Skip to statewide header Skip to site header Skip to main content Skip to site footer Skip to statewide footer

2025-111 Pesticide Use — Regulatory Oversight

Audit Scope and Objectives

The audit by the California State Auditor will provide independently developed and verified information related to the oversight of regulatory compliance for pesticide use by the responsible state and local oversight entities. The audit’s scope will include, but not be limited to, the following activities:

  1. Review and evaluate the laws, rules, and regulations significant to the audit objectives.
  2. Review and evaluate the Department of Pesticide Regulation’s (DPR) oversight of and guidance to county agricultural commissioners (CAC) related to the CACs’ role in pesticide permitting and oversight of pest control advisers (PCA). Specifically address the following areas:
    • DPR’s approach to providing technical assistance to CACs to ensure consistent statewide enforcement of pesticide use laws and regulations, permitting, alternatives evaluations, and PCA oversight and specific actions DPR has taken to address potential inconsistency among counties.
    • The processes by which DPR receives and responds to information from CACs about challenges in carrying out their responsibilities.
    • The way DPR ensures that CACs are correctly administering their duties for permitting and PCA oversight and any steps DPR takes if it identifies deficiencies. To the extent possible, determine the number of times DPR has identified deficiencies in the last three years.
    • DPR’s appeals process for CACs’ permitting decisions, including the steps it takes following its own decision on the appeal to ensure that CACs take appropriate action. To the extent possible, determine the number of appeals DPR has received in the last three years.
  3. Determine the number of PCAs’ licenses that DPR issued, denied, suspended, and revoked in the last three years and the reasons for these decisions.
  4. Determine whether during its initial licensure or license renewal processes, DPR collects information from prospective PCAs about compensation they may receive from pest control dealers or other potential interests the prospective PCAs have that could present conflicts of interest in the administration of their duties.
  5. Identify what program changes may be necessary – if any – that could increase the consistency and efficacy of DPR’s oversight, as well as mitigate potential conflicts of interest resulting from how the PCAs are compensated.
  6. Select four counties and, to the extent possible according to their rates of pesticide use, determine the number of restricted materials permits for which each CAC did the following in the last three years:
    • Issued the permit: Determine the number of permits issued that did not include mitigation measures and those that included mitigation measures as a condition of the permit.
    • Denied the permit: Determine the number of denials due to potential human health or environmental harm and the number denied because alternatives to pesticides were available.
    • Identified violations of the permit: For a selection of those violations, determine how the CAC responded to the violation.
    • Conducted an alternatives evaluation.
    • Approved, denied, revoked, or suspended a PCA registration. Determine the reasons for denied, revoked, and suspended registrations.
  7. For the selected counties, review a selection of permit action reviews and determine the following:
    • The concerns raised in the review and how the CAC addressed those concerns.
    • The decision the CAC made after the review.
    • Whether there were any subsequent actions by the CAC.
  8. Review each of the selected counties to determine whether the CAC has policies for conducting alternatives evaluations and, if so, whether those policies direct the CAC to conduct the alternatives evaluations themselves or whether they allow external parties, including PCAs, to conduct those evaluations.
  9. For a selection of permit applications in each selected county, review the following:
    • Whether the permit review process complied with state law and regulations.
    • Whether there was an alternatives evaluation performed. If not, determine why not and whether that conforms to state law and regulations. If yes, then determine whether the CAC performed the evaluation.
    • Whether the CAC conducted any oversight of the permit recipient’s activity after permit issuance and, if so, the type of oversight and any enforcement actions taken.
  10. For each selected county, review the oversight of PCAs that the CAC conducts. Include in this review an evaluation of the policies and procedures the CAC maintains for such oversight, the steps the CAC takes to ensure that PCA recommendations comply with state law and regulations, whether PCAs must submit their recommendations in writing, and what the CAC does if a PCA violates state law or regulations.
  11. For each selected county, determine whether the CAC has conducted any workload analysis or regularly reviews caseloads and staffing metrics to evaluate how to address any capacity challenges.
  12. Review and assess any other issues that are significant to the audit.

Los Angeles Fires

Go to ca.gov/LAfires for recovery resources and information. Get help now.

Opens in new window