaquin Valley were less than 1 ton/day of the level 
10

triggering additional restrictions (95% of SIP goal). The year-to-year variation in emissions 

is approximately 0.5 – 3 tons/day, so exceeding the trigger level is possible for 2014 in the 

San Joaquin Valley.

The 2008 regulations trigger a fumigant limit if emissions exceed 95% of the SIP goal, even 

though fumigants only account for approximately one-quarter of the pesticide VOC 

emissions in the San Joaquin Valley NAA. If nonfumigant emissions increase, it’s possible 

that the 2008 regulations would require a major decrease or a total prohibition of fumigants, 

and still not achieve the pesticide SIP goal for the San Joaquin Valley. Therefore, restrictions 

on nonfumigant VOC emissions in the San Joaquin Valley NAA are needed to: (1) ensure 

that the SIP goal is achieved in a worst-case year; (2) reduce the regulatory burden on 

fumigants by avoiding unnecessarily triggering a fumigant limit; and (3) comply with the SIP 

commitment to implement restrictions on nonfumigant pesticides by 2014.

3. Overview of Final Nonfumigant VOC Regulations

Beginning November 1, 2013, regulations to reduce VOC emissions from certain 

nonfumigant products went into effect (Title 3, California Code of Regulations, sections 

6558, 6577, 6880, 6881, 6883, 6884, and 6886). These regulations are designed to keep 

pesticide VOC emissions below 18.1 tons/day during May to October in the San Joaquin 

Valley. 

The regulations apply to certain products containing any of the four active ingredients listed 

below, and specify criteria to designate products as high-VOC, low-VOC, or to exclude them

from the regulations. VOC requirements pertain only to high-VOC products. Except for the 

excluded products, high-VOC products are those with emission potentials that exceed the 

following thresholds.

• Abamectin product emission potential 35%

• Chlorpyrifos product emission potential 25%

• Gibberellins product emission potential 25%

• Oxyfluorfen product emission potential 15%

Restrictions apply to pest control dealers who sell:

• High-VOC products containing abamectin, chlorpyrifos, gibberellins, or oxyfluorfen

• For use in San Joaquin Valley.

The key restriction requires dealers to provide specified information to purchasers of the 

above products. The information summarizes the requirement for certain growers to obtain a 

recommendation from a pest control adviser prior to application.

Restrictions apply to pest control advisers who recommend and growers who use:

• High-VOC products containing abamectin, chlorpyrifos, gibberellins, or oxyfluorfen

• In the San Joaquin Valley 

• Between May 1 and October 31 

• For alfalfa, almonds, citrus, cotton, grapes, pistachios, or walnuts.
11

A key restriction requires growers to obtain a recommendation from a pest control adviser 

prior to making an application meeting the above criteria. The regulations also replace the 

fumigant limit backup measure with a prohibition of most applications meeting the above 

criteria, if pesticide VOC emissions exceed a trigger level (95% of the SIP goal).

If high-VOC product prohibitions are triggered, the regulations include exceptions that allow 

high-VOC applications for specific, limited uses. The high-VOC product prohibitions would 

remain in effect for at least two years. The prohibitions could be lifted after two years if 

emissions decline sufficiently.

The regulations include recordkeeping requirements for pest control dealers, pest control 

advisers, and growers to document compliance with the restrictions.

The following web page contains the nonfumigant VOC regulations and supporting 

documents: <http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/reduce_nonfumigant.htm>.

DPR developed the regulations in consultation with numerous people, such as staff from 

other agencies including the U.S. EPA, U.S. Department of Agriculture (USDA), California 

Department of Food and Agriculture (CDFA), ARB, the Office of Environmental Health 

Hazard Assessment, the Department of Toxic Substances Control, the State Water Resources 

Control Board, the California Department of Public Health, Cal/Recycle, the San Joaquin 

Valley’s Air Pollution Control District, and county agricultural commissioners; extension 

specialists with the University of California (UC); and representatives from groups that will 

be directly affected by the restrictions including registrants, agricultural commodity 

organizations, pest control advisers, pest control dealers, applicators, and growers. DPR 

invited several environmental and worker organizations to discuss the regulatory options, but 

all declined the invitation. DPR received comments at several public meetings with its 

Pesticide Registration and Evaluation Committee, its Agricultural Pest Control Advisory 

Committee, and its Pest Management Advisory Committee. DPR considered the following 

options and issues based on these discussions and evaluation of the available VOC emissions

data.

4. Options Considered for Reducing Pesticide VOC Emissions

In 1993, U.S. EPA published an alternative control technology document that addresses the 

control of VOC emissions from the application of agricultural pesticides 

<http://www.epa.gov/ttn/naaqs/ozone/ctg_act/199303_voc_epa453_r-92-

011_ag_pesticides.pdf>. To DPR’s knowledge, no other state has developed measures to 

reduce pesticide VOC emissions, so there are no other evaluations to rely on. This section 

describes DPR’s evaluation of the seven techniques the document identified as technically 

viable for reducing pesticide VOC emissions, plus one not included in the document:

• Reformulating organic solvent containing pesticide formulations (e.g., emulsifiable 

concentrates)

• Reducing fumigant usage

• Using alternative application methods

• Applying microencapsulation techniques
12

• Using integrated pest management

• Using alternative active ingredients

• Reducing the use of crop oils

• Reducing acrolein emissions – not included in alternative control technology 

document

Reformulating organic solvent containing pesticide formulations is a likely result of 

DPR’s 2013 nonfumigant regulations.

The previous section describes the regulations with sales and use restrictions on designated 

high-VOC products. This provides an incentive to reformulate products, and several 

registrants have done so to avoid the additional restrictions.

Reducing fumigant usage is a backup measure in DPR’s 2008 fumigant regulations.

The regulations include a fumigant emission limit as a backup measure in the event 

low-emission fumigation methods are insufficient to achieve the SIP goals for four of the 

NAAs. The regulations include several methods for DPR and county agricultural 

commissioners to enforce the fumigant limit.

Using alternative application methods is the key element of the DPR’s fumigant 

regulations.

Although not described in the alternative control technology document, DPR considers 

changes to fumigation methods as alternative application methods. The fumigant regulations 

rely primarily on low-emission fumigation methods to achieve reductions. Additionally, 

numerous researchers are working on methods to further reduce fumigant emissions. Much 

of this work was sponsored by USDA as part of two area-wide programs on methyl bromide 

alternatives. The Pacific Area-Wide program included several multi-year projects in 

California to develop, demonstrate, and implement fumigant reduction measures. This 

research led to additional low-emission fumigation methods. In April 2013, DPR issued 

interim approval for several fumigation methods that use low permeability tarpaulins 

developed in part by this program. Field monitoring data indicate that low permeability 

tarpaulins reduce emissions of some fumigants by 70-80%. Research also continues on soil 

amendments, soil compaction techniques, and other fumigant emission reduction measures. 

All research of the Pacific Area-Wide program, as well as the Southeast Area-Wide program, 

and other fumigant research are presented at an annual conference. Information about the 

research is available at the conference website:<http://www.mbao.org/>.

Alternative application methods are also included in the nonfumigant regulations, as an 

exception allowing the use of high-VOC products. The alternative control technology 

document describes this option as “improved-efficiency application equipment.” To 

encourage the voluntary reduction of emissions, purchase of precision pest control 

application equipment or “smart sprayers” is one of three pesticide VOC measures for which 

USDA’s Environmental Quality Incentives Program (EQIP) provides matching funds to 

growers in California. Priority is given to application equipment that uses photo 
13

identification or sonar-type technologies. These technologies are primarily used for orchard 

sprayers, where a sensor controls the amount of spray, and turns off the spray in between 

trees. This results in less pesticide being applied. Requiring such equipment in regulation is 

not feasible because the equipment is costly and the VOC emissions due to pesticides applied 

with orchard sprayers are relatively low.

Applying microencapsulation techniques are an option registrants can use to 

reformulate a product.

This measure consists of reformulating emulsifiable concentrates into microcapsules to 

reduce the amount of solvent in the product. This is a subset of reformulation. Registrants 

can use this option to develop low-VOC products and avoid the restrictions of the 

nonfumigant regulations.

Using integrated pest management is encouraged, but DPR lacks legal authority to 

require this measure.

The alternative control technology document describes integrated pest management as an 

“ecologically based pest management program that combines biological and nonbiological 

control techniques to suppress weeds, insects, and diseases. This option has been defined as 

a pest population management system that utilizes all suitable techniques in a compatible 

manner to reduce pest populations and maintain them at levels below those causing 

economic injury.” DPR regulates the use of pesticides, but it does not have legal authority to 

require integrated pest management, which includes non-pesticidal practices. However, DPR 

has programs that encourage the adoption of integrated pest management, not only to address

VOCs, but also to reduce health and environmental risks. These programs include DPR’s 

IPM Innovator awards to honor California organizations that emphasize pest prevention, 

favor least-toxic pest control, and share their successful strategies with others. DPR’s Pest 

Management web page describes these programs in detail 

<http://www.cdpr.ca.gov/docs/pestmgt/ipminov/ipmmenu.htm>.

DPR has also funded grants and alliances that form a step-wise progression from applied 

research and demonstration projects to regional or statewide implementation of multidisciplinary reduced-risk pest management practices. Reducing VOC emissions is one of the 

criteria DPR uses to judge applications for its research and pest management grants. In 2012, 

DPR convened a working group with the goal to accelerate change in strawberry production 

to be less reliant on traditional soil fumigants, yet economically manage soilborne pests. The 

group published an action plan that describes the priorities for researching innovative 

technologies and adopting new practices. DPR has provided approximately $650,000 in 

research grants to help implement this plan

<http://www.cdpr.ca.gov/docs/pestmgt/strawberry/work_group.htm>.

Organic crop production or growing crops with no fumigants is possible in some situations, 

but is infeasible for all crop production. For some annual crops such as strawberries, 

conventional crops are normally grown every year or every other year on the same field,

which is only possible if the soil is fumigated. In contrast an organic crop must be rotated 
14

with other commodities and is grown on the same field once every several years. There is 

insufficient land in California, given its climate and water supply, to support 100% organic 

production. In the case of perennial crops (orchards, vineyards), growing them without 

fumigants can be very risky. 

In summary, this measure is not feasible because integrated pest management and organic 

production are not always technically feasible, and DPR lacks legal authority to implement 

this as a requirement. However, DPR has funded grants and provided additional resources to 

encourage development and adoption of alternative practices and products.

Using alternative active ingredients is not feasible because DPR lacks legal authority to 

require this measure.

This option is not feasible because DPR lacks legal authority to require certain pesticides to 

be used. While DPR can regulate or prohibit sales or use of certain pesticides based on 

unacceptable risks, DPR cannot require growers and applicators to apply specific pesticides 

in place of the regulated ones. 

Reducing the use of crop oils will result in minimal VOC reductions, and likely increase 

use of more hazardous pesticides. 

Crop oils have insecticidal uses, and are among the highest used pesticides in California. 

(Petroleum oil was ranked second and mineral oil was ranked fourth in pounds applied 

during 2012 [<http://www.cdpr.ca.gov/docs/pur/pur12rep/top_100_ais_lbs12.pdf>]).

However, DPR disagrees that reducing crop oils is a good option to reduce VOC emissions. 

Based on thermogravimetric analysis data and DPR’s evaluation of 26 oil products, the 

emission potentials for oil products are low, with a median value of 1.53%. Even accounting 

for the high use, none of the oils are among the top 10 pesticide VOC contributors in any of 

the NAAs, so any reductions would have minimal impact on emissions. Moreover, DPR and 

others encourage the use of oils because they have lower health and environmental risk 

compared with most other active ingredients in insecticide products, particularly 

organophosphates. In summary, this measure is not feasible because the VOC emission 

reductions associated with this measure would be minimal, and would likely cause an 

increase in use of pesticides with greater health or environmental impact. DPR’s VOC 

evaluation of oil products is available at:

<http://www.cdpr.ca.gov/docs/emon/pubs/ehapreps/analysis_memos/2079_segawa.pdf>.

Reducing acrolein emissions do not appear to be feasible.

The U.S. EPA’s alternative control technology document does not include this option. 

Acrolein is the highest pesticide VOC contributor in the San Joaquin Valley (Table 4) that is 

not included in the fumigant regulations, and was not considered for nonfumigant 

restrictions. Acrolein (Magnacide®) is used as an aquatic herbicide primarily in irrigation 

canals. The products contain few if any inert ingredients, so they cannot be reformulated. 

Acrolein is applied by injection below the water surface, so changes to application methods 

seem infeasible. 
15

Based on the evaluation described above, DPR concluded that incentivizing 

reformulation of certain nonfumigant products through sales and use restrictions is the 

best alternative for reducing pesticide VOC emissions, in addition to the fumigant 

reduction measures previously implemented.

DPR has implemented options that involve reformulation, alternative application methods, 

and reducing fumigant usage. DPR expects these measures to achieve the SIP goals. The 

other four alternatives (integrated pest management, alternative active ingredients, crop oils, 

and acrolein reductions) are not feasible at this time, and as discussed in later sections, 

additional measures are not needed to consistently achieve the pesticide SIP goals for all 

NAAs.

5. Nonfumigant Alternatives Analysis: Selecting Products and Uses

This and following sections describe the methods and alternatives analysis DPR used to 

implement reformulation, as sales and use restrictions on designated high-VOC products. 

DPR conducted a reevaluation to assess the feasibility of reformulating certain

nonfumigant pesticide products.

In 2005, DPR initiated a reevaluation (regulatory process to request actions by pesticide 

manufacturers and formulators [registrants]) for several hundred nonfumigant products.1 The 

reevaluation required registrants to submit plans for reformulating the inert ingredients in the 

products to reduce product emission potentials, thereby reducing VOC emissions. Some 

registrants responded to the reevaluation or earlier informal DPR requests by successfully 

reformulating several products (Table 5). In 2010, DPR revised the reevaluation to limit 

reformulation efforts to those products with the highest pesticide VOC contribution in the 

San Joaquin Valley:

• Abamectin products (e.g. Agri-Mek®)

• Chlorpyrifos products (e.g. Lorsban®)

• Dimethoate products (e.g. Cygon®)

• Gibberellins products (e.g. Gibgro®)

• Oxyfluorfen products (e.g. Goal®)

• Permethrin products

• Trifluralin products (e.g. Treflan®)

Pesticide products containing abamectin, chlorpyrifos, gibberellins, or oxyfluorfen are 

consistently among the highest nonfumigant VOC contributors in the San Joaquin 

Valley.

 1 To achieve more immediate VOC reductions, DPR stopped work on the reevaluation of nonfumigant products 

and began rulemaking for fumigants in 2006. After completing a series of fumigant VOC regulations, DPR 

restarted work on nonfumigant products.
16

Table 5 and Figure 3 show that products containing abamectin, chlorpyrifos, gibberellins, or 

oxyfluorfen have consistently been among the highest pesticide VOC contributors in the San 

Joaquin Valley for several years. Combined, products with these four active ingredients 

accounted for 28% of the pesticide VOC emissions in the San Joaquin Valley during MayOctober 2008-2010. Products containing other active ingredients such as dimethoate, 

permethrin, and trifluralin were relatively high VOC contributors several years ago, but their 

contribution has declined recently. Conversely, contributions from pesticides, such as 

products containing bifenthrin and fenpyromixate, that were relatively low contributors in 

earlier years have recently increased. 

Products with lower VOC emissions are available for several major nonfumigant active 

ingredients.

In most cases, the most agronomically feasible alternatives to current emulsifiable 

concentrates are liquid products that contain the same active ingredient because liquids are 

usually easier to handle and apply, and are more effective for some pests. Solid products such 

as dusts and powders have lower emission potentials (median emission potential = 1.5%, 

Table 1) compared with emulsifiable concentrates (median emission potential = 39%, Table 

1), but different equipment and procedures are required to apply solid products. 

Consequently, simple substitution of solid formulations for liquid formulations may not be 

possible in many cases. However, liquid products containing abamectin, chlorpyrifos, or 

oxyfluorfen are available with lower emission potentials than other products commonly used 

containing these same active ingredients (Table 6). Most of the liquid products with lower 

emission potentials have only recently been registered, and currently have low use. 

Abamectin, chlorpyrifos, oxyfluorfen, as well as gibberellins and other active ingredients are 

also available in products formulated as solids (e.g., dusts, powder, or granules). 

