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Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA): Agriculture-Related Enforcement Cases 2004

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The following are agriculture-related enforcement cases pertaining to the Federal Insecticide, Fungicide, Rodenticide Act.  This information is provided for reference. Over time, links to news items may become unavailable. In these cases the item will remain listed, but no link will be provided. Also, please be aware that the information in any particular article may be outdated or superseded by additional information.

EPA Enforcement Cases 2008 through present

EPA Enforcement Cases 2007

EPA Enforcement Cases 2006

EPA Enforcement Cases 2005

EPA Enforcement Cases 2004

EPA Enforcement Cases 2003

EPA Enforcement Cases 2002

EPA Enforcement Cases 2001

EPA Enforcement Cases 1999 and 2000

October 7, 2004

EPA Fines Los Angeles Company for Selling Unregistered Pesticides
EPA fined Los Angeles-based Vernon Sales Inc. $4,400 for allegedly selling unregistered pesticides in violation of the Federal Insecticide, Fungicide, and Rodenticide Act. EPA cited the company for allegedly selling or distributing Limon Lysol Antibacterial, Pino Lysol Antibacterial, De La Nines Lysol Antibacterial, and Lavanda Lysol Antibacterial, without EPA registration numbers. The civil complaint was based on an inspection conducted by the California Department of Pesticide Regulation.

"Companies must register their pesticides with EPA," said Enrique Manzanilla, director of EPA's Cross Media Division. "Without EPA registration, we have no information on the effects of the products, which could result in harm to public health and the environment." Federal law requires that before selling or distributing a pesticide in the U.S., companies must register the pesticide with EPA. Pesticides that have been registered with the Agency will have an EPA registration number on the label. Each producer, seller, and distributor have certain obligations to ensure that the pesticide being produced, distributed, or sold is properly registered and labeled.

Before registering a new pesticide or approving a new use for a registered pesticide, EPA must first ensure that the pesticide, when used according to label directions, does not pose unreasonable risks to people or the environment. The Agency also ensures that pesticide labels provide consumers with the information they need to use the products safely. To assist the public and regulated community, EPA and the California Department of Pesticide Regulation provide Internet access to registration information on approximately 90,000 products.

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October 7, 2004

EPA Cites Two Businesses for Selling Illegal Pesticides
EPA is seeking $57,750 in fines from an Orange, Calif. firm and $40,400 in fines from a St. Louis firm for violations of federal pesticide laws. EPA cited Eagle One Golf Products, 1201 West Katella Avenue, Orange, Calif., for allegedly selling an unregistered pesticide to homeowners' associations and golf courses. Bio Logix Algae Treatment, which is designed to control algae in ponds, was initially sold and distributed illegally by a St. Louis-based firm, Biologix Products Group, under the name "WaterTreat 100." EPA is fining Biologix $40,040 for selling and distributing an illegal pesticide.

EPA discovered the violations through information obtained during an inspection by the California Department of Pesticide Regulation. "Firms must register their products with EPA if they wish to sell them as pesticides. We will continue to pursue both distributors and retailers of unregistered pesticides." said Enrique Manzanilla, director of the EPA's Cross Media Division. "Without the proper registration, we have no information on the effects of these products, which could lead to harm to public health and the environment." Pesticides that have been registered with the Agency will have an EPA registration number on the label. EPA will not register a pesticide without information to show that it will not pose an unreasonable risk when used according to the label. The Agency ensures that pesticide labels provide consumers with the information they need to use the products safely.

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October 1, 2004

Illinois Company Cited for Pesticide Export Violations
EPA filed an administrative complaint against Nufarm Americas Inc., Chicago Heights, Ill., for improperly exporting unregistered pesticide products. A $33,000 penalty has been proposed. In a six-count notice of violation, Nufarm was cited for exporting Atila 41% Herbicida-Fosfonico Glifosato, Marmina 6 D Herbicida Solucion Concentrada Acuosa, Marman 24-De 60 SL Marman Amina 6D, and 2,4-D/Mecoprop Manufacturing Concentrate. The products were exported to Mexico, El Salvador, and Canada.

In order to export pesticides unregistered in the U.S., the exporter must, among other things, obtain a written acknowledgment that the purchaser understands the product is not registered and cannot be sold in the U.S. Nufarm failed to do this. The violations were discovered during inspections in March 2004. EPA registers all pesticides and pesticide products under the Federal Insecticide, Fungicide and Rodenticide Act. Except for certain limited exemptions, no pesticide may be legally sold, distributed or exported from the U.S. unless its label has an EPA registration number. Nufarm can request a hearing to discuss the charges.

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September 30, 2004

EPA Fines Two Ontario, Calif. Companies for Pesticide Violations
EPA fined two Ontario, Calif. companies a combined total of $58,481 for violations of federal pesticide regulations. EPA fined Everkleen Enterprises $2,381 for allegedly producing a pesticide in an unregistered establishment, and Cardenas Markets, Inc. $56,100 for the alleged sale and distribution of two unregistered pesticides. EPA cited Everkleen Enterprises for allegedly producing Cardenas Pine Cleaner without a registered establishment number. Cardenas Markets, Inc. was fined for the alleged sale and distribution of two pine cleaner products, Cardenas Pine Cleaner and Pinol. Cardenas Pine Cleaner's label claims that it “kills household germs,” while Pinol's label claims it is a “disinfectant.”

“Companies must register their pesticides and the establishments in which they are produced with EPA,” said Enrique Manzanilla, director of the EPA's Cross Media Division. “Without EPA registration, we have no information on the effects of these products, which could lead to harm to public health and the environment.” The enforcement actions were based on information obtained during inspections at both facilities by the California Department of Pesticide Regulation. As in this case, when adequate evidence exists, the EPA will take action against both the producer and retailer of unregistered pesticides. Federal law requires that before selling or distributing a pesticide in the United States, companies must register the pesticide with the EPA. Pesticides that have been registered with the agency will have an EPA registration number on the label. Each producer, seller, and distributor has certain obligations to ensure that the pesticide being produced, distributed, or sold is properly registered and labeled. To assist the public and regulated community, EPA and the California Department of Pesticide Regulation provide internet access to registration information on approximately 90,000 products.

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September 16, 2004

EPA Cites Company for Improper Sale and Distribution of Pesticide to Nevada Business
EPA cited a pesticide dealer $3,850 for improperly distributing and selling a restricted-use pesticide to a non-certified applicator, a violation of the Federal Insecticide, Fungicide and Rodenticide Act. EPA cited Salt Lake City-based Steve Regan Company for allegedly distributing and selling Diazinon 4F/AG500 to Whipple Pest Control, a non-certified applicator in Mesquite, Nevada. Diazinon 4F/AG500, a restricted use pesticide, is used to control insects in agricultural crops and other plants. EPA regulations specify that restricted-use pesticides can only be applied by a certified applicator, or by a person supervised by a certified applicator.

"Restricted use pesticides must be handled carefully in order to protect the users and the environment," said Enrique Manzanilla, director of the EPA's Cross Media Division. "Companies selling these chemicals must make sure that they do not fall into inexperienced hands." EPA classifies certain pesticides that present significant human health or environmental hazards as restricted use pesticides. In order to minimize risks to human health and the environment, EPA requirements limit the use of restricted-use pesticides to trained applicators. EPA regulations outline specific certification and training requirements necessary to qualify applicators to use these types of pesticides. Nevada Department of Agriculture inspectors discovered the violations during an inspection of the Whipple Pest Control facility in March 2003.

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September 16, 2004

EPA Agreement With Aquascape Designs Includes $36,650 Fine and Sale Stoppage (PDF) (207pp, 492K) (Scroll down to page 124)
EPA recently reached agreement with Aquascape Designs Inc., Batavia, Ill. Under the agreement, the company will pay a $36,650 penalty for illegally selling and distributing seven unregistered pesticides. The products, ADI S.A.B., ADI EcoBlast, Ecosystems Barley Pellets, Pond Balance, NP EcoBalance, NP EcoBalance Plus with Barley, and ADI AquaClearer Bacteria made claims of algae control in ponds and water features but were not registered with EPA as required. In June, EPA also ordered Aquascape Designs to stop selling, distributing, or using the unregistered products S.A.B., AquaClearer, Supercharged AquaClearer, and Barley Mats.