Reformulation for most other major pesticide VOC contributors is not feasible because the 

products contain little or no VOCs as inert ingredients (e.g., fumigants, oils, and acrolein) or 

the emission potentials are already relatively low (e.g., glufosinate, glyphosate, and oil 

products have emission potentials less than 15%). 

The agricultural impact of switching to products with lower VOC emissions is minimal 

in some cases.

The major nonfumigant VOC contributors have different uses in the San Joaquin Valley. 

Abamectin is a miticide and insecticide used on a wide variety of crops, but mostly almonds. 

Chlorpyrifos is an insecticide used primarily on alfalfa, almonds, citrus, cotton, and walnuts. 

Gibberellins are plant growth regulators used primarily on citrus and grapes. Oxyfluorfen is 

an herbicide used primarily on almonds and pistachios. Use of abamectin, chlorpyrifos, 

gibberellins, and oxyfluorfen products with lower VOC emissions likely has lower 

agricultural impact (greater relative efficacy and lower additional cost) compared with other 

major nonfumigants. Under contract to CDFA, UC evaluated the cost and efficacy of 

alternatives with lower VOC emissions for the major pesticides used on selected crops, 

including alfalfa, almonds, broccoli, cotton, grapes, lettuce, oranges, and walnuts (Appendix 

1). In general, the effective alternatives with lower VOC emissions for abamectin, 

chlorpyrifos, gibberellins, and oxyfluorfen had lower costs than the other major 
17

nonfumigants (Table 7a – b). However, the alternatives with lower VOC emissions were not 

as effective as products with higher VOC emissions for some crops and pests. More 

information on efficacy and costs of switching to products with lower VOC emissions is 

given in later sections. 

Current voluntary efforts assist in reducing nonfumigant VOC emissions, but may not 

consistently achieve the SIP reduction goals.

USDA-EQIP provides the opportunity for growers who use several practices that reduce 

pesticide VOC emissions to receive matching funds. These practices include purchasing

precision sprayers, applying fumigant water treatments, and purchasing nonfumigant 

products with lower VOC emissions.

DPR has developed several tools to assist growers in using low-VOC alternatives. DPR has:

• Written a guide that describes low-VOC options

(<http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/reducing_voc_emissions.pdf>), 

and

• Developed a calculator that determines the VOC emissions of nonfumigant products 

after inputting the product, application rate, and acres. The calculator includes an 

option to compare different products (<http://apps.cdpr.ca.gov/voc-calculator>).

These and other voluntary efforts to switch to products with lower emission potentials have 

had limited success. Figure 4 shows the time trend of pounds of VOCs for each pound of 

active ingredient applied in the San Joaquin Valley. Chlorpyrifos shows a decline in the 

pounds of VOCs per pound of active ingredient in recent years, indicating that products with 

lower emission potentials are being adopted. However, Figure 3 shows that changing to 

products with lower emission potentials was offset by greater use of the products, so that

overall emissions (emission potential x use) from chlorpyrifos products increased between 

2009 and 2010. In contrast, the pounds of VOC per pound of active ingredient for abamectin, 

gibberellins and oxyfluorfen show no consistent trend or a slightly increasing trend, 

indicating that their products with lower emission potentials are not being adopted. 

6. Nonfumigant Alternatives Analysis: Regulatory Scope and 

Approach 

DPR’s SIP commitment is to limit pesticide VOC emissions in the San Joaquin Valley 

NAA to no more than an average of 18.1 tons/day during May-October, and 

nonfumigant VOC reductions are not needed for other areas or time periods.

The regulations are designed to achieve this VOC emission limit, not to reduce VOC 

emissions or ozone concentrations in general. The regulations only affect certain uses of 

certain pesticide products to comply with 18.1 tons/day limit. While additional VOC 

reductions may be feasible, they are not necessary to achieve the SIP commitment. 
18

Other areas of the state do not meet the federal air quality standard for ozone, but the 

regulatory options discussed here for the San Joaquin Valley are inappropriate for statewide 

restrictions or other NAAs for several reasons, which are listed below. 

• San Joaquin Valley is the only NAA for which additional pesticide VOC reductions may 

be needed to achieve the SIP goal. The other four NAAs included in the pesticide SIP 

element consistently achieve SIP goals. 

• Most of the top nonfumigant VOC contributors in the San Joaquin Valley NAA are not 

top contributors in the other NAAs. If needed, nonfumigant VOC restrictions for other 

areas should focus on products with different active ingredients and different crops. 

• DPR can develop similar restrictions for other areas in the future if it becomes necessary. 

However, if DPR were to include additional restrictions in these regulations, they may 

need to stay in place even if unnecessary because making the regulations less stringent in 

the future may not be allowed by the anti-backsliding provisions of the federal Clean Air 

Act. 

• Extending restrictions outside the San Joaquin Valley likely would not comply with 

California’s Administrative Procedures Act because such restrictions would cause an 

unwarranted regulatory burden in other regions. 

Similarly, the regulations require the nonfumigant VOC use restrictions only during MayOctober instead of year-round for several reasons, listed below. 

• May-October is the peak ozone season and the time period of the SIP goal, as well as the 

time period included in DPR’s emissions inventory. VOC reductions outside MayOctober would have no effect on compliance with the SIP goal or emissions inventory. 

• The regulations will likely have the added benefit of reducing emissions by shifting 

applications outside the May-October period. Table 3 shows that the fumigant regulations 

resulted in 6% fewer fumigations due to shifting applications outside May-October. 

Shifting applications outside May-October is a more effective reduction measure than 

switching to a low-VOC product because effectively no VOC emissions occur for the 

shifted applications. A year-round requirement would negate these reductions. 

• Pesticide VOC emissions contribute little or nothing to formation of particulate matter, 

the primary air pollutant outside May-October. 

• DPR can revise the restrictions to be year-round in the future, should it become 

necessary. However, DPR may not be able to make the restrictions less stringent in the 

future due to the anti-backsliding provisions of the federal Clean Air Act. 

• The restrictions would not likely comply with California’s Administrative Procedures Act 

because they would cause an unwarranted regulatory burden outside May-October.

DPR’s regulatory approach focuses on designating nonfumigant products as low-VOC 

or high-VOC products, based on the emission potential.

Similar to ARB’s consumer products program, DPR set emission potential thresholds for 

products containing certain active ingredients. DPR designated products with emission 

potentials less than or equal to the thresholds as low-VOC products and products with 

emission potentials greater than the thresholds as high-VOC products. Products exceeding 
19

the emission potential thresholds and designated as high-VOC products would be subject to 

additional restrictions.

DPR considered setting product emission rate thresholds [pounds VOC/acre; (emission 

potential) x (maximum product application rate)]. Product emission rate thresholds might be

preferable if there were products reformulated to increase the amount of active ingredient, 

without significantly changing the content or amounts of the solvents in the products. In 

these cases, the emission potentials might not change significantly, but the label would 

require a lower product application rate to achieve the same active ingredient application 

rate. This would result in lower overall VOC emissions because less product would be 

applied. With this approach, emission rates, not products, would be designated as high-VOC 

or low-VOC. This would likely make enforcement of the regulatory requirements more 

difficult. During the rulemaking, no registered products were candidates for setting an 

emission rate threshold.

Products containing abamectin, chlorpyrifos, gibberellins, or oxyfluorfen with active 

registrations in 2012 provide clear choices for setting emission potential thresholds to 

designate low-VOC and high-VOC products.

Growers and applicators generally prefer liquid products over solid products due to their

handling and mixing characteristics. However, liquid products generally have higher 

emission potentials. The emission potential thresholds are based on liquid products that have 

relatively low emission potentials to reduce the agricultural impact of requiring solid 

products. Additionally, DPR considered the number of registrants and products that would be 

designated low-VOC in setting the emission potential thresholds. The more registrants and 

products DPR designated as low-VOC, the less impact on costs and markets.

Abamectin, chlorpyrifos, and oxyfluorfen have several liquid products available with lower 

emission potentials (Table 8). During the rulemaking, there were two distinct emission 

potential groups for both chlorpyrifos and oxyfluorfen, and three for abamectin:

• Five chlorpyrifos liquid products from three registrants had emission potentials less than 

21%. The remaining chlorpyrifos liquid products had emission potentials equal to or 

greater than 50%. 

• Six oxyfluorfen liquid products from four registrants had emission potentials less than 

11%. The remaining oxyfluorfen liquid products had emission potentials of 60% or 

greater. 

• Two abamectin liquid products from a single registrant had emission potentials of 

approximately 6%. Three liquid products from two other registrants had emission 

potentials of approximately 30%. All other abamectin liquid products had emission 

potentials of 55% or greater. An abamectin threshold based on an emission potential of 

6% would achieve the most VOC reduction, but costs could increase because products 

would only be available from a single registrant. An abamectin threshold based on an 

emission potential of 30% would be less stringent and achieve less VOC reduction, but 

have less cost impact. 
20

During the rulemaking, gibberellins lacked liquid products with lower emission potentials, 

but several solid formulations were available, all with emission potentials of less than 5% 

(Table 8c). All gibberellins liquid products had emission potentials of at least 79%, but a new 

liquid product in development had an emission potential of approximately 20%. DPR 

registered this liquid product with an emission potential of 18% in April 2013. An emission 

potential threshold of 5% for gibberellins would achieve the most VOC reduction, but there 

are handling and mixing problems with some applications of the solid products (Appendix 1). 

As discussed above, products containing abamectin, chlorpyrifos, gibberellins, or 

oxyfluorfen are consistently among the top nonfumigant VOC contributors in the San 

Joaquin Valley. Setting emission potential thresholds for only these pesticides could provide 

incentive for growers to switch to products with other active ingredients that have higher 

VOC emissions, negating the anticipated VOC reductions. Setting emission potential 

thresholds for numerous active ingredients and products would achieve greater VOC 

reductions, but administering such a large program would greatly increase DPR’s workload, 

and likely cause unwanted effects such as efficacy problems with some crops. At least 

initially, DPR could never be certain that it included all the possible alternatives, and not all 

alternatives have low-VOC products available. If growers do not change to other active 

ingredients, the needed VOC reductions can be achieved from a few active ingredients, as 

discussed in a later section. As detailed in the Process to Evaluate the Need for Additional 

Restrictions section of this document, the regulations can be revised later if the SIP goal is 

exceeded due to growers switching to other active ingredients with higher VOC products.

DPR considered setting emission potential thresholds based on achieving certain target VOC 

emission reductions (e.g., reduce VOC emissions by 1 ton per day). This is more difficult and 

more subjective than setting the emission potential thresholds based on the available 

product(s) with the lowest emission potential. Additionally, setting a threshold based on a 

target VOC reduction could result in thresholds too low to be achieved with current 

technology. Conversely, it could result in thresholds that are too easy to achieve, penalizing 

registrants who have already reformulated to a product with a lower emission potential. 

While it would be relatively easy to determine an overall target VOC reduction amount, DPR 

would also need to make subjective judgments about what sub-targets to achieve for each 

active ingredient.

DPR considered all possible approaches to regulate high-VOC products. 

Once products are designated as high-VOC, there are several options for regulating the 

products. High-VOC products could have more stringent registration requirements, sales 

requirements, use requirements, or some combination of these requirements. These options 

are discussed in a later section.

DPR prefers to exclude some nonfumigant products and uses from any VOC 

restrictions.

Some products containing abamectin, chlorpyrifos, gibberellins, or oxyfluorfen also contain 

other active ingredients. DPR set emission potential thresholds only for products based on the 
21

“primary active ingredient.” If a product contains more than one active ingredient, the 

primary active ingredient is the one present at the highest percentage in a product. The 

specific inert ingredients and amounts greatly depend on the solubility and other 

characteristics of the active ingredients. A product emission potential threshold based on a 

pesticide as a primary active ingredient may be infeasible for products that contain the same 

pesticide, but as a secondary active ingredient. 

DPR is obligated to reduce VOC emissions from agricultural and structural pesticide uses. 

However, DPR exempted structural and non-production agricultural (e.g., cemetery, right of 

way, golf course) uses and products from the regulations. As shown in Table 9, these uses 

have negligible emissions and some of the enforcement options discussed below are 

problematic for these uses.

Table 10 shows the VOC emissions for abamectin, chlorpyrifos, gibberellins, and 

oxyfluorfen products by crop for the San Joaquin Valley. These active ingredients are used 

for several dozen crops. However, commodities such as almonds, which have high acreage,

contribute the most VOCs from these products, and the top ten crops account for more than 

90% of the emissions from these pesticide products. DPR excluded most of the minor crops 

because they have low emissions and the efficacy of the low-VOC products is uncertain in 

many cases.

For two main reasons, DPR relied on UC’s evaluation (Appendix 1) and considered allowing 

high-VOC products for situations where the efficacy of the low-VOC products is uncertain or 

lower than the high-VOC products. If DPR required low-VOC products in all cases, growers 

and applicators would likely use a greater amount of product, offsetting any VOC reductions 

from the lower emission potentials. More importantly, the amount of active ingredient 

applied would likely increase. The health and environmental risk of a greater amount of 

active ingredient could easily outweigh the benefits of any VOC reductions that might be 

achieved. These efficacy exceptions include:

• Low-VOC products are not as effective for cotton and corn aphids. 

• Additional application of other herbicides at low application rates may be needed for 

low-VOC oxyfluorfen to be effective for some post-emergence situations. 

• Low-VOC (dust/powder) gibberellins are difficult to apply at low application rates. 

The efficacy of low-VOC products is unknown for certain products and uses that are 

exempted from registration under Section 18 or have a Special Local Need registration under 

Section 24(c) of the Federal Insecticide, Fungicide, and Rodenticide Act. These applications 

typically have low use because they are used to control unusual pests or to control pests on

unusual crops. During the rulemaking, the only applicable Section 18 exemption was for 

abamectin on lima beans. The applicable Section 24(c) registrations were for:

• Abamectin on alfalfa

• Chorpyrifos on citrus

• Gibberellins on azaleas and tangerines

• Oxyfluorfen on almonds, clover, olives, peas, roses, and stone fruit
22

Low-VOC products may or may not be effective for pesticide applications required by 

USDA, CDFA, or county agricultural commissioners to eradicate or control exotic pests. 

These agencies have extensive activities to prevent establishment of invasive pests that do 

not normally occur in California. Federal and state laws require quarantines and other 

measures to contain and eradicate certain detected pests. Moreover, pesticide applications 

soon after detection are often successful in avoiding greater pesticide use, should the exotic 

pest become established. 

DPR also considered allowing high-VOC products for “precision sprayers” that use various 

sensing technologies to treat only the target plant or pest. The sprayer automatically turns off 

when a target plant or pest is not detected. Precision sprayers apply less pesticide product to 

achieve the same efficacy. This has the same effect as using a low-VOC product, with the 

added benefit of applying less active ingredient. 

7. Nonfumigant Alternatives Analysis: Estimated VOC Reductions

The amount of VOC reductions achieved from the nonfumigant regulations depend on 

four factors: the pesticide products (by active ingredient) included, the emission 

potential thresholds specified, the crops included, and the exceptions included.

DPR balanced these four factors to achieve the needed VOC reductions for the San Joaquin 

Valley (Figure 5). The analysis of various nonfumigant restriction scenarios below is based 

on the worst-case year of 2006 when San Joaquin Valley emissions were 21.3 tons/day. 

DPR estimates that the 2008 fumigant regulations would have decreased 2006 fumigant 

emissions, hence also total emissions, by 2.5 tons/day had they been in place at that time.

Tables 2 and 3 show a 37 percent decrease in fumigant emissions due to low-emission 

fumigation methods (31 percent) and fumigation dates shifted outside the May-October 

period (6 percent). Fumigant VOC emissions in 2006 were 6.81 tons/day, so a 37 percent 

reduction is 2.5 tons/day. Thus, total 2006 emissions would have been 21.3 – 2.5 = 18.8 

tons/day. This yields a target for adequate VOC reduction from nonfumigants of 18.8 – 17.2 

= 1.6 tons per day to avoid the trigger for additional restrictions. Keeping emissions less than 

17.2 tons/day is desirable to allow for fluctuations in pesticide use, variations in cropping 

patterns, and changes in product use from year to year.