According to Karl Bremer, chief of EPA Region 5's pesticides and toxics branch, "Consumers should make sure that any product with pesticide claims is registered with EPA. Only then can they be certain that the product will not cause adverse effects on the environment or people." EPA registers all pesticides and pesticide products under the Federal Insecticide, Fungicide and Rodenticide Act. Except for certain limited exemptions, no pesticide may be legally sold or used in the U.S. unless its label has an EPA registration number. It is also unlawful to use any registered pesticides in a manner other than that indicated on the product label.

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September 15, 2004

EPA Penalizes Twin Falls Pesticides Company $9,960
EPA has reached an agreement with WaterTech, a Twin Falls-based pesticide manufacturer, to resolve EPA complaints that the company violated federal pesticide labeling laws. An inspection by the Idaho State Department of Agriculture found that on a number of occasions in 2003 and 2004 WaterTech sold and distributed mislabeled CWT-257, a pesticidel product used to control bacteria, fungi, and algae in industrial and commercial recirculating cooling water systems, air washer systems, and paper manufacturing. The labeling lacked the required full precautionary and first aid statements, and contained incorrect directions for use. The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) establishes clear labeling requirements to protect users, the public, and the environment from accidental misuse of potentially harmful chemicals. Selling and/or distributing mislabeled pesticides may lead to penalties of up to $5,500 per violation. WaterTech has agreed to pay $9,960 in penalties for the mislabeling violations.

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August 19, 2004

EPA Cites Las Vegas Store for Selling Canceled Pesticide Product
EPA fined the owner of a discount store $4,400 for allegedly selling a pesticide product that was canceled by EPA more than two years ago, in violation of the Federal Insecticide, Fungicide and Rodenticide Act. EPA alleged that Greenbacks, Inc. sold "Tiny Tiger" flea and tick cat collars at a Las Vegas store subsequently purchased by Dollar Tree Stores, Inc. The collars contained a pesticide, chlorpyrifos, which was canceled by the EPA for nearly all home uses in 2002 because children might be harmed by exposure to the chemical. "Retailers need to remove canceled pesticide products from their shelves," says Enrique Manzanilla, director of EPA's Cross Media Division. "EPA often cancels certain uses of pesticides because of concerns about children's exposure to these chemicals."

In the late 1990s, EPA began a review of all pesticides to ensure that they were able to meet the tough, new safety standards established in 1996 through the Food Quality Protection Act. Based on this review, the EPA canceled chlorpyrifos for nearly all indoor and outdoor residential uses. Chlorpyrifos is one of the most widely used insecticides in the country. Its uses include controlling pests on fruits and vegetables, golf courses and utility poles and fenceposts. EPA issued the civil complaint against Dollar Tree Stores, Inc. based on an inspection of the store conducted in March 2003 by the Nevada Department of Agriculture. In June 2003 Greenbacks merged into Dollar Tree.

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July 29, 2004

EPA Agreement With Minnesota Company Includes Fine, Immediate Sale Stoppage (PDF) (207pp, 492K) (Scroll down to page 99)
EPA recently reached agreement with Greener Pastures Development Corporation, Oakdale, Minn. Under the agreement, the company will pay a $25,000 penalty for illegally selling and distributing four unregistered pesticides; two for use in controlling algae in ponds and two for killing weeds in lawns. EPA ordered Greener Pastures to stop selling, distributing or using all unregistered pesticides, including but not limited to “Tiger-by-the-Tail,” “Nature’s Weed & Feed 7-0-7,” “Nature’s Weed Control for Ponds,” and “Clarify.” In addition to the fine and stop-sale order, Greener Pastures must remove all pesticide claims from its Web sites, advertising, labeling, or other communications.

EPA worked closely with the Minnesota Department of Agriculture (MDA), the state’s lead agency for pesticide enforcement. MDA performed inspections and provided testimony in support of EPA’s action. The collaboration between the state and federal agencies was instrumental in reaching this agreement. According to Karl Bremer, chief of EPA Region 5's pesticides and toxics branch, “Consumers should make sure that any product with pesticide claims is registered with EPA. Only then can they be certain that the product will not cause adverse effects on the environment or people.” EPA registers all pesticides and pesticide products under the Federal Insecticide, Fungicide, and Rodenticide Act. Except for certain limited exceptions, no pesticide may be legally sold or used in the U.S. unless its label has an EPA registration number. It is also unlawful to use any registered pesticides in a manner other than that indicated on the product label.