Table 11a – b shows estimated VOC reductions from nonfumigant restrictions by active 

ingredient, emission potential thresholds, crops, and exceptions based on 2006 data. Table 

12a – b and Figure 6a – b show theoretical VOC emissions based on 2006 data resulting from 

the various restriction scenarios. The values in Tables 11 and 12 were calculated by assuming 

each application in 2006 that used a high-VOC product instead used a product with an 

emission potential at the specified emission potential threshold.

The pesticide products (by active ingredient) and crops included in the restrictions are 

the major factors in determining the level of VOC reductions achieved.
23

Table 11b shows that the theoretical 2006 VOC reduction for the products containing the top 

active ingredient (chlorpyrifos) would have been 1.86 tons/day, with a total reduction of 3.18 

tons/day for all four active ingredients included in the regulations. This is a difference of 1.32 

tons/day between the least restrictive and most restrictive scenarios. Those estimated 

reductions assume the higher emission potential thresholds are selected, all crops are 

included, and no exceptions to the restrictions. Similarly, the estimated VOC reduction for 

the top crop (almond) would have been 1.11 tons/day, with a total reduction of 3.18 if all 

crops were included, a difference of 2.07 tons/day between the least restrictive and most 

restrictive scenario. Those theoretical reductions also assume higher emission potential 

thresholds are specified, all four active ingredients are included, and no exceptions to the 

restrictions.

The product emission potential thresholds selected and the exceptions included are 

minor factors in determining the level of VOC reductions achieved.

VOC reductions for the higher emission potential thresholds would have been 3.18 tons/day 

(Table 11b), while a total VOC reduction of 3.62 tons/day would have been achieved if the 

lower emission potential thresholds were selected (Table 11a). This is a difference of 0.44 

tons/day between the least restrictive and most restrictive scenarios. Both theoretical 

reductions assume all four active ingredients and all crops were included, and no exceptions 

to the restrictions.

The effect of allowing exceptions is relatively small. For the high emission potential 

thresholds and all exceptions allowed, the theoretical reduction in emissions would have been 

2.70 as compared to 3.18 (Table 11b). This is a difference of 0.48 tons/day between the least 

restrictive and most restrictive scenarios. The corresponding “exception allowed”/“no 

exception” comparison under a low emission potential threshold assumption yields VOC 

reduction estimates of 3.13 and 3.62 tons/ day, respectively. The emissions associated with 

the exceptions were calculated as follows. Emissions were calculated directly from pesticide 

use reports for the structural, non-production agricultural, gibberellins less than 16

grams/acre (as recommended by UC), Section 18, and Section 24(c) applications because 

these specific applications can be identified. Emissions for chlorpyrifos applications to 

control aphids on cotton were assumed to be 10% of all chlorpyrifos emissions, based on a 

personal communication with UC staff. Emissions from quarantine or other USDA/CDFA 

programs were assumed to be negligible, 0.0001 tons/day because only one chlorpyrifos 

application has occurred for this use in the last 10 years. Precision sprayer applications were 

assumed to negate 1% of the VOC reductions.

DPR can consistently achieve the SIP reduction goal for the San Joaquin Valley with 

restrictions on high-VOC products. No restrictions are needed for low-VOC products.

The analysis shows that if all abamectin, chlorpyrifos, gibberellins, and oxyfluorfen 

applications in 2006 had used low-VOC products on all crops, total 2006 pesticide VOC 

emissions would have been 15.2-15.6 tons/day, depending on the emission potential 

thresholds selected and the exceptions included. This compares favorably with the trigger for 

additional restrictions of 17.2 tons/day previously discussed, and provides a margin in light 
24

of (a) uncertainty in the analysis, and (b) the inherent variability in cropping patterns, 

pesticide use, and product use trends. The combined fumigant restrictions and nonfumigant 

restrictions combined would achieve that the SIP goal of 18.1 tons/day each year, and the 

17.2 tons/day trigger for a fumigant emissions limit would not be exceeded.

8. Nonfumigant Alternatives Analysis: Enforcing VOC Restrictions

The regulations enforce the nonfumigant VOC restrictions through requirements on pest 

control dealers who sell high-VOC products, pest control advisers who recommend highVOC products, and growers who use high-VOC products. These are Options 4b and 4c 

described below.

DPR considered all possible approaches for enforcing restrictions on high-VOC 

products.

DPR has legal authority to regulate sales and use of pesticides using three methods: label 

changes, state regulations, or recommended county permit conditions for restricted materials. 

Label changes are probably the easiest use restrictions to enforce, but they have several 

disadvantages in this case (see below).

• Label changes are most feasible if year-round restrictions are needed statewide. For 

nonfumigant VOCs, restrictions are only needed in the San Joaquin Valley during MayOctober.

• Use restrictions may change from year to year, as described below. Labels that change 

from year to year would be difficult to enforce and to comply with due to carryover of 

older products.

• DPR has limited authority over labels. Only registrants and U.S. EPA can change label 

requirements. DPR approves labels, but does not have legal authority to require changes. 

Additionally, coordinating label revisions with registrants in a timely manner would be 

difficult.

Regulations can achieve the nonfumigant VOC reductions and provide the flexibility that 

labels lack. DPR considered regulations in three forms: a registration requirement, sales 

restrictions, and use restrictions. A registration requirement would likely have been the 

preferred approach if low-VOC products were required statewide, year-round, with few 

exceptions. DPR preferred sales or use restrictions because low-VOC products are only 

needed in the San Joaquin Valley during May-October. However, the regulations need some 

method to ensure compliance with sales or use restrictions. Several specific options for 

regulations are described below.

Restricted materials are potentially hazardous pesticides that require a permit issued by the 

county agricultural commissioner, after an evaluation of local conditions. These materials 

can only be applied by a certified applicator. None of the major nonfumigant VOC 

contributors are restricted materials, so restricting their use through permit conditions by 

county agricultural commissioners is not currently possible. Regulations would be needed to 
25

designate additional active ingredients as restricted materials, but this is normally a statewide 

action. More details on the restricted materials option are given below.

DPR prefers an enforcement option that revises the trigger for fumigant emission 

limits.

Regulations on sales or use offered the opportunity to replace or amend the trigger for 

fumigant emission limits in the 2008 regulations. Fumigants account for approximately onequarter of the pesticide emissions in the San Joaquin Valley, and nonfumigants account for 

three-quarters. Under the previous regulations, a fumigant limit was triggered even if 

emissions exceeded a specified level due to an increase in nonfumigant emissions. It’s 

possible that the previous regulations would require a major decrease or a total prohibition of 

fumigants, and still not achieve the pesticide SIP goal for the San Joaquin Valley due to 

increased nonfumigant emissions. Additional reasons that strict reliance on fumigant 

emissions reductions is undesirable for the San Joaquin Valley are the complex cropping 

patterns and the large number of counties involved. In comparison, the fumigant limit and 

allowance program in the Ventura NAA is relatively easy to administer because the 

allowances are issued by a single county agricultural commissioner and the great majority of 

the allowances are issued for strawberries, with grower assistance provided by the California 

Strawberry Commission. A fumigant limit and allowance program in the San Joaquin Valley 

would be much more difficult to administer because DPR would need to coordinate the 

activities of eight county agricultural commissioners for multiple crops. 

DPR preferred to replace the San Joaquin Valley trigger for fumigant limits with a trigger for 

restrictions on nonfumigant high-VOC products (i.e., if pesticide emissions exceed 95% of 

the SIP goal, nonfumigant restrictions would be triggered in the San Joaquin Valley instead 

of a fumigant limit). DPR also considered an option that would give DPR’s Director 

discretion to trigger a fumigant limit or nonfumigant restrictions, depending on which 

pesticides increased. However, providing this discretion in regulations would be problematic 

because of the uncertain criteria the Director would use. The 2008 regulations require DPR to 

evaluate the need for a fumigant limit each year. If changed, DPR would annually evaluate 

the need for additional nonfumigant restrictions instead of a fumigant limit. Specific options 

for enforcing nonfumigant restrictions are described below and summarized in Table13.

Option 1: Deny/cancel registrations for nonfumigant high-VOC products, with 

exceptions.

This is a simple approach, if few exceptions are granted. This would likely require low-VOC 

products statewide, year-round, but reductions are only needed in the San Joaquin Valley 

during May-October. Compliance is likely good, if few exceptions are granted, because most 

products available would be low-VOC. High-VOC products would have labels with limited 

uses for crops-pests that are not controlled with low-VOC products. Compliance is less 

certain if numerous crops-pests can use high-VOC products, unless there is a new procedure 

to check that low-VOC products are used when required. This option would require lowVOC products statewide, year-round, unless the San Joaquin Valley during May-October is 

specified on the labels. However, this would make compliance less certain because of the 
26

greater availability of high-VOC products. Requiring product labels for the affected active 

ingredients to include a high-VOC/low-VOC designation may assist in compliance. 

However, only the registrants and U.S. EPA can implement this action; DPR lacks legal 

authority to require label changes. Restrictions would still be in effect for years when 

additional VOC reductions are not needed to achieve the SIP goal. The fumigant limit trigger 

would remain unchanged.

Option 2: Prohibit use of nonfumigant high-VOC products in San Joaquin Valley every 

May-October, with exceptions.

This is probably the simplest of the use restrictions. Disadvantages include a requirement for 

VOC reductions when they are not needed. Extensive outreach would likely be needed to 

ensure compliance, at least for the first few years. The compliance methods described for 

Options 4a, 4b, and 4c could be used, but that negates Option 2’s advantage of simplicity. 

Requiring product labels for the affected active ingredients to include a high-VOC/low-VOC 

designation may assist in compliance. However, only the registrants and U.S. EPA can 

implement this action; DPR lacks legal authority to require label changes. Restrictions would 

still be in effect during those years when additional VOC reductions are not needed to 

achieve the SIP goal. The fumigant limit trigger would remain unchanged.

Option 3: Make additional active ingredients restricted materials.

County agricultural commissioners would evaluate the need for high-VOC products through 

the permitting process. This is most consistent with the current regulatory structure. It is 

uncertain if the fumigant limit trigger can be replaced with this option. Compliance would be 

more certain through the permitting process. This option likely provides the most flexibility. 

It would be possible to have different permit conditions in different counties to minimize the 

impact and/or maximize VOC reductions. A key disadvantage is the requirement for some 

growers to obtain a restricted materials permit and become certified applicators for the first 

time. Certified applicators are unnecessary for VOC purposes because special equipment, 

procedures, or precautions are not needed. Workload would increase for county agricultural 

commissioners because an evaluation of local conditions is required for all restricted 

materials. The additional work would have little value because an evaluation of local 

conditions would not be needed for VOC purposes, particularly outside the San Joaquin 

Valley. This would not be a feasible option if structural applications are included in the 

restrictions because they are exempt from permitting requirements.

Nonfumigant restrictions could change from year to year with this option, placing a burden 

on production. There could also be “downstream” effects with pesticide dealers or growers 

possessing high-VOC products, but being unable to sell or use them. Registrants may not 

continue to produce and sell high-VOC products, even in areas outside the San Joaquin 

Valley. Requiring product labels for the affected active ingredients to include a highVOC/low-VOC designation may assist in compliance. However, only the registrants and 

U.S. EPA can implement this action; DPR lacks legal authority to require label changes.
27

DPR would use its VOC annual report to provide guidance on permit conditions for the 

upcoming year, recommending more stringent or less stringent requirements depending on 

the emissions level documented in the report. There would be an inherent lag in providing the 

guidance by using the annual report. The VOC annual report and emissions inventory rely on 

data from pesticide use reports. Historically, county agricultural commissioners 

electronically submit all pesticide use reports to DPR by August 1 for the previous year. DPR 

usually releases the draft annual report for public comment in November, and finalizes the 

report the following March or April. With this timeline, there would be a two-year lag in 

implementing restrictions under this option. For example, during the fall of 2013, DPR would

determine if high-VOC restrictions would be needed for May-October 2014, based on the 

pesticide use and VOC emissions for 2012. 

Option 4: Replace the fumigant limit trigger with a trigger for use restrictions on 

nonfumigant high-VOC products in the San Joaquin Valley during May-October, with 

exceptions.

This option removes the possibility of fumigant allowances and would implement new use 

restrictions only if the trigger level is exceeded when VOC reductions are needed to achieve 

the SIP goal. Restrictions on high-VOC products may be in effect for some years, but not 

others. The annual emissions inventory report would be used to determine if the trigger level 

is exceeded. 

Nonfumigant restrictions could change from year to year with this option, placing a burden 

on production. There could also be “downstream” effects with pesticide dealers or growers 

possessing high-VOC products, but being unable to sell or use them. Registrants may not 

continue to produce and sell high-VOC products, even in areas outside of the San Joaquin 

Valley. Requiring product labels for the affected active ingredients to include a highVOC/low-VOC designation may assist in compliance. However, only the registrants and 

U.S. EPA can implement this action; DPR lacks legal authority to require label changes.

DPR would use its VOC annual report to determine if the trigger level is exceeded and 

implement high-VOC restrictions. There would be an inherent lag in providing the guidance 

by using the annual report. The VOC annual report and emissions inventory rely on data 

from pesticide use reports. Historically, county agricultural commissioners electronically 

submit all pesticide use reports to DPR by August 1 for the previous year. DPR usually 

releases the draft annual report for public comment in November, and finalizes the report the 

following March or April. With this timeline, there would be a two-year lag in implementing 

restrictions under this option. For example, during the fall of 2013, DPR would determine if 

high-VOC restrictions would be needed for May-October 2014, based on the pesticide use 

and VOC emissions for 2012. 

This option should include a procedure for dropping the high-VOC restrictions once 

triggered, if emissions decrease sufficiently. However, the lag to compile pesticide use 

reports could make the timing problematic. The criteria to drop the high-VOC restrictions are 

complex because DPR cannot use actual VOC emissions data. For the years when the high-
28

VOC restrictions are in effect, DPR must estimate hypothetical emissions as if the 

restrictions are not in effect. 

A key issue with this option is the method to achieve compliance. The following are 

compliance options, and they can be implemented singly or in any combination. 

Option 4a (county agricultural commissioner authorizations): To achieve compliance if the 

nonfumigant restrictions are triggered, growers would obtain an “authorization” for highVOC products from the county agricultural commissioner. The regulations would specify the 

situations for which the county agricultural commissioner could issue an authorization. 

Applications that use low-VOC products would not need an authorization. The process to 

obtain the authorization would likely be similar to a restricted materials permit. DPR would 

provide a fact sheet that explains the regulations and lists the allowed uses for the high-VOC 

products. A key disadvantage of this option is the possibility that the county agricultural 

commissioner may need to administer a new program. However, this program may be 

preferable to the possibility of administering a fumigant allowance program or the additional 

workload of issuing a restricted materials permit. The possibility of requiring authorizations 

provides additional incentive for voluntary reductions. Additional outreach would be needed 

for growers who do not routinely interact with the county agricultural commissioner.

Option 4b (dealer requirements): Current regulations require purchase of agricultural 

pesticide products only from licensed pest control dealers. To achieve compliance if the 

nonfumigant restrictions are triggered, pest control dealers would be required to provide 

information on the high-VOC prohibitions. For example, as a condition of sale, the 

regulations could require purchasers to read a form and self-certify that the high-VOC 

product will be used for an allowed exception. This sales requirement is similar to current 

dealer regulations for tributyltin and clopyralid, but the number of sales affected would be 

much greater. Alternatively, pest control dealers could be required to provide a fact sheet 

explaining the nonfumigant restrictions to purchasers of high-VOC products. DPR would 

notify and provide information to pest control dealers if the trigger level is exceeded. The 

sales requirement may need to apply to all dealers because the amount of pesticides 

purchased outside the San Joaquin Valley for use inside the San Joaquin Valley is unknown. 

There are approximately 1100 pesticide dealers in the San Joaquin Valley. Minimal outreach 

to growers would be needed because agricultural pesticides can only be purchased from 

licensed dealers. This would not be a good option if structural applications are included in the 

restrictions because structural applicators are not required to purchase products from licensed 

dealers. Other existing regulations require dealers to keep records of all pesticide sales. 

Minimal revisions to those regulations would provide documentation of compliance with 

nonfumigant sales requirements.

This option can be implemented independently from the trigger for additional restrictions. 