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July 29, 2004

EPA Cites National Liquidators and Odd Job for Selling Illegal Household Pesticides
EPA cited National Wholesale Liquidators and Odd-Job Stores, Inc. for illegally selling misbranded household pesticide products from Canada in the U.S. The Agency is seeking more than $500,000 in combined penalties for numerous violations of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The complaints against these two large retail outlets are based on the findings of EPA and state investigations conducted in New York, New Jersey, Pennsylvania, and Connecticut. All products containing a pesticide must have an EPA registration number and conform to EPA labeling requirements.

"Consumers should not buy products that claim to eliminate insects, rodents, microorganisms, and bacteria but do not carry EPA-approved labels for use in this country," EPA Regional Administrator Jane M. Kenny warned. "While these products may be perfectly legal to sell in Canada, such products are not approved by EPA and may not carry proper precautions on their labels." EPA charged National Wholesale Liquidators, headquartered in West Hempstead, New York, with 83 violations of FIFRA at its stores in New York, New Jersey, Pennsylvania, and Connecticut. The Agency is seeking fines of $273,900 against the retailer for illegally distributing a wide variety of misbranded household pesticide products in 2002. EPA cited Odd-Job Stores, Inc, headquartered in South Plainfield, New Jersey, for 77 violations of FIFRA involving the illegal distribution and sale of misbranded disinfectant products since at least 2002. EPA proposed a fine of $254,100 against the retailer.

In order for a pesticide product to be used legally in the U.S., it must have two sets of numbers on the front label of the container. The first number (EPA registration number) indicates that the product is registered with EPA. The second number (EPA establishment registration number) is placed at the bottom of the label and shows which facility manufactured the product. To come into compliance with FIFRA regulations, National Wholesale Liquidators and Odd-Job Stores, Inc. must voluntarily recall the misbranded products from all their outlets and provide documentation that the products in question were sent back to their point of origin or disposed of at a licensed facility as hazardous waste. Both companies have the opportunity to plead their case before an administrative law judge or to contact EPA to negotiate an informal settlement of the matter.

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July 8, 2004

EPA Fines Yuma Company $4,400 for Pesticide Violations
EPA fined Gowan Milling of Yuma, Ariz. $4,400 for allegedly failing to submit 2003 pesticide reports, a violation of the federal pesticide law. "Companies must report their pesticide production in a timely manner," said Enrique Manzanilla, the EPA's Cross Media Division director for the Pacific Southwest region. "EPA uses these reports to track pesticides and ensure safe management and distribution." Under the Federal Insecticide, Fungicide, and Rodenticide Act, companies must annually report pesticide production to EPA by March 1. Production records provide information on the quantities of pesticides produced and distributed. EPA also fined two So. Calif. companies a total of $9,900 for similar violations in Azusa and North Hollywood.

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July 8, 2004

EPA Fines Two So. Calif. Pesticide Companies
EPA fined two California businesses in Azusa, and North Hollywood a total of $9,900 for allegedly failing to submit 2003 pesticide reports, a violation of the federal pesticide law. The company Dunhill Chemical Company of Azusa was fined $4,400. OPI Products of North Hollywood was fined $5,500. "Companies must report their pesticide production in a timely manner," said Enrique Manzanilla, the EPA's Cross Media Division director for the Pacific Southwest region. "EPA uses these reports to track pesticides and ensure safe management and distribution." Under the Federal Insecticide, Fungicide and Rodenticide Act, companies must annually report pesticide production to the EPA by March 1. Production records provide information on the quantities of pesticides produced and distributed.