That is, the dealer requirements could be in effect whether or not the trigger level is 

exceeded. This should result in more consistent actions by dealers, alleviate some of the 

timing issues discussed above, and discourage use of high-VOC products even if the trigger 

is not exceeded.
29

Option 4c (pest control adviser requirements): To achieve compliance if the nonfumigant 

restrictions are triggered, purchase or use of high-VOC products would require a written 

recommendation from a licensed agricultural pest control adviser. A pest control adviser 

recommendation is currently optional for all pesticides. This option would require a grower 

to obtain a pest control adviser recommendation as a condition of purchase and/or use of any 

of the specified high-VOC products. Other regulations (3 CCR section 6556) require all pest 

control advisers’ recommendations to certify that alternatives and mitigation measures that 

would substantially lessen any significant adverse impact on the environment were 

considered and, if feasible, adopted. This will require pest control advisers to consider and 

recommend low-VOC products when feasible. Additional outreach will be needed for 

growers who do not routinely use a pest control adviser. Other regulations require pest 

control advisers to keep records of all recommendations. Minimal revisions to those 

regulations would provide documentation of compliance with recommendation requirements.

This option can be implemented independently from the trigger for additional restrictions. 

That is, the pest control adviser requirements could be in effect whether or not the trigger 

level is exceeded. This should result in more consistent actions by pest control advisers and 

growers, alleviate some of the timing issues discussed above, and discourage use of highVOC products even if the trigger is not exceeded.

Option 5: Track pesticide VOC emissions on a real-time basis and implement 

restrictions only if the trigger level is exceeded.

The lag in pesticide use reporting likely makes a “track and regulate” system infeasible. A 

track and regulate system would involve real-time compilation of pesticide use data, and 

implementing restrictions if a certain target emission level is reached. Current regulations 

require most pesticide use reports to be submitted to the county agricultural commissioners 

by the 10th day of the month following the application (licensed pest control businesses must 

report within seven days of application). Unless reported electronically, it usually takes 

several weeks or months for county agricultural commissioners to enter pesticide use report 

information into the database. Pesticide use data could be obtained earlier under Option 3 

(restricted materials) because restricted materials require notification (notice of intent) to the 

county agricultural commissioner prior to use. However, application plans may change and 

several notices of intent may be filed for a single application, or the application may never 

occur. Additionally, information on the notice of intent is not available electronically. The 

system would require tracking use for all eight San Joaquin Valley counties combined, with 

county agricultural commissioners sending use data to DPR on a real-time basis, and DPR 

converting the use data to VOC emissions on a real-time basis. Even if a near real-time 

reporting system could be developed, implementing restrictions if a trigger level is exceeded 

would be difficult and uncertain. Outreach to growers and applicators, and ensuring 

compliance would be difficult if use restrictions are triggered. Lastly, restrictions or 

prohibitions of high-VOC nonfumigant products and/or fumigant applications may be 

insufficient to achieve the SIP goal if restrictions are triggered in September or October due 

to the lag in reporting. A track and regulate system is infeasible without major changes to the 

pesticide use reporting system, and could trigger more severe restrictions than currently 

proposed.
30

Option 6: Implement nonfumigant VOC restrictions only for days when ozone 

concentrations are expected to be high.

“Episodic” restrictions may not achieve the SIP reduction goals. Episodic restrictions would 

be similar to no-burn days, where pesticide restrictions would only be in effect for days when 

ozone is expected to be high. In theory, this may reduce ozone concentrations, but 

compliance with the SIP goal is uncertain. DPR is legally required to reduce total pesticide 

VOC emissions by a specified amount during the May through October period, as calculated 

using the emission inventory methodology. VOC reductions that occur only on designated 

days may be insufficient to achieve the SIP goal. DPR is not required to reduce VOC 

emissions on each day, and it is not required to reduce ozone concentrations. This option is 

infeasible given the requirements of DPR’s SIP commitment.

DPR prefers to implement high-VOC prohibitions if the trigger level is exceeded 

(Option 4), with dealer requirements (Option 4b) and pest control adviser requirements 

(Option 4c).

Detailed reasons for selecting Options 4b and 4c are given in a later section, but in summary, 

DPR preferred these options to enforce the nonfumigant restrictions because:

• VOC reductions occur where and when they are needed – in the San Joaquin Valley 

during May-October.

• The fumigant limit is replaced with a more appropriate backup measure.

• High-VOC prohibitions are in effect only when pesticide VOC reductions are needed.

• Compliance and enforceability are likely high.

9. Nonfumigant Alternatives Analysis: Estimated Effects, Risks, and 

Costs

Nonfumigant restrictions are needed to meet DPR’s legal obligation to reduce pesticide 

VOC emissions, but the reduction in ozone levels will likely be minimal.

The San Joaquin Valley and other areas of California exceed the federal and state air quality 

standards for ozone several times each year. Reductions of both VOCs and nitrogen oxides 

are needed to reduce ozone concentrations, but ozone levels in rural areas such as the San 

Joaquin Valley primarily depend on nitrogen oxides. ARB’s SIP discusses these issues in 

more detail (<http://www.arb.ca.gov/planning/sip/2007sip/2007sip.htm>).

Pesticide products contribute approximately 6% of the total VOC emissions for San Joaquin 

Valley, and negligible emissions of nitrogen oxides. Therefore, restrictions on nonfumigant 

products will provide minimal overall reduction in VOC emissions and resulting ozone air 

concentrations. The restrictions should reduce VOC emissions by approximately 2 tons/day 

during a worst-case year, less than a 1% reduction in total VOC emissions from all sources in 

the San Joaquin Valley. However, even the largest sources contribute less than 15% to the 

total VOC emissions, and pesticide products are consistently among the top ten VOC sources 

in the San Joaquin Valley. Reductions from many sources are needed to achieve the ozone air 
31

quality standard. Moreover, nonfumigant pesticides are one of the few, if only, significant 

VOC sources without VOC control measures. ARB’s SIP discusses these issues in more 

detail (<http://www.arb.ca.gov/planning/sip/2007sip/2007sip.htm>).

Different VOCs create different amounts of ozone. VOCs with higher reactivities create 

more ozone, all other factors being equal. DPR evaluated the reactivity of the major 

nonfumigants to determine the effectiveness of reducing their emissions. In general, highVOC abamectin, chlorpyrifos, and oxyfluorfen products contain ingredients with higher 

reactivity and potentially create more ozone, compared with other major nonfumigants. 

Some, but not all, gibberellins products have lower reactivity. While DPR considers product 

reactivity, its current legal obligation is to reduce the mass of VOCs, regardless of reactivity. 

DPR’s evaluation of reactivity of pesticide products discusses these issues in more detail 

(<http://www.cdpr.ca.gov/docs/emon/vocs/vocproj/voc_research.htm>).

Nonfumigant VOC restrictions will have little or no impact on efforts to address other 

adverse environmental or health effects from pesticides.

As toxic chemicals, pesticides can cause other adverse environmental or health effects. 

Abamectin, gibberellins, and oxyfluorfen have few if any other environmental or health 

concerns at this time. DPR is evaluating and regulating chlorpyrifos for aquatic toxicity and 

human exposure concerns. These other concerns pertain only to chlorpyrifos as an active 

ingredient, not as the inert ingredient in products. Therefore, any VOC restrictions for 

chlorpyrifos products will have little or no effect on the other mitigation efforts. DPR crafted

the nonfumigant VOC restrictions so that they do not cause an increase in the amount of 

active ingredient applied to offset lower efficacy of low-VOC products.

DPR and other agencies have programs to encourage the use of integrated pest management 

and other techniques to reduce the use and risks of pesticides. The nonfumigant VOC 

restrictions should not impact DPR’s pest management programs. USDA-EQIP provides 

matching funds to growers to purchase or use precision pesticide sprayers, fumigant water 

treatments, and low-VOC pesticide products. These funds are normally available only for 

voluntary measures. It is uncertain what effect nonfumigant VOC restrictions will have on 

USDA-EQIP.

Most current abamectin, chlorpyrifos, gibberellins, and oxyfluorfen applications in the 

San Joaquin Valley use high-VOC products.

During the rulemaking, DPR estimated the number of applications that might need to switch 

from high-VOC to low-VOC products. Table 14 and Appendix 3 show that most of the 

abamectin, chlorpyrifos, gibberellins, and oxyfluorfen applications used high-VOC products 

in the San Joaquin Valley. Overall, 77% of the 2010 applications and 48% of the acreage 

used high-VOC products. High-VOC abamectin and oxyfluorfen products were used most 

frequently, on approximately 90% of the applications and acreage. Chlorpyrifos was the one 

pesticide for which low-VOC products were used for the majority of the applications. HighVOC chlorpyrifos products were used for 44% of the applications and 12% of the acreage. 
32

The costs of nonfumigant VOC restrictions are uncertain.

As part of the rulemaking process, ARB conducted an economic analysis of the proposed 

regulations (Appendix 2). Most costs are due to some growers switching from high-VOC 

products to low-VOC products, and the higher cost of most of the low-VOC products. Under 

contract to CDFA, UC estimated the grower cost of various low-VOC products and 

alternatives (Appendix 1). The primary reason for the uncertain costs is because restrictions 

may only go into effect if an emissions trigger level is exceeded. There may be no 

restrictions and no additional costs if the trigger level is not exceeded. If the trigger level is 

exceeded, some of the applications that use high-VOC products would be required to switch 

to low-VOC products. If the high-VOC restrictions include exceptions, those applications 

would not be required to switch to low-VOC products. Table 14 shows that approximately 

50% of the active ingredient applied and 43% of the acreage treated with high-VOC products 

would be required to switch to low-VOC products, assuming the restrictions include products 

containing the top four active ingredients, all crops, and all exceptions. Detailed data for 

major crops is shown in Appendix 3.

10. Nonfumigant Alternatives Analysis: Additional Areas for 

Research

UC should continue its work to evaluate the need for continuing the oxyfluorfen and 

gibberellins exceptions. Initial tests indicate that low-VOC oxyfluorfen products may be as 

effective as high-VOC products for all target weeds (Appendix 1). The new liquid low-VOC 

gibberellins product should be evaluated.

UC has evaluated the efficacy and cost of several low-VOC products for major crops such as 

almonds, cotton, and grapes. However, UC has not evaluated some of the pesticides that have 

recently started to make significant VOC contributions, such as bifenthrin products, nor has it 

evaluated most minor crops. This work should continue in the event that the nonfumigant 

restrictions implemented do not consistently achieve the required VOC reductions and more 

stringent requirements are needed.

11. Process to Evaluate the Need for Additional Restrictions

As part of its annual report on the pesticide VOC emissions inventory, DPR will evaluate the 

reasons for a significant increase in pesticide VOC emissions, particularly if increases occur 

for several consecutive years. Examples of significant increases include an increase greater 

than the historical year-to-year variation, or new active ingredients or crops among the top 10 

contributors. The evaluation of a significant increase of emissions will include an analysis of 

the 

• Specific products and uses causing the increase;

• Target pest(s) and whether this is a new pest(s), or an increase in an existing pest(s);

• Increase in pesticide use and whether it is expected to be temporary or permanent;

• Feasibility of low-VOC products containing the same active ingredient; and
33

• Feasibility of alternative active ingredients, and whether they are low-VOC or high-VOC 

products.

While DPR will conduct an evaluation of a significant increase in emissions, additional 

regulatory actions are unlikely. DPR will take additional regulatory actions if the SIP goal is 

exceeded. DPR would also likely take additional regulatory actions if the trigger level is 

consistently exceeded and the evaluation indicates that the increased emissions are likely 

permanent. DPR does not anticipate either of these events occurring. However, if either the 

SIP goal is ever exceeded or the trigger level is consistently exceeded, this means that the 

high-VOC prohibitions for the products containing the four active ingredients and seven 

crops currently included in the regulations, as well as the low-emission fumigation methods 

are insufficient to achieve the SIP goal. DPR would evaluate the possible alternatives 

following the same or similar procedure described in earlier sections if the emissions increase 

is due to nonfumigant products, or evaluate possible alternatives following the same 

procedure described in the fumigant alternatives analysis if fumigant products cause the 

emissions increase. DPR would likely evaluate several pesticides, and may not apply 

restrictions to the product(s) causing the greatest increase. A hypothetical example is if VOC 

emissions from gibberellins increase due to an increase in grape and citrus acreage. It may 

not be feasible to further reformulate gibberellins products, and as growth regulators with a 

unique mode of action there are no alternative active ingredients. DPR may choose to 

achieve VOC reductions from other products instead. 

The timeline for implementing additional regulatory requirements would vary depending on 

if the products to be regulated are fumigants or nonfumigants, and if they are restricted 

materials or general use pesticides. Once DPR drafted new requirements, county agricultural 

commissioners could implement new requirements as permit conditions in a few weeks if the 

products are restricted materials. Formal rulemaking would be required for general use 

pesticides and take at least several months to complete before the regulations are effective 

under state law. Additional time would be required for DPR and ARB to submit the 

regulations for review and approval by U.S. EPA and be enforceable under federal law.

12. Conclusions and Justification for Final Nonfumigant VOC 

Regulations

The nonfumigant regulations achieve the needed VOC reductions by including 

products with a greater number of active ingredients, higher emission potential 

thresholds, fewer crops, and all exceptions.

DPR balanced four factors to achieve the needed VOC reductions from the nonfumigant 

restrictions: the pesticide products (by active ingredient) included, the emission potential 

thresholds selected, the crops included, and exceptions to the restrictions. DPR can achieve 

the needed reductions with restrictions on more products (by active ingredient) and fewer 

crops, or with restrictions on fewer products (by active ingredient) and more crops. UC has 

evaluated the impact and cost of all four active ingredients for major crops, such as almonds, 

cotton, and grapes. The exceptions UC recommended for these crops are well documented

(Appendix 1). In contrast, the efficacy, cost, and other impacts from use of low-VOC 
34

products for minor crops are uncertain. Therefore, the nonfumigant VOC restrictions include 

a greater number of active ingredients and fewer crops.

The emission potential thresholds have a smaller effect on nonfumigant VOC reductions 

compared with the pesticide products or crops included in the restrictions. The necessary

VOC reductions can still be achieved with the higher emission potential thresholds, and the 

costs will be minimized because this will designate products from multiple registrants as 

low-VOC. DPR can make the emission potential thresholds more stringent in the future if 

needed. These nonfumigant VOC restrictions will not result in the prohibition of any active 

ingredients in the San Joaquin Valley or elsewhere.

The exclusions and exceptions to the nonfumigant restrictions also have a smaller effect on 

VOC reductions compared with the pesticide products (by active ingredient) or crops 

included. The regulations include all exclusions and exceptions discussed because:

• Relatively small emissions,

• Problems with enforcing restrictions on structural applications, and

• Possible increases in the amount of active ingredient applied.

The nonfumigant regulations include four active ingredients in products formulated as 

liquids, and specify less stringent emission potential thresholds to designate products as 

high-VOC and low-VOC.

Liquid products, particularly emulsifiable concentrates, containing abamectin, chlorpyrifos, 

gibberellins, or oxyfluorfen are consistently among the highest nonfumigant VOC 

contributors in the San Joaquin Valley. Other nonfumigants are relatively high VOC 

contributors in some years, but not other years. Low-VOC products containing abamectin, 

chlorpyrifos, gibberellins, or oxyfluorfen are available and feasible for the majority of uses, 

but voluntary efforts to switch to the low-VOC products have had limited success. The 

necessary VOC reductions for the San Joaquin Valley can be achieved with restrictions on 

chlorpyrifos, the largest nonfumigant VOC contributor. However, the agricultural impact 

may be lessened (or at least more certain) with less stringent restrictions on products for all 

four active ingredients. DPR considered phasing in restrictions on the active ingredients. For 

example, restrictions on chlorpyrifos products could go into effect immediately, and 

restrictions on products with the other active ingredients could go into effect in later years. 

This would give growers more time to adjust to the low-VOC products. However, phasing in 

the restrictions could make achieving the needed VOC reductions difficult depending on the 

number of crops included (see next conclusion).

As specified in 3 CCR section 6880, products containing abamectin, chlorpyrifos, 

gibberellins, or oxyfluorfen as the primary active ingredient are the nonfumigant products 

regulated for VOCs. A product emission potential threshold based on the primary active 

ingredient may be infeasible for products that contain one of these pesticides, but as a 

secondary active ingredient.