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June 10, 2004

EPA Orders ‘Stop Sale’ of Product that Claims To Neutralize Anthrax
The owner of 1st EnviroSafety Inc. of St. James, Fla., was ordered by EPA on May 26 to stop Web site sales of unregistered pesticide products, including one that claims to neutralize the effects of anthrax bacteria. The products involved are “Organic Cleaner/Degreaser (Military Strength);” “Organic Veggie Wash;” “Yacht & Boat Bath (Organic);” “Any Floors #123;” “ECCO Dishwashing Machine Concentrate;” “ECCO Commercial All Purpose;" "Industrial Cleaner/Degreaser;” “Organic - Bath & Tile;” “Organic - Pet Care;” and “Organic - Multi-Purpose.” Among its public health claims, the company says that "Organic Cleaner/Degreaser “helped neutralize anthrax in the U.S. Justice Department building. Other products claimed to eliminate or remove bacteria, odor-causing bacteria, germs, mildew, fleas, mites, and ticks. Under the Federal Insecticide, Fungicide, and Rodenticide Act, products claiming to prevent, destroy, or repel pests, including anthrax bacteria, are considered pesticides and must be registered with EPA. The pre-market registration process requires a company to prove the product is safe and effective for consumer use before a legal claim can be made that it protects people and pets from illness caused by pests. EPA-registered products must bear the registration number on labeling, along with directions for use and any safety precautions. The 'stop sale' order requires 1st EnviroSafety Inc. to remove all pesticide claims from its advertising and labeling and to notify EPA within 30 days of the steps they have taken to do so. EPA, with the assistance of the Florida Department of Agriculture, will be monitoring compliance with this 'stop sale' order and will continue to monitor the internet for illegal pesticide sales.

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May 26, 2004

EPA Fines Culver City Company $4,400 for Pesticide Violation
EPA fined Jason Natural Products, Inc. $4,400 for allegedly selling and distributing a sunscreen that makes insect repellent claims without proper registration, which is a violation of federal pesticide law. EPA cited the company for selling SunBrellas Block SPF 30 - a sunscreen that makes insect repellent claims against mosquitoes, deer ticks, and fleas - without first registering the product with EPA. "Companies must register their pesticides with EPA," said Enrique Manzanilla, Director of the Cross Media Division of EPA's Pacific Southwest Regional Office. "Without EPA registration, we have no information on the effects of this product, which could result in harm to public health and the environment."

Federal law requires that before selling or distributing a pesticide in the U.S., companies must register the pesticide with the EPA. Before registering a new pesticide or new use for a registered pesticide, EPA must first ensure that the pesticide, when used according to label directions, can be used with a reasonable certainty of no harm to human health and without posing unreasonable risks to the environment. The Agency also ensures that pesticide labels provide consumers with the information they need to use the products safely. The Federal Insecticide, Fungicide, and Rodenticide Act allows for penalties of up to $6,500 per violation.

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May 26, 2004

EPA Fines Pesticide Importer $13,000
EPA fined Nichino America, Inc. $13,000 for allegedly attempting to import an unregistered and misbranded pesticide into the Port of Long Beach, California. Nichino America, Inc. is based in Wilmington, Del. In March, the firm allegedly imported a product called Fenpyroximate Technical from Japan without the proper registration from EPA. Federal law requires that before importing a pesticide into the U.S., companies must register the pesticide with EPA. Before registering pesticides, EPA must first ensure that when used according to label directions, the product can be used with a reasonable certainty of no harm to human health and without posing unreasonable risks to the environment.

Any firm that intends to sell imported pesticides in the U.S. must register its product with EPA,” said Enrique Manzanilla, director of the Cross Media Division in EPA’s Pacific Southwest Regional Office. “We need to know about a product so that we can determine whether it will pose unreasonable risks to people or to the environment. The Agency also ensures that pesticide labels provide consumers with the information they need to use the products safely. The Federal Insecticide, Fungicide, and Rodenticide Act allows for penalties of up to $6,500 per violation.

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May 17, 2004

EPA Fines San Luis Obispo Company for Pesticide Violation
EPA fined ClearWater Tech, LLC $4,400 for allegedly failing to register the San Luis Obispo, Calif. facility with EPA prior to production of a pesticide device. The Federal Insecticide, Fungicide, and Rodenticide Act requires all pesticide and pesticide device producers to register their operation with EPA so products can be tracked to the companies that produce them. ClearWater Tech produces large ultra-violet light air purifier systems that kill micro organisms. The company corrected the violation and is now legally registered to produce the devices. EPA discovered the violation after the company submitted reports to the agency indicating the facility was producing the devices.