As described above, DPR can assure that the San Joaquin Valley SIP goal will be 

consistently achieved by setting higher emission potential thresholds, and will minimize the 
35

economic impact of requiring low-VOC products. Therefore, 3 CCR section 6880 establishes

the following emission potential thresholds to designate products as high-VOC or low-VOC:

Product Primary Active 

Ingredient

Product VOC Emission Potential 

Threshold (% by weight)

Abamectin 35

Chlorpyrifos 25

Gibberellins 25

Oxyfluorfen 15

The nonfumigant regulations include use restrictions on high-VOC products when 

applied to any of seven crops in the San Joaquin Valley during May-October.

As specified in 3 CCR sections 6883 and 6884, the seven crops with high-VOC product use 

restrictions are:

• Alfalfa

• Almonds

• Citrus

• Cotton

• Grapes

• Pistachios

• Walnuts

DPR selected these seven crops for several reasons. First, they account for more than 90% of 

the VOC emissions from the products containing the four active ingredients. Second, 

switching to low-VOC products for these crops will reduce VOC emissions below the SIP 

goal as well as the trigger level. Third, use of low-VOC products for these crops is feasible in 

most cases. UC has evaluated the impact and cost of all four active ingredients for each of 

these crops. In most cases, use of low-VOC alternatives is as effective and the additional cost 

is minimal. UC also documented situations where low-VOC products may not be effective; 

in these cases, UC recommended continued use of high-VOC products. In contrast, the 

efficacy, cost, and other impacts from use of low-VOC products for other crops are 

uncertain.

The nonfumigant regulations require pest control dealers to provide VOC information 

to purchasers of high-VOC products for use in the San Joaquin Valley. (Option 4b)

As specified in 3 CCR sections 6577 and 6886, all California licensed pest control dealers 

when selling a high-VOC product with one of four specified active ingredients for 

agricultural use must provide specified information to the purchaser if the product will be 

used in the San Joaquin Valley. This requirement applies to all dealers statewide since 

growers and applicators may purchase products outside the San Joaquin Valley for use inside 

the San Joaquin Valley. This requirement also applies year-round since growers and 

applicators may purchase during November-April for use during May-October. The

requirement is in effect whether or not the trigger level is exceeded. This should result in 

more consistent actions by dealers, and discourage use of high-VOC products even if 
36

additional restrictions are not implemented. The regulations include dealer recordkeeping 

requirements so DPR and county agricultural commissioners can check compliance. The 

option for high-VOC product purchasers to sign a self-certifying form was not selected 

because most agricultural pesticides are shipped, not picked up at the point of purchase. This 

type of delivery makes signing a form problematic.

The nonfumigant regulations require growers to obtain a recommendation from a pest 

control adviser prior to using a high-VOC product in the San Joaquin Valley during 

May-October, for any of the seven crops above. (Option 4c)

As specified in 3 CCR section 6883, most growers will have minimal workload to comply 

with the regulations because they routinely obtain a pest control adviser recommendation. 

The regulations place a greater burden on pest control dealers and pest control advisers than 

growers to achieve compliance with the use restrictions. The requirement for growers to 

obtain a pest control adviser recommendation is part of the information that dealers provide 

to purchasers of high-VOC products, as specified in 3 CCR section 6577. Other regulations 

(3 CCR section 6556) require pest control advisers to certify that alternatives and mitigation 

measures that would substantially lessen any significant adverse impact on the environment 

have been considered and, if feasible, adopted. Therefore, pest control advisers must consider 

low-VOC alternatives and recommend them to growers when feasible. The requirement is in 

effect whether or not the trigger level is exceeded and additional restrictions are 

implemented. This should result in more consistent actions by growers and pest control 

advisers, and discourage use of high-VOC products even if additional restrictions are not 

implemented. The regulations include grower and pest control adviser recordkeeping 

requirements so DPR and county agricultural commissioners can check compliance.

The nonfumigant regulations have no additional requirements for county agricultural 

commissioners. (Option 4a not selected)

County agricultural commissioners have no review or other new responsibilities under these 

regulations. As part of their normal duties, they will assist DPR with outreach and advice to 

dealers, growers, and pest control advisers. As part of their routine audits, county agricultural 

commissioners will check the new documentation required by the nonfumigant regulations.

Options 4b (dealer requirements) and 4c (PCA requirements) were selected because the 

county agricultural commissioner workload and outreach needed would be less than for 

Options 3 (restricted materials) and 4a (commissioner authorizations). Outreach to affected 

growers and applicators is more comprehensive through dealers, but pest control advisers are 

more knowledgeable in determining when a high-VOC product should and should not be 

used. 

The nonfumigant regulations prohibit most applications of high-VOC products to the 

seven crops above in the San Joaquin Valley during May-October, if the trigger level is 

exceeded. (Option 4)
37

As specified in the 2008 fumigant regulations, 3 CCR section 6452.2 continues to set a 

trigger level for the San Joaquin Valley NAA of 95% of the pesticide SIP goal (95% of 18.1 

= 17.2 tons/day). However, if emissions exceed the trigger level, the revisions to 3 CCR 

6452.2 implement nonfumigant high-VOC product prohibitions instead of a fumigant 

emission limit. Nonfumigant products account for approximately three times more VOC 

emissions than fumigants in the San Joaquin Valley; therefore, nonfumigant restrictions are a 

more efficient and effective reduction measure than the fumigant limit.

Both pest control advisers and growers must comply with the high-VOC prohibitions, if they 

are triggered. As specified in 3 CCR sections 6558 and 6884, pest control advisers cannot 

recommend and growers cannot use a high-VOC product for the prohibited applications.

While this is a shared responsibility, DPR will rely primarily on pest control advisers to 

know if the high-VOC prohibitions are in effect, and the exceptions to the prohibitions. Since 

DPR licenses all pest control advisers, outreach will be focused on them.

As specified in 3 CCR sections 6452.2 and 6884, high-VOC prohibitions only pertain to the 

San Joaquin Valley during May-October because this is the NAA and time period when VOC 

reductions are needed, and the restrictions can be applied to other areas or time periods in the 

future if necessary. Options 1 (registration requirements) and 2 (high-VOC prohibitions 

every year) would have implemented unnecessary restrictions for other areas and time 

periods. Similarly, imposing the high-VOC prohibitions only if the trigger level is exceeded 

would achieve the needed VOC reductions, but would minimize restrictions and economic 

impacts when reductions are not needed. The regulations include criteria to end the highVOC prohibitions if use levels decrease sufficiently.

The nonfumigant regulations include all exclusions and exceptions to the high-VOC 

prohibitions considered.

If the trigger level is exceeded, 3 CCR section 6884 specifies that all applications of highVOC products containing the four active ingredients in the San Joaquin Valley during MayOctober for the seven crops are prohibited, except for:

• Chlorpyrifos to control aphids on cotton

• Gibberellins applied at no more than 16 grams active ingredient/acre

• Oxyfluorfen applied at no more than 0.125 (1/8) pounds active ingredient/acre 

• Emergency exemption from registration (Section 18)

• Special Local Need (Section 24(c)) registration

• Applications required by USDA, CDFA, or a county agricultural commissioner to 

control, suppress or eradicate pests

These exceptions are needed due to less or uncertain efficacy, and potential for greater 

amounts of products and active ingredients to be applied. This would offset the VOC 

reductions and could cause increased health or environmental impacts.

In addition, the high-VOC prohibitions do not apply to applications that use a precision 

sprayer meeting the criteria of the California Office of USDA-EQIP. Use of this equipment 

achieves VOC reductions by applying less product, as well as less active ingredient.
38

DPR is obligated to reduce VOC emissions from agricultural and structural pesticide uses. 

However, DPR did not include structural and non-production agricultural (e.g., cemetery, 

right of way, golf course) uses and products in the regulations. These uses have negligible 

emissions and some of the enforcement options are problematic for these uses.

The nonfumigant regulations include procedures to remove pesticides or crops, or add 

exceptions as long as the SIP goal will still be met.

As specified in 3 CCR section 6884, DPR may remove pesticides and crops to prevent 

continuing regulation if they no longer contribute significantly to VOC emissions. Similarly, 

DPR may add exceptions if low-VOC products demonstrate lower efficacy in comparison to 

high-VOC products. DPR must document that the SIP goal will still be met if a pesticide or 

crop is removed, or if an exception is added.

The nonfumigant regulations will likely achieve more than the needed VOC reductions.

For a year with the estimated maximum pesticide VOC emissions in the San Joaquin Valley, 

the high-VOC prohibitions would be triggered and likely reduce VOC emissions by 

approximately 2 tons/day (Table 11b). The San Joaquin Valley pesticide VOC emissions 

would likely be less than 16 tons/day (Table 12b). This emission level is low relative to the 

SIP goal of 18.1 tons/day. The regulations achieve extra reductions in case they are needed to 

offset:

• unanticipated exceptions to the restrictions,

• growers switching to other active ingredients in products with higher emission potentials, 

• incomplete compliance, and 

• to provide a margin for pesticide use that exceeds the historical pattern.

As described in the previous section, DPR will evaluate the need for additional restrictions if 

a significant increase in pesticide VOC emissions occurs.

DPR will use its annual pesticide VOC emissions inventory report and website to 

publish requirements that may change over time.

As part of the 2008 fumigant regulations, 3 CCR section 6881 specifies the content and 

procedure DPR must use to publish an annual report on pesticide VOC emissions, including 

a public comment period. The nonfumigant regulations revise 3 CCR section 6881 by

requiring DPR to

• establish prohibitions on high-VOC nonfumigant products, and if applicable, determine if 

prohibitions remain in effect; and 

• include a list of actively registered products designated as high-VOC and low-VOC.

DPR will also publish updates on its website as needed.
39

DPR has adopted regulations to reduce VOC emissions from both fumigant and 

nonfumigant pesticide products, ensuring that emissions will continue to meet the SIP 

goals for all five NAAs.

DPR considered seven different measures for reducing pesticide VOC emissions, and 

selected three for implementation: using alternative application methods, reducing fumigant 

usage, and reformulating certain pesticide products. Other measures that would reduce 

pesticide VOC emissions are infeasible and not needed at this time. DPR previously adopted 

regulations requiring low-emission fumigation methods in certain NAAs. The fumigant 

regulations also include a fumigant emission limit as a backup measure if low-emission 

fumigation methods are insufficient to achieve the SIP goals for four NAAs. For the fifth 

NAA, San Joaquin Valley, DPR evaluated possible regulatory actions to reformulate 

nonfumigant products, including label changes, regulations, and conditions for restricted 

materials permits. Based on the evaluation, DPR adopted regulations for nonfumigant 

products in 2013 that designate certain products containing abamectin, chlorpyrifos, 

gibberellins, and oxyfluorfen as high-VOC products. San Joaquin Valley growers must 

obtain a recommendation from a pest control adviser prior to certain uses of high-VOC 

products, and pest control advisers are required to recommend low-VOC products when 

feasible. As a backup measure, the regulations will prohibit certain uses of high-VOC 

products in the San Joaquin Valley if pesticide VOC emissions exceed a trigger level. The 

fumigant and nonfumigant regulations will keep all five NAAs in compliance with the VOC 

reductions required by the SIP.
40

Tables

Table 1. Median emission potential for each formulation class, based on thermogravimetric 

analysis for several products in each class. These are used as emission potential default 

values for products without thermogravimetric analysis data or other information to estimate 

the emission potential.

Formulation 

Code Formulation Class Median Emission Potential (%)

A0 Dust/powder 1.53

B0 Emulsifiable concentrate 39.15

C0 Flowable concentrate 4.80

E0 Granular/flake 3.70

G0 Microencapsulated 3.24

H0 Oil 3.47

J0 Pellet/tablet/cake/briquet 5.18

K0 Pressurized dust 100.00*

L0 Pressurized gas 100.00*

M0 Pressurized liquid/sprays/foggers 100.00*

N0 Soluble powder 1.15

O0 Solution/liquid (ready-to-use) 7.30

P0 Wettable powder 1.85

R0 Dry flowable 1.02

Q0 and S0 Suspension and liquid concentrate 5.71**

T0 Other (liquid) 6.91

U0 Other (dry) 2.05

* Default emission potential of all pressurized products defined as 100.

** Q0 and S0 formulation classes are combined due to (a) low number of Q0 products (n = 6) 

and (b) no significant difference in median thermogravimetric analysis for these formulation 

classes (Wilcoxon rank sum test, p = 0.8). 
41

Table 2. Comparison of fumigant emissions and use prior to and after implementation of 

fumigant VOC regulations (2006-2007 versus 2008-2009 May-October annual average).

Fumigant VOC Emissions and Use San Joaquin 

Valley NAA

Southeast

Desert NAA

Ventura

NAA

2006-7 Fumigant Emissions (tons/day) 6.47 0.49 3.06

2008-9 Fumigant Emissions (tons/day) 3.35 0.092 1.30

2006-7 Fumigant Use (tons/day) 14.39 0.92 8.89

2008-9 Fumigant Use (tons/day) 11.93 0.47 6.53

2006-7 versus 2008-9 Relative Difference 

(percent)

 Decrease in VOC emissions 48 81 57*

 Decrease in Amount Applied 17 49 26*

 Decrease Due to Low-Emission Methods** 31 32 31

2006-7 versus 2008-9 Mass Difference (tons/day)

 Decrease in VOC emissions 3.12 0.40 1.75*

 Decrease Due to Low-Emission Methods** 2.01 0.16 0.95

* Some of the decrease in use for Ventura was due to the fumigant limit and allowances 

required by the regulations.

** Some of the decrease may be due to changes in the procedure for determining the 

frequency each fumigation method is used.

Table 3. Comparison of fumigant use prior to and after implementation of fumigant VOC 

regulations (2006-2007 versus 2008-2009 annual average). Data is for all fumigants 

combined.

Time Period

Fumigant Use

San Joaquin 

Valley NAA

Southeast

Desert NAA

Ventura

NAA

May-Oct 2006-7 7,005,537 lbs 490,624 lbs 3,283,589 lbs

Jan-Dec 2006-7 16,225,657 lbs 1,029,983 lbs 3,538,332 lbs

May-Oct as fraction of 2006-7 43% 48% 93%

May-Oct 2008-9 5,805,199 lbs 317,963 lbs 2,453,000 lbs

Jan-Dec 2008-9 15,710,197 lbs 950,877 lbs 3,018,515 lbs

May-Oct as fraction of 2008-9 37% 33% 81%

Decrease in May-Oct fraction 

between 2006-7 and 2008-9 6% 15% 11%
42

Table 4. VOC emissions by product primary active ingredient in the San Joaquin Valley

NAA during May-October, 2008-2010 annual average.

Product Primary Active 

Ingredient Rank

VOC 

Emissions 

(tons/day)

Percent of 

Pesticide 

Emissions

Cumulative

Percent

Chlorpyrifos 1 1.8127 12.2380 12.2380

1,3-Dichloropropene* 2 1.2798 8.6405 20.8785

Metam-sodium* 3 0.9932 6.7052 27.5837

Abamectin 4 0.8078 5.4537 33.0374

Oxyfluorfen 5 0.7782 5.2538 38.2913

Gibberellins 6 0.7042 4.7540 43.0453

Methyl bromide* 7 0.6620 4.4697 47.5151

Bifenthrin** 8 0.6528 4.4074 51.9224

Dimethoate 9 0.5045 3.4063 55.3288

Glufosinate-ammonium 10 0.3778 2.5505 57.8793

Potassium N-methyldithiocarbamate* 11 0.3674 2.4806 60.3599

Fenpyroximate 12 0.3536 2.3871 62.7470

Acrolein 13 0.3180 2.1466 64.8937

Trifluralin 14 0.3053 2.0609 66.9546

Glyphosate, isopropylamine salt 15 0.2975 2.0087 68.9633

Permethrin 16 0.2201 1.4860 70.4493

Mineral Oil 17 0.2194 1.4815 71.9309

Chloropicrin* 18 0.1989 1.3432 73.2741

Petroleum Oil, Unclassified 19 0.1841 1.2431 74.5171

Hexythiazox 20 0.1834 1.2380 75.7552

All other pesticides 3.5911 24.2448 100.0000

TOTAL 14.8118

* Fumigant pesticide

** The bifenthrin products emissions shown were used for the original evaluation, but were 

subsequently found to contain an error. The corrected data indicates that the average 

emissions for bifenthrin products during 2008-2010 were 0.1378 tons/day, ranked #23, and 

average total emissions were 14.508 tons/day.
43

Table 5. Examples of reformulated nonfumigant products with lower emission potentials.

Active Ingredient Lower VOC Product

Emission

Potential

(%)

Comparable Higher 

VOC Product

Emission

Potential

(%)

Abamectin Agri-Mek SC 5.63 Agri-Mek 0.15 EC 55.10

Abamectin Abba 0.15 ME 30.73 Abba 0.15 EC 62.60

Chlorpyrifos Lorsban Advanced 18.45 Lorsban 4E 50.00

Chlorpyrifos Drexel Chlorpyrifos 

4E-AG 18.20 Drexel Chlorpyrifos 4E-AG 52.90

Diazinon Diazinon AG 600 

WBC 9.22 Diazinon AG 500 56.76

Esfenvalerate Fenvastar Plus 

Insecticide 2.19 Fenvastar EcoCap 51.78

LambdaCyhalothrinWarrior II with Zeon 

Technology 18.67 Warrior with Zeon Technology 29.06

Oxyfluorfen Goaltender 8.28 Goal 2XL 62.30

Oxyfluorfen Willowood OxyFlo 4 

SC 6.76 Willowood OxyFlo 2 EC 60.00

Oxyfluorfen Oxystar 4L 10.63 Oxystar 2E 73.09

Oxyfluorfen Galigan Slapshot 3.84 Galigan 2E 66.15

Pendimethalin Prowl H2O 3.00 Prowl 3.3 EC 42.35
44

Table 6. Availability of products in 2012 with lower VOC emissions for major VOC 

contributors in the San Joaquin Valley. DPR considered reformulation and nonfumigant 

restrictions for the active ingredients highlighted. Fumigants and acrolein were not 

considered for reformulation or nonfumigant restrictions because they contain little or no 

VOCs as inert ingredients. Glufosinate, glyphosate, and oils were not considered for 

reformulation or restrictions because the emission potentials for all products are less than 

15%. “Rank” is the pesticide VOC emissions ranking for the San Joaquin Valley during 

May-October 2008-2010. “Liquid Products Available” indicates if there were high-VOC 

and/or low-VOC products registered in 2012. “Solid Products Available” indicates if solid 

products were registered in 2012. All solid products are considered low-VOC, but may not be 

effective in all cases.

Product Primary Active Ingredient Rank Liquid Products 

Available

Solid Products 

Available

Chlorpyrifos 1 High- and Low-VOC Low-VOC

1,3-Dichloropropene* 2 High-VOC only None

Metam-sodium* 3 High-VOC only None

Abamectin 4 High- and Low-VOC Low-VOC

Oxyfluorfen 5 High- and Low-VOC Low-VOC

Gibberellins 6 High-VOC only Low-VOC

Methyl bromide* 7 High-VOC only None

Bifenthrin** 8 High- and Low-VOC*** Low-VOC

Dimethoate 9 High-VOC only Low-VOC

Glufosinate-ammonium 10 Low-VOC only None

Potassium N-methyldithiocarbamate* 11 High-VOC only None

Fenpyroximate 12 High- and Low-VOC None

Acrolein 13 High-VOC only None

Trifluralin 14 High-VOC only Low-VOC

Glyphosate, isopropylamine salt 15 Low-VOC only None

Permethrin 16 High- and Low-VOC*** Low-VOC

Mineral Oil 17 Low-VOC only None

Chloropicrin* 18 High-VOC only None

Petroleum Oil, Unclassified 19 Low-VOC only None

Hexythiazox 20 High-VOC only Low-VOC

* Fumigant pesticide

** The bifenthrin products ranking was used for the original evaluation, but was 

subsequently found to contain an error. The corrected data indicates that bifenthrin products 

during 2008-2010 were ranked #23.

*** Low-VOC products may not be registered for all uses.
45

Table 7a. Approximate change in cost of switching to a low-VOC alternative in 2012, by 

percentage. Negative value indicates a cost savings by switching to an alternative product.

Pesticide Alfalfa Almonds Citrus Cotton Grapes Walnuts

Abamectin Low use 0% Low use 0% 0% 0%

Chlorpyrifos <0.1% 33% 0% 0% 20% 9%

Dimethoate 40% No use 104% ? Low use No use

Gibberellins No use No use -2% No use 0.6% No use

Oxyfluorfen No use 6% 6% 6% 6% 6%

Table 7b. Approximate change in cost of switching to a low-VOC alternative in 2012, by 

amount per acre. Negative value indicates a cost savings by switching to an alternative 

product.

Pesticide Alfalfa Almonds Citrus Cotton Grapes Walnuts

Abamectin Low use $0/ac Low use $0/ac $0/ac $0/ac

Chlorpyrifos $0.02/ac $10.77/ac $0/ac $0/ac $6.58/ac $4.10/ac

Dimethoate $14/ac No use $38/ac No data Low use No use

Gibberellins No use No use -$1.40/ac No use $1.20/ac No use

Oxyfluorfen No use $1.19/ac $1.19/ac $1.19/ac $1.19/ac $1.19/ac
46

Table 8a. Actively registered agricultural products in 2012 containing abamectin as the primary active ingredient Products are listed 

in order by emission potential (EP). Products highlighted indicate liquid products with lower emission potentials and considered in 

determining the emission potential threshold for designating low-VOC and high-VOC products. The product amount is amount 

applied in the San Joaquin Valley during May-October 2010.

Product Name Registration Number Registrant Formulation EP 

(%)

Product Amt 

(pounds)

Prescription Treatment Brand Advance Granular 499-370-AA Whitmire Micro-Gen Research Granular/Flake 3.70 184

Prescription Treatment Brand Ascend Fire Ant 

Bait 499-370-ZA Whitmire Micro-Gen Research Granular/Flake 3.70 0

Clinch Ant Bait 10965-50068-AA California Dept. Of Food & Ag. Granular/Flake 3.70 943

Prescription Treatment Brand Advance Granular 499-370-ZB Whitmire Micro-Gen Research Granular/Flake 3.70 24

Clinch Ant Bait 100-894-ZA Syngenta Crop Protection, Inc. Granular/Flake 3.70 184,535

Prescription Treatment Brand Advance 375A 

Select 499-370-ZC Whitmire Micro-Gen Research Granular/Flake 3.70 26

Optigard Fire Ant Bait 100-893-ZB Syngenta Crop Protection, Inc. Granular/Flake 3.70 0

Prescription Treatment Brand Avert Cockroach 499-467-AA Whitmire Micro-Gen Research Pellet/Tablet/Cake/Briquet 5.18 49

Raid Double Control Small Roach Baits 4822-472-ZC S.C. Johnson & Son Inc. Pellet/Tablet/Cake/Briquet 5.18 0

Enforcer Antmax Bait Stations 40849-75-AA ZEP Commercial Sales & Service, Pellet/Tablet/Cake/Briquet 5.18 0

Enforcer Roachmax Bait Stations 40849-76-AA ZEP Commercial Sales & Service, Pellet/Tablet/Cake/Briquet 5.18 0

Raid Max Double Control Large Roach Baits 4822-472-ZH S.C. Johnson & Son Inc. Pellet/Tablet/Cake/Briquet 5.18 0

Raid Max Double Control Ant Baits 4822-472-ZI S.C. Johnson & Son Inc. Pellet/Tablet/Cake/Briquet 5.18 0

Avicta 400FS 100-1211-AA Syngenta Crop Protection, Inc. Aqueous Concentrate 5.50 0

Prescription Treatment Brand Avert Dry Flowable 499-294-ZA Whitmire Micro-Gen Research Dust/Powder 5.55 0

Agri-Mek SC Miticide/Insecticide 100-1351-AA Syngenta Crop Protection, Inc. Aqueous Suspension 5.63 1

Timectin 0.15 EC T&O Insecticide/Miticide 84229-1-AA Tide International USA, Inc. Emulsifiable Concentrate 29.75 0

Master Label - Abba 0.15 ME Miticide/Insecticide 66222-191-ML Makhteshim-Agan Microencapsulated 30.73 0

Abba Ultra Miticide/Insecticide 66222-226-AA Makhteshim-Agan Emulsifiable Concentrate 34.18 0

Abamectin E-Ag 0.15 EC Insecticide 79676-58-AA Etigra Emulsifiable Concentrate 39.15* 1,227

Timectin 0.15 EC Ag Insecticide/Miticide 84229-2-AA Tide International USA, Inc. Emulsifiable Concentrate 39.15* 17,167

Agmectin 0.15 EC 84229-2-AA-72662 Oro Agri, Inc. Emulsifiable Concentrate 39.15* 6,518

Solera Abamectin 0.15EC Ag Insecticide/Miticide 82542-11-AA-84237 Solera Ato, LLC Emulsifiable Concentrate 39.15* 1,149

Nufarm Abamectin 0.15 EC Insecticide 228-658-AA Nufarm Americas Inc. Emulsifiable Concentrate 39.15* 0

Nufarm Abamectin Spc 0.15 EC Insecticide 228-657-AA Nufarm Americas Inc. Emulsifiable Concentrate 39.15* 0

Merlin 81943-29-AA Phoenix Environmental Care LLC Emulsifiable Concentrate 39.15* 0

Agmectin 0.15ED Insecticide/Miticide 84229-2-ZA Tide International USA, Inc. Emulsifiable Concentrate 39.15* 0

Greyhound Insecticide 69117-2-AA Arborsystems Solution/Liquid 55.10 0

Agri-Mek 0.15 EC Miticide/Insecticide 100-898-ZA Syngenta Crop Protection, Inc. Emulsifiable Concentrate 55.10 116,183

Avid 0.15EC Miticide/Insecticide 100-896-ZA Syngenta Crop Protection, Inc. Emulsifiable Concentrate 55.10 55

Epi-Mek 0.15 EC Miticide/Insecticide 100-1154-AA Syngenta Crop Protection, Inc. Emulsifiable Concentrate 55.10 221,777
47

Product Name Registration Number Registrant Formulation EP 

(%)

Product Amt 

(pounds)

Ardent 0.15 EC Miticide/Insecticide 100-896-ZB Syngenta Crop Protection, Inc. Emulsifiable Concentrate 55.10 0

Aracinate 74779-1-AA Rainbow Treecare Scientific Other (Liquid) 55.10 0

Abacus Agricultural Miticide/Insecticide 83100-4-AA-83979 Rotam North America, Inc. Emulsifiable Concentrate 60.54 58,371

Lucid Ornamental Miticide/Insecticide 83100-5-AA-83979 Rotam North America, Inc. Emulsifiable Concentrate 60.54 141

Minx Ornamental Miticide/Insecticide 1001-83-AA Cleary Chemical Corp. Emulsifiable Concentrate 60.54 0

Solera Abamectin Agricultural 

Miticide/Insecticide 83100-4-AA-82542 Source Dynamics, LLC Emulsifiable Concentrate 60.54 3

Zoro Miticide/Insecticide 67760-71-AA Cheminova, Inc. Emulsifiable Concentrate 61.20 36,807

Temprano 67760-71-AA-400 Chemtura Corporation Emulsifiable Concentrate 61.20 7,172

Abba 0.15 EC 66222-139-AA Makhteshim-Agan Emulsifiable Concentrate 62.62 54,844

Quali-Pro Abamectin 0.15 EC 73220-10-AA Farmsaver.Com, LLC Emulsifiable Concentrate 62.62 362

Quali-Pro Abamectin 0.15 EX 

Miticide/Insecticide 66222-210-AA Makhteshim-Agan Emulsifiable Concentrate 62.62 0

Vivid II 64014-10-AA Florida Silvics Inc., DBA Tree Solution/Liquid 71.77 0

Abamectin E-Pro 0.15 EC Insecticide 79676-57-AA Etigra Emulsifiable Concentrate 72.96 70

Reaper 0.15 EC 34704-923-AA Loveland Products, Inc. Emulsifiable Concentrate 73.33 94,294

* DPR was evaluating the emission potentials for these liquid products. They were assigned default emission potential values on an 

interim basis.
48

Table 8b. Actively registered agricultural products in 2012 containing chlorpyrifos as the primary active ingredient. Products are 

listed in order by emission potential (EP). Products highlighted indicate liquid products with lower emission potentials and considered 

in determining the emission potential threshold for designating low-VOC and high-VOC products. The product amount is amount 

applied in the San Joaquin Valley during May-October 2010.

Product Name Registration Number Registrant Formulation EP 

(%)

Product Amt 

(pounds)

Prescription Treatment Brand Duraguard ME 499-367-ZA Whitmire Micro-Gen Research Aqueous Concentrate 0.00 0

Durashield CS Controlled Release Premise 499-419-ZB Whitmire Micro-Gen Research Microencapsulated 0.00 144

Dursban W 62719-352-AA Dow Agrosciences LLC Wettable Powder 1.85 0

Pyrinex Chlorpyrifos Insecticide 11678-58-AA Makhteshim Chemical Works Ltd. Other (Dry) 2.05 0

Lorsban 50W In Water Soluble Packets 62719-221-ZA Dow Agrosciences LLC Wettable Powder 3.03 0

Lorsban 50-W 62719-221-AA-10163 Gowan Company Wettable Powder 3.03 0

Nufos 15G 67760-14-AA Cheminova, Inc. Granular/Flake 3.70 420

Rainbow Fire Ant & Insect Killer 13283-14-ZA Rainbow Technology Corporation Granular/Flake 3.70 0

Andersons Golf Products Insecticide III 9198-167-AA Andersons Lawn Fertilizer Granular/Flake 3.70 600

Lorsban-75WG 62719-301-AA Dow Agrosciences LLC Granular/Flake 3.70 390

Lorsban 75WG 62719-301-AA-10163 Gowan Company Granular/Flake 3.70 507

Lorsban 15G Smartbox 5481-525-AA Amvac Chemical Corporation Granular/Flake 3.70 1,200

Lorsban 15G Granular Insecticide 62719-34-ZA Dow Agrosciences LLC Granular/Flake 5.33 14,880

HM-0531 62719-34-AA-5905 Helena Chemical Company Granular/Flake 5.33 523

Saurus 62719-34-ZA-5905 Helena Chemical Company Granular/Flake 5.33 9,605

Dursban 50W In Water Soluble Packets 62719-72-ZA Dow Agrosciences LLC Wettable Powder 10.80 35

Drexel Chlorpyrifos 4E-Ag 19713-520-AA Drexel Chemical Company Emulsifiable Concentrate 18.20 0

Lorsban Advanced 62719-591-AA Dow Agrosciences LLC Aqueous Concentrate 18.45 728,372

Lock-On Insecticide 62719-79-ZA Dow Agrosciences LLC Emulsifiable Concentrate 20.90 127,051

Govern 4E Insecticide 62719-220-AA-55467 Tenkoz Inc. Emulsifiable Concentrate 50.00 208,994

Warhawk 62719-220-AA-34704 Loveland Products, Inc. Emulsifiable Concentrate 50.00 31,825

Whirlwind 62719-220-AA-5905 Helena Chemical Company Emulsifiable Concentrate 50.00 25,538

Eraser 62719-220-AA-71058 Independent Agribusiness Prof Emulsifiable Concentrate 50.00 218

Agrisolutions Yuma 4E Insecticide 62719-220-AA-1381 Winfield Solutions LLC Emulsifiable Concentrate 50.00 1,272

Hatchet 62719-220-ZC Dow Agrosciences LLC Emulsifiable Concentrate 50.00 344

Lorsban-4E 62719-220-ZA Dow Agrosciences LLC Emulsifiable Concentrate 51.32 83,929

Nufos 4E 67760-28-AA Cheminova, Inc. Emulsifiable Concentrate 52.30 240,390

Chlorpyrifos 4E Ag 66222-19-AA Makhteshim-Agan Emulsifiable Concentrate 52.90 17,302

Quali-Pro Chlorpyrifos 4E 66222-19-AA-73220 Farmsaver.Com, LLC Emulsifiable Concentrate 52.90 47

Quali-Pro Chlorpyrifos 4E 66222-19-ZA Makhteshim-Agan Emulsifiable Concentrate 52.90 0

Warhawk 34704-857-AA Loveland Products, Inc. Aqueous Concentrate 54.41 170,147

Cobalt 62719-575-AA Dow Agrosciences LLC Emulsifiable Concentrate 68.61 22,717
49

Table 8c. Actively registered agricultural products in 2012 containing gibberellins as the primary active ingredient. Products are listed 

in order by emission potential (EP). The product amount is amount applied in the San Joaquin Valley during May-October 2010.