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May 6, 2004

EPA Cites Redmond Co. for 304 Violations of Federal Pesticide Laws
In one of the biggest federal pesticide cases ever filed in the Northwest, EPA has issued a 304-count complaint against Redmond-based Argent Chemical Laboratories alleging the company illegally produced, sold, imported, and exported a variety of potentially dangerous pesticides. Each count carries a penalty of up to $5,500. The complaint (available upon request) alleges that Argent and Eliot Lieberman and Beatriz Shanahan, the owners of the company, violated the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) which requires all manufacturers, wholesalers, importers, and exporters of pesticides to register their products and their pesticide producing establishments with the federal government, provide basic health and safety information to their customers, and to sell restricted-use pesticide products only to licensed pesticide applicators.

The EPA investigation uncovered 304 violations of these requirements and others that occurred between May 1999 and January 2003. Among the violations committed by Argent are:

In 1988, Argent pled guilty to submitting false statements to the Food and Drug Administration and the EPA. Argent, Lieberman, and Shanahan also pled guilty to knowingly selling unregistered pesticides in violation of FIFRA. In 1993, a routine inspection at Argent's Redmond, Washington, facility revealed violations of FIFRA similar to those found in 1988. The inspection also found that Argent was further violating FIFRA by failing to maintain pesticide production records, illegally exporting pesticides, and misusing EPA-registered pesticides. As a result, Argent paid a civil penalty of $50,000.

In a letter dated April 24, 1998, Argent requested that EPA Region 10 deactivate Argent as a pesticide producing establishment. The letter states, "Please be notified that Argent no longer manufactures EPA registered pesticides anymore. If there is any expired Argent registered pesticide product in your data base, please deactivate it and do not send this kind of report to us in the future." Subsequent inspections conducted at the Redmond facility revealed that the company was continuing to produce, distribute or sell pesticides.

"The repeated sale of these types of pesticides to uncertified applicator, the sale of unlabeled and unregistered products – even after prior criminal and civil penalties – are egregious violations," said Mike Bussell, Acting Director of the EPA's Office of Compliance and Enforcement in Seattle. "Restricted-use pesticides can pose hazards to applicators, the environment, and human health. These violations suggest that the owners care so little about their customers that they are willing to repeatedly break the laws meant to promote the safe use of potentially dangerous products."

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April 28, 2004

Alabama Man Sentenced to 41 Months in Counterfeit Pesticide Case
On Apr. 21, an Alabama man was sentenced to serve 41 months in prison and pay a $45,305 fine for his conviction on 17 counts of violating the Federal Insecticide, Fungicide and Rodenticide Act and 11 counts of trafficking in counterfeit goods. Operating under the company name of Sierra Chemical, the defendant sold counterfeit, misbranded, adulterated and/or mislabeled pesticides to municipalities in Alabama and Georgia. The towns applied these products to control mosquitoes and the spread of the West Nile Virus. Selling altered, counterfeit or improperly branded and labeled pesticides can present a significant public health risk because the substances may not protect people from disease-carrying insects. The unauthorized substances in counterfeit pesticides can also pose an environmental risk, especially when sprayed over large areas. The case was investigated by the Jacksonville and Atlanta Area Offices of EPA's Criminal Investigation Division, the FBI, EPA's Office of Inspector General, EPA Region 4 Pesticide and Toxics Division and the Alabama Department of Agriculture and Industry. It was prosecuted by the U.S. Attorney's Office for the Northern District of Alabama and the Environmental Crimes Section of the U.S. Department of Justice.

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April 8, 2004

EPA Fines Arcadia Company for Selling Mislabeled Disinfectants
EPA fined Elio E. Salvo Inc., doing business as Miracle Sealants Company of Arcadia Calif., $13,200 for allegedly selling a mislabeled pesticide product named "Miracle Disinfectant, a violation of EPA's pesticide regulations. A review of the label showed that it did not adequately warn consumers of the potential risks involved with use of this product. The label was lacking information consistent with the EPA approved labeling requirements for ingredients, precautionary statements and application methods. This information is necessary to communicate effective use of the product.

"Pesticide registrants are responsible for ensuring that the labels on their product contain the necessary instructions," said Enrique Manzanilla, EPA's director of the pesticide division for the Pacific Southwest region. "Precautionary information is necessary to ensure consumers use the product safely." EPA registers pesticides under the Federal Insecticide, Fungicide and Rodenticide Act. Properly registered products have labels that list their ingredients, their human, environmental, physical and chemical hazards, and information on their use, storage and disposal. The alleged violation was noted after an inspection by the California Department of Pesticide Regulation.

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