Product Name Registration Number Registrant Formulation EP 

(%)

Product Amt 

(pounds)

Gibgro 20% Powder 55146-53-ZA Nufarm Americas Inc. Dust/Powder 0.00 711

Gibgro 5% Powder 55146-56-ZA Nufarm Americas Inc. Dust/Powder 0.01 121

Pro-Gibb Plus 2x Plant Growth Regulator 73049-16-AA Valent Biosciences Corporation Soluble Powder 1.15 5,505

Release Plant Growth Regulator Soluble Powder 73049-6-AA Valent Biosciences Corporation Soluble Powder 1.15 0

GA3 20% 72639-13-AA LT Biosyn, Inc. Soluble Powder 1.15 852

N-Large 40 SP 57538-22-AA Stoller Enterprises, Inc. Soluble Powder 1.15 0

Falgro 20SP 62097-3-AA-82917 Fine Americas, Inc. Soluble Powder 1.15 445

Progibb 40% Water Soluble Granules 73049-1-AA Valent Biosciences Corporation Granular/Flake 3.70 12,045

Provide 10 SG Plant Growth Regulator 73049-409-AA Valent Biosciences Corporation Granular/Flake 3.70 0

Progibb 40% Plant Growth Regulator 73049-1-ZA Valent Biosciences Corporation Granular/Flake 3.70 0

Fresco 62097-6-ZA-82917 Fine Americas, Inc. Aqueous Concentrate 5.71* 0

Procone Plant Growth Regulator Solution 73049-32-AA Valent Biosciences Corporation Solution/Liquid 7.30* 0

N-Large Premier 57538-20-AA Stoller Enterprises, Inc. Aqueous Concentrate 79.02 974

GA3 4% 72639-8-AA LT Biosyn, Inc. Aqueous Concentrate 92.36 2,412

Gibbmax 69766-1-AA Advanced Foliar Nutrients Systems Other (Liquid) 92.43 20

Falgro 4L 62097-2-AA-82917 Fine Americas, Inc. Solution/Liquid 93.82 28,114

Florgib 4L 62097-10-AA-82917 Fine Americas, Inc. Aqueous Concentrate 93.82 0

Pro-Gibb 4% Plant Growth Regulator Solution 73049-15-AA Valent Biosciences Corporation Aqueous Concentrate 94.13 96,661

Progibb T & O Plant Growth Regulator 73049-15-ZA Valent Biosciences Corporation Aqueous Concentrate 94.13 24

Gibgro 4LS 55146-62-ZA Nufarm Americas Inc. Flowable Concentrate 94.87 61,740

Novagib 10L 62097-7-AA-82917 Fine Americas, Inc. Aqueous Concentrate 98.91 0

* DPR was evaluating the emission potentials for these liquid products. They were assigned default emission potential values on an 

interim basis.
50

Table 8d. Actively registered agricultural products in 2012 containing oxyfluorfen as the primary active ingredient. Products are listed 

in order by emission potential (EP). Products highlighted indicate liquid products with lower emission potentials and considered in 

determining the emission potential threshold for designating low-VOC and high-VOC products. The product amount is amount 

applied in the San Joaquin Valley during May-October 2010.

Product Name Registration Number Registrant Formulation EP 

(%)

Product Amt 

(pounds)

Regal 0-0 Herbicide 48234-10-AA Regal Chemical Company Granular/Flake 3.70 0

Double O E-Pro Herbicide 79676-20-AA Etigra Granular/Flake 3.70 5,400

Permaguard 79676-20-AA-72112 Prokoz, Inc. Granular/Flake 3.70 2,207

Two Ox E-Pro Herbicide 79676-38-AA Etigra Granular/Flake 3.70 0

Nufarm Double O SPC Herbicide 228-632-AA Nufarm Americas Inc. Granular/Flake 3.70 0

Galigan Slapshot 66222-107-ZA Makhteshim-Agan Aqueous Concentrate 3.84 2,771

Galigan H2O 66222-140-AA Makhteshim-Agan Aqueous Concentrate 5.71 427

Willowood Oxyflo 4 SC 87290-10-AA Willowood, LLC Aqueous Concentrate 6.76 0

Ortho Groundclear Superedger Plus Ready To 

Use 239-2516-ZD Scotts Company Solution/Liquid 7.30 0

Goaltender 62719-447-ZA Dow Agrosciences LLC Flowable Concentrate 8.28 16,330

Rout Ornamental Herbicide 58185-27-AA Scotts-Sierra Crop Prot. Co. Granular/Flake 8.60 1,465

Progrow Ornamental Herbicide 2 538-172-AA Scotts Company Granular/Flake 9.17 4,687

OH 2 538-172-ZA Scotts Company Granular/Flake 9.17 1,745

Pindar GT 62719-611-AA Dow Agrosciences LLC Aqueous Suspension 10.60 1,792

Oxystar 4L 42750-199-AA Albaugh, Inc. Emulsifiable Concentrate 10.63 0

Willowood Oxyflo 2 EC 87290-8-AA Willowood, LLC Emulsifiable Concentrate 60.00 21

Goal 2XL 62719-424-AA Dow Agrosciences LLC Emulsifiable Concentrate 62.30 315,487

Oxen Herbicide 34704-877-AA Loveland Products, Inc. Other (Liquid) 64.00 0

Galigan 2E Oxyfluorfen Herbicide 66222-28-AA Makhteshim-Agan Emulsifiable Concentrate 66.15 32,097

Oxystar 2E 42750-136-AA Albaugh, Inc. Emulsifiable Concentrate 73.09 18,411
51

Table 9. VOC emissions from abamectin, chlorpyrifos, gibberellins, and oxyfluorfen products used for production agriculture, 

nonproduction agriculture, and structures in the San Joaquin Valley during May-October, annual average for 2008-2010.

Use Type VOC Emissions (pounds) % of Total Abamectin Chlorpyrifos Gibberellins Oxyfluorfen Sum

Production agriculture 301,490 662,991 268,331 266,721 1,499,533 98.68

Nonproduction agriculture 318 449 668 18,250 19,685 1.30

Structural 133 48 0 130 311 0.02

Total 301,941 663,488 268,999 285,101 1,519,529 100.00
52

Table 10. VOC emissions from abamectin, chlorpyrifos, gibberellins, and oxyfluorfen products by crop or site in the San Joaquin 

Valley during May-October, annual average for 2008-2010.

Crop/Site VOC Emissions (pounds) Percent of 

Total

Cumulative

Abamectin Chlorpyrifos Gibberellins Oxyfluorfen Sum Percent

Almond 165,059 184,506 0 150,065 499,630 32.88 32.88

Citrus 25,134 143,533 108,929 1,102 278,697 18.34 51.22

Grapes 38,954 25,227 146,131 22,767 233,079 15.34 66.56

Cotton 27,363 83,727 0 17,742 128,832 8.48 75.04

Walnut 14,267 75,484 0 18,249 108,000 7.11 82.15

Alfalfa 3,058 104,264 0 5 107,327 7.06 89.21

Pistachio 19 0 0 37,951 37,971 2.50 91.71

Corn 26 36,767 0 26 36,819 2.42 94.13

Cherry 2,033 94 13,315 4,285 19,727 1.30 95.43

Rights of way 77 12 0 17,190 17,279 1.14 96.57

Cantaloupe 4,475 0 0 15 4,489 0.30 96.86

Plum 2,321 8 26 1,522 3,877 0.26 97.12

Watermelons 3,065 0 0 0 3,065 0.20 97.32

Peach 1,275 32 66 1,617 2,990 0.20 97.52

Beans, dried-type 2,449 386 0 35 2,870 0.19 97.70

Lettuce, head 2,548 0 0 0 2,548 0.17 97.87

Asparagus 0 2,151 0 0 2,151 0.14 98.01

Tomatoes 2,020 5 0 32 2,057 0.14 98.15

Nursery-outdoor 529 81 14 1,396 2,020 0.13 98.28

Nectarine 450 10 113 1,180 1,752 0.12 98.40

All other crops 6,821 7,201 405 9,922 24,349 1.60 100.00

Total (pounds) 301,941 663,488 268,999 285,101 1,519,529

Total (tons/day) 0.82 1.80 0.73 0.77 4.13
53

Table 11a. Estimated VOC reductions for various nonfumigant restrictions (negative values) 

and exceptions (positive values) in the San Joaquin Valley during May-October 2006, the 

highest year. The emission potential thresholds (EP thd) are set at the lowest level to achieve 

the greatest reductions. Setting higher emission potential thresholds for abamectin and 

gibberellins could result in less cost.

Scenario

Estimated VOC Reductions (tons/day) with Nonfumigant Restrictions

Abamectin 

EP thd=10%

Chlorpyrifos 

EP thd=25%

Gibberellins 

EP thd=5%

Oxyfluorfen 

EP thd=15% Sum

Estimated reduction

Alfalfa restrictions -0.0069 -0.0978 0.0000 0.0000 -0.1048

Almond restrictions -0.2490 -0.7342 0.0000 -0.2763 -1.2595

Cherry restrictions 0.0000 -0.0007 -0.0220 -0.0145 -0.0373

Citrus restrictions -0.0236 -0.3473 -0.2950 -0.0061 -0.6720

Corn restrictions 0.0000 -0.0397 0.0000 0.0000 -0.0397

Cotton restrictions -0.1089 -0.3897 0.0000 -0.0558 -0.5544

Grape restrictions -0.0365 -0.0469 -0.3955 -0.0433 -0.5223

Pistachio restrictions 0.0000 0.0000 0.0000 -0.0401 -0.0401

Right of way restrictions 0.0000 0.0000 0.0000 -0.0498 -0.0499

Walnut restrictions -0.0157 -0.1566 0.0000 -0.0480 -0.2203

Remaining crops restrictions -0.0350 -0.0433 -0.0036 -0.0360 -0.1179

Sum of all crops/sites -0.4756 -1.8563 -0.7162 -0.5700 -3.6181

Estimated exceptions

Structural 0.0001 0.0002 0.0000 0.0000 0.0003

Non-production ag 0.0002 0.0003 0.0000 0.0204 0.0210

Chlorpyrifos cotton aphids 0.0000 0.0390 0.0000 0.0000 0.0390

Gibberellins ≤16 grams/acre 0.0000 0.0000 0.1403 0.0000 0.1403

Oxyfluorfen ≤0.125 lbs/acre 0.0000 0.0000 0.0000 0.0769 0.0769

Section 18* 0.0131 0.0000 0.0000 0.0000 0.0131

Section 24c* 0.0068 0.0744 0.0072 0.2185 0.3069

USDA/CDFA 0.0000 0.0001 0.0000 0.0000 0.0001

Precision sprayer 0.0048 0.0186 0.0072 0.0057 0.0362

Sum of all exceptions 0.0249 0.1326 0.1547 0.3214 0.6337

Reduction from all crops with 

all exceptions -0.4507 -1.7237 -0.5614 -0.2486 -2.9844

Actual emissions 0.6000 3.9692 0.7607 0.7784 6.1082

* Section 18 for abamectin on lima beans.

** Section 24c for abamectin on alfalfa; chlorpyrifos on citrus; gibberellins on azaleas and 

tangerines; oxyfluorfen on peas, roses, clover, stone fruit, olives, and almonds.
54

Table 11b. Estimated VOC reductions for various nonfumigant restrictions (negative values) 

and exceptions (positive values) in the San Joaquin Valley during May-October 2006, the 

highest year. The emission potential thresholds (EP thd) are set at the highest level to 

achieve the least reductions. Greater reduction could be achieved by setting lower emission 

potential thresholds for abamectin and gibberellins, but that could cause higher cost. 

Scenario

Estimated VOC Reductions (tons/day) with Nonfumigant Restrictions

Abamectin 

EP thd=35%

Chlorpyrifos 

EP thd=25%

Gibberellins 

EP thd=25%

Oxyfluorfen 

EP thd=15% Sum

Estimated reductions

Alfalfa restrictions -0.0031 -0.0978 0.0000 0.0000 -0.1009

Almond restrictions -0.1037 -0.7342 0.0000 -0.2763 -1.1142

Cherry restrictions 0.0000 -0.0007 -0.0171 -0.0145 -0.0323

Citrus restrictions -0.0098 -0.3473 -0.2281 -0.0061 -0.5914

Corn restrictions 0.0000 -0.0397 0.0000 0.0000 -0.0397

Cotton restrictions -0.0456 -0.3897 0.0000 -0.0558 -0.4911

Grape restrictions -0.0150 -0.0469 -0.3064 -0.0433 -0.4116

Pistachio restrictions 0.0000 0.0000 0.0000 -0.0401 -0.0401

Right of way restrictions 0.0000 0.0000 0.0000 -0.0498 -0.0499

Walnut restrictions -0.0055 -0.1566 0.0000 -0.0480 -0.2101

Remaining crops restrictions -0.0149 -0.0433 -0.0030 -0.0360 -0.0972

Sum of all crops/sites -0.1975 -1.8563 -0.5546 -0.5700 -3.1785

Estimated exceptions

Structural 0.0001 0.0002 0.0000 0.0000 0.0003

Nonproduction ag 0.0002 0.0003 0.0000 0.0204 0.0210

Chlorpyrifos cotton aphids 0.0000 0.0390 0.0000 0.0000 0.0390

Gibberellins ≤16 grams/acre 0.0000 0.0000 0.1403 0.0000 0.1403

Oxyfluorfen ≤0.125 lbs/acre 0.0000 0.0000 0.0000 0.0769 0.0769

Section 18* 0.0131 0.0000 0.0000 0.0000 0.0131

Section 24c** 0.0068 0.0744 0.0072 0.2185 0.3069

USDA/CDFA 0.0000 0.0001 0.0000 0.0000 0.0001

Precision sprayer 0.0020 0.0186 0.0055 0.0057 0.0318

Sum of all exceptions 0.0222 0.1326 0.1531 0.3214 0.6293

Reduction from all crops with 

all exceptions -0.1754 -1.7237 -0.4015 -0.2486 -2.5492

Actual emissions 0.6000 3.9692 0.7607 0.7784 6.1082

* Section 18 for abamectin on lima beans.

** Section 24c for abamectin on alfalfa; chlorpyrifos on citrus; gibberellins on azaleas and 

tangerines; oxyfluorfen on peas, roses, clover, stone fruit, olives, and almonds.
55

Table 12a. Estimated VOC emissions with various nonfumigant active ingredient and crop 

restrictions. All scenarios assume that the emission potential thresholds for abamectin and 

gibberellins products are set at the lowest level of 10% and 5%, respectively. All scenarios 

assume that the fumigant regulations reduce fumigant VOC emissions by 37%. Lower 

emission levels are achieved by restricting more nonfumigant active ingredients and/or more 

crops. Emissions are estimated for the San Joaquin Valley during May-October 2006, the 

highest year. Actual emissions for 2006 were 21.3 tons/day. The emission level goal for these 

nonfumigant restrictions combined with the fumigant regulations is 17.2 tons/day (trigger for 

additional restrictions) or less. Highlighted values indicate scenarios that achieve the 

emission level goal.

Scenario

Estimated VOC Emissions (tons/day) with Lowest Emission 

Potentials, Fumigant Regs, and Nonfumigant Restrictions

Top Active 

Ingredient

(Chlorpyrifos)

Top 2 Active 

Ingredients

(Previous+

Oxyfluorfen)

Top 3 Active 

Ingredients

(Previous+

Gibberellins)

Top 4 Active 

Ingredients

(Previous+

Abamectin)

Estimated emissions with nonfumigant restrictions and no exceptions

Top crop (almond) 18.052 17.776 17.776 17.527

Top 2 crops (previous+citrus) 17.705 17.422 17.127 16.855

Top 3 crops (previous+cotton) 17.315 16.977 16.682 16.300

Top 4 crops (previous+grape) 17.268 16.886 16.196 15.778

Top 5 crops (previous+walnut) 17.111 16.682 15.991 15.558

Top 6 crops (previous+alfalfa) 17.013 16.584 15.893 15.453

Top 7 crops (previous+right of way) 17.013 16.534 15.844 15.403

Top 8 crops (previous+pistachio) 17.013 16.494 15.803 15.363

Top 9 crops (previous+corn) 16.974 16.454 15.764 15.323

Top 10 crops (previous+cherry) 16.973 16.439 15.726 15.286

All crops 16.930 16.360 15.644 15.168

Estimated emissions with nonfumigant restrictions and all exceptions*

Top crop (almond) 18.1845 18.0970 17.9303 17.5515

Top 2 crops (previous+citrus) 17.8372 17.7435 17.2818 16.8794

Top 3 crops (previous+cotton) 17.4474 17.2980 16.8363 16.3250

Top 4 crops (previous+grape) 17.4005 17.2078 16.3505 15.8027

Top 5 crops (previous+walnut) 17.2439 17.0032 16.1459 15.5825

Top 6 crops (previous+alfalfa) 17.1461 16.9053 16.0481 15.4777

Top 7 crops (previous+right of way) 17.1461 16.8555 15.9982 15.4278

Top 8 crops (previous+pistachio) 17.1461 16.8153 15.9581 15.3877

Top 9 crops (previous+corn) 17.1064 16.7757 15.9184 15.3480

Top 10 crops (previous+cherry) 17.1057 16.7604 15.8811 15.3107

All crops 17.0623 16.6811 15.7982 15.1928

* Possible exceptions to nonfumigant restrictions include the following uses: chlorpyrifos for 

cotton aphid, gibberellins ≤16 grams/acre, oxyfluorfen ≤0.125 lbs/acre, Section 18, Section 

24c, USDA/CDFA projects, and smart sprayers.
56

Table 12b. Estimated VOC emissions with various nonfumigant active ingredient and crop 

restrictions. All scenarios assume that the emission potential thresholds for abamectin and 

gibberellins products are set at the highest level of 35% and 25%, respectively. All scenarios 

assume that the fumigant regulations reduce fumigant VOC emissions by 37%. Lower 

emission levels are achieved by restricting more nonfumigant active ingredients and/or more 

crops. Emissions are estimated for the San Joaquin Valley during May-October 2006, the 

highest year. Actual emissions for 2006 were 21.3 tons/day. The emission level goal for these 

nonfumigant restrictions combined with the fumigant regulations is 17.2 tons/day (trigger for 

additional restrictions) or less. Highlighted values indicate scenarios that achieve the 

emission level goal. 

Scenario

Estimated VOC Emissions (tons/day) with Highest Emission 

Potentials, Fumigant Regs, and Nonfumigant Restrictions

Top Active 

Ingredient

(Chlorpyrifos)

Top 2 Active 

Ingredients

(Previous+

Oxyfluorfen)

Top 3 Active 

Ingredients

(Previous+

Gibberellins)

Top 4 Active 

Ingredients

(Previous+

Abamectin)

Estimated emissions with nonfumigant restrictions and no exceptions

Top crop (almond) 18.052 17.776 17.776 17.672

Top 2 crops (previous+citrus) 17.705 17.422 17.194 17.080

Top 3 crops (previous+cotton) 17.315 16.977 16.748 16.589

Top 4 crops (previous+grape) 17.268 16.886 16.352 16.178

Top 5 crops (previous+walnut) 17.111 16.682 16.147 15.968

Top 6 crops (previous+alfalfa) 17.013 16.584 16.049 15.867

Top 7 crops (previous+right of way) 17.013 16.534 16.000 15.817

Top 8 crops (previous+pistachio) 17.013 16.494 15.959 15.777

Top 9 crops (previous+corn) 16.974 16.454 15.920 15.737

Top 10 crops (previous+cherry) 16.973 16.439 15.887 15.705

All crops 16.930 16.360 15.805 15.608

Estimated emissions with nonfumigant restrictions and all exceptions*

Top crop (almond) 18.1845 18.0970 17.9287 17.6940

Top 2 crops (previous+citrus) 17.8372 17.7435 17.3471 17.1026

Top 3 crops (previous+cotton) 17.4474 17.2980 16.9016 16.6115

Top 4 crops (previous+grape) 17.4005 17.2078 16.5050 16.2000

Top 5 crops (previous+walnut) 17.2439 17.0032 16.3004 15.9899

Top 6 crops (previous+alfalfa) 17.1461 16.9053 16.2025 15.8890

Top 7 crops (previous+right of way) 17.1461 16.8555 16.1526 15.8391

Top 8 crops (previous+pistachio) 17.1461 16.8153 16.1125 15.7990

Top 9 crops (previous+corn) 17.1064 16.7757 16.0728 15.7593

Top 10 crops (previous+cherry) 17.1057 16.7604 16.0405 15.7270

All crops 17.0623 16.6811 15.9582 15.6297

* Possible exceptions to nonfumigant restrictions include the following uses: chlorpyrifos for 

cotton aphid, gibberellins ≤16 grams/acre, oxyfluorfen ≤0.125 lbs/acre, Section 18, Section 

24c, USDA/CDFA projects, and smart sprayers.
57

Table 13. Overview of enforcement options for nonfumigant restrictions. All options include sales and/or use restrictions on certain 

high-VOC products in the San Joaquin Valley (SJV) during May-October. Some options are more stringent, causing a greater burden. 

The selected options are highlighted.

Option Statewide/all year

or SJV/May-Oct

VOC reduction 

achieved

Fumigant limit

trigger

Compliance and

enforceability Extra impact*

1-Cancel high-VOC product 

registrations, with 

exceptions

Statewide, 

all year

Likely more 

than required Unchanged High, if few exceptions Growers

2-Prohibit use of high-VOC 

products, with exceptions

Statewide or SJV, 

all year or May-Oct

Likely more 

than required Unchanged High, if extensive outreach occurs

Growers

3-Designate additional 

restricted materials SJV, May-Oct Required reduction Replaced?? High Ag commissioners, some growers

4a-If triggered, high-VOC 

use restrictions; plus use 

“authorizations”

SJV, May-Oct Required 

reduction Replaced High, if outreachoccurs

Possibly ag 

commissioners, 

growers

4b-If triggered, high-VOC 

use restrictions; plus dealer 

requirements

SJV, May-Oct Required 

reduction Replaced High Possibly dealers

4c-If triggered, high-VOC 

use restrictions; plus pest 

control adviser

recommendation

SJV, May-Oct Required 

reduction Replaced High, if outreachoccurs

Possibly some 

growers

* Growers and applicators are impacted under all of the options because applications may be required to use low-VOC products. The 

extra impact indicated reflects the relative workload and problems of making this change.
58

Table 14. Estimated applications that would be affected by nonfumigant high-VOC 

restrictions. Estimates are based on applications for all crops in the San Joaquin Valley for 

the most recent reported year during rulemaking (May-October, 2010). These estimates 

assume that the emission potential thresholds for abamectin and gibberellins products are set 

at the highest level of 35% and 25%, respectively. The estimates for the applications affected 

with the lowest emission potential thresholds would likely be the same or very similar. 

Application Parameters Abamectin Chlorpyrifos Gibberellins Oxyfluorfen Sum 

Total applications

Number of applications 20,315 10,420 10,390 9,593 50,178

Area treated (acres) 1,662,438 2,560,976 382,989 444,103 5,050,506

Active ingredient (pounds) 13,685 766,524 16,160 100,073 896,442

Applications that used high-VOC products

Number of applications 17,961 4,601 8,110 8,673 39,345

Area treated (acres) 1,460,409 315,564 267,820 402,002 2,445,795

Active ingredient (pounds) 13,663 397,583 10,250 90,589 512,085

Applications that used low-VOC products

Number of applications 2,354 5,819 2,280 920 11,373

Area treated (acres) 202,029 2,245,412 115,169 42,102 2,604,712

Active ingredient (pounds) 22 368,941 5,910 9,484 384,357

Applications that used high-VOC products for an exception

Number of applications 105 522 3,306 1,448 5,381

Area treated (acres) 8,220 43,959 125,795 73,286 251,260

Active ingredient (pounds) 91 44,278 1,229 14,372 59,970

High-VOC applications that would switch to low-VOC due to restrictions (exceptions do not switch)

Number of applications 17,856 4,079 4,804 7,225 33,964

Area treated (acres) 1,452,189 271,605 142,026 328,716 2,194,536

Active ingredient (pounds) 13,572 353,306 9,021 76,217 452,116

Percent that used high-VOC products

 % of applications 88.41 44.16 78.06 90.41 77.58

 % of area treated (acres) 87.85 12.32 69.93 90.52 48.43

 % of active ingredient (lbs) 99.84 51.87 63.43 90.52 57.12

Percent that used low-VOC products

 % of applications 11.59 55.84 21.94 9.59 22.42

 % of area treated (acres) 12.15 87.68 30.07 9.48 51.57

 % of active ingredient (lbs) 0.16 48.13 36.57 9.48 42.88

Percent that would switch to low-VOC products due to restrictions (exceptions do not switch)

% of applications 87.90 39.15 46.24 75.32 66.97

% of area treated (acres) 87.35 10.61 37.08 74.02 43.45

% of active ingredient (lbs) 99.17 46.09 55.82 76.16 50.43
59

Figures

Figure 1. Ozone nonattainment areas included in the pesticide element of the SIP.
60

Figure 2a. Pesticide VOC emissions inventory for the Sacramento Metro ozone NAA during 

May-October. The solid horizontal line indicates the SIP goal.

Figure 2b. Pesticide VOC emissions inventory for the South Coast ozone NAA during 

May-October. The solid horizontal line indicates the SIP goal.

0.0

0.5

1.0

1.5

2.0

2.5

3.0

1990 2008 2009 2010 2011 2012

VOC Emissions (tons/day)

Fumigant Nonfumigant - ECs Nonfumigant - Others

0.0

2.0

4.0

6.0

8.0

10.0

12.0

1990 2008 2009 2010 2011 2012

VOC Emissions (tons/day)

Fumigant Nonfumigant - ECs Nonfumigant - Others
61

Figure 2c. Pesticide VOC emissions inventory for the Southeast Desert ozone NAA during 

May-October. The solid horizontal line indicates the SIP goal.

Figure 2d. Pesticide VOC emissions inventory for the Ventura ozone NAA during 

May-October. The solid horizontal lines indicate the phased in SIP goal. Final goal is 3.0 

tons/day in 2012.

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1990 2008 2009 2010 2011 2012

VOC Emissions (tons/day)

Fumigant Nonfumigant - ECs Nonfumigant - Others

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

1990 2008 2009 2010 2011 2012

VOC Emissions (tons/day)

Fumigant Nonfumigant - ECs Nonfumigant - Others
62

Figure 2e. Pesticide VOC emissions inventory for the San Joaquin Valley ozone NAA during 

May-October. The solid horizontal line indicates the SIP goal. The dashed horizontal line 

indicates the trigger for additional restrictions.

0.0

5.0

10.0

15.0

20.0

25.0

1990 2008 2009 2010 2011 2012

VOC Emissions (tons/day)

Fumigant Nonfumigant - ECs Nonfumigant - Others
63

Figure 3. VOC emission trends of major nonfumigant pesticides in the San Joaquin Valley.

The two charts have different scales.
64

Figure 4a. Abamectin product and VOC emissions trends for the San Joaquin Valley. 

Emissions are expressed as pounds of VOC per pound of active ingredient applied. An 

increasing trend indicates use of products with higher emission potentials over time. A 

decreasing trend indicates use of products with lower emission potentials over time.

Figure 4b. Chlorpyrifos product and VOC emissions trends for the San Joaquin Valley. 

Emissions are expressed as pounds of VOC per pound of active ingredient applied. An 

increasing trend indicates use of products with higher emission potentials over time. A 

decreasing trend indicates use of products with lower emission potentials over time.

25

26

27

28

29

30

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Pounds VOC/Pounds AI

Abamectin

0.00

0.25

0.50

0.75

1.00

1.25

1.50

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Pounds VOC/Pounds AI

Chlorpyrifos
65

Figure 4c. Gibberellins product and VOC emissions trends for the San Joaquin Valley. 

Emissions are expressed as pounds of VOC per pound of active ingredient applied. An 

increasing trend indicates use of products with higher emission potentials over time. A 

decreasing trend indicates use of products with lower emission potentials over time.

Figure 4d. Oxyfluorfen product and VOC emissions trends for the San Joaquin Valley. 

Emissions are expressed as pounds of VOC per pound of active ingredient applied. An 

increasing trend indicates use of products with higher emission potentials over time. A 

decreasing trend indicates use of products with lower emission potentials over time.

0

2

4

6

8

10

12

14

16

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Pounds VOC/Pound AI

Gibberellins

0.0

0.5

1.0

1.5

2.0

2.5

3.0

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Pounds VOC/Pound AI

Oxyfluorfen
66

Possible Nonfumigant Product 

Emission Potential Thresholds

Abamectin: 35% or 10%

Chlorpyrifos: 25%

Gibberellins: 25% or 5%

Oxyfluorfen: 15%

Possible Nonfumigant Reductions 

by Active Ingredient (all crops)

Chlorpyrifos: 1.856 tons/day

Oxyfluorfen: 0.570 tons/day

Gibberellins 0.555 or 0.716 tons/day

Abamectin: 0.198 or 0.476 tons/day

TOTAL: 3.179 or 3.618 tons/day

Possible Nonfumigant Reductions 

by Crop (all 4 active ingredients)

Almond: 1.114 or 1.260 tons/day

Citrus: 0.591 or 0.672 tons/day

Cotton 0.491 or 0.554 tons/day

Grape: 0.412 or 0.522 tons/day

Walnut: 0.210 or 0.220 tons/day

Alfalfa: 0.101 or 0.105 tons/day

Right of way: 0.050 tons/day

Pistachio: 0.040 tons/day

Corn: 0.040 tons/day

Cherry: 0.032 or 0.037 tons/day

All other crops: 0.097 or 0.118 tons/day

TOTAL: 3.179 or 3.618 tons/day

Possible Nonfumigant Reductions Not 

Achieved from Exclusions and Exceptions

Structural use: 0.0003 tons/day

Non-production ag use: 0.0210 tons/day

Chlorpyrifos on cotton aphid: 0.0390 tons/day

Gibberellins rate <16 g/ac: 0.1403 tons/day

Oxyfluorfen <0.125 lbs/ac: 0.0769 tons/day

Exempt registration-Sec 18: 0.0131 tons/day

Special Local Need-Sec 24c: 0.3069 tons/day

USDA/CDFA use: 0.0001 tons/day

Precision sprayer: 0.0362 tons/day

TOTAL: 0.6337 tons/day

Target

Fumigant and nonfumigant restrictions reduce VOC 

emissions by at least 4.1 tons/day in worst-case year 

(from 21.3 to <17.2 tons/day (trigger) in 2006)

Reductions from Fumigant Restrictions

Low-emission fumigation methods: 

2.5 tons/day

Figure 5. Overview of the possible scope and estimated VOC reductions for nonfumigant 

restrictions in the San Joaquin Valley during May-October. Reductions are achieved with 

restrictions on products that exceed emission potential thresholds. DPR must balance four 

factors to achieve the target VOC reductions from nonfumigant restrictions: the pesticide 

products (by active ingredient) included, the emission potential thresholds selected, the crops 

included, and the exceptions included. Where more than one emission estimate is shown, the 

differences are due to different emission potential thresholds. Fumigant restrictions 

contribute additional reductions.
67

Figure 6a. Estimated pesticide VOC emissions for various reduction scenarios by active 

ingredient for the San Joaquin Valley during May-October 2006, the highest year. Estimates 

include all crops, highest emission potentials, and all exceptions. The solid horizontal line 

indicates the SIP goal. The dashed horizontal line indicates the trigger for additional 

restrictions. Actual pesticide VOC emissions for 2006 were 21.3 tons/day. The emissions 

include an estimated reduction of 2.5 tons/day due to the 2008 fumigant regulations.

10

12

14

16

18

20

Top AI (chlorpyrifos) Top 2 AIs

(previous+oxyfluorfen)

Top 3 AIs

(previous+gibberellins)

Top 4 AIs

(previous+abamectin)

VOC Emissions (tons/day)
68

Figure 6b. Estimated pesticide VOC emissions for various reduction scenarios by crop for the 

San Joaquin Valley during May-October 2006, the highest year. Estimates include the top 

four active ingredients, highest emission potentials, and all exceptions. The solid horizontal 

line indicates the SIP goal. The dashed horizontal line indicates the trigger for additional 

restrictions. Actual pesticide VOC emissions for 2006 were 21.3 tons/day. The emissions 

include an estimated reduction of 2.5 tons/day due to the 2008 fumigant regulations.

10

12

14

16

18

20

VOC Emissions (tons/day)