PMRA Tank Inspections: Zero Tolerance

If your not aware or haven’t had the good fortune of a visit, the Regional PMRA enforcement officers are doing on-site inspections at each PCO place of business.

This isn’t really a bad thing, hell we get inspected by 5 or 6 different gun-toting, ticket writing folk all the time.  Keeps everyone on our toes and doing things properly.

The inspections involve different aspects of your business: record keeping, product usage, product storage etc.

One aspect of the inspection is swabbing the tanks to see if the proper rate of product is being mixed and applied.  I’ve seen reports where the swab showed 12 ppm of Demand, 14 ppm of Dragnet and a little bit of something that shouldn’t have been in there.

Oops!

I’ve also seen reports where the PCO had 60% of the label rate of the product in the tank.

Oops!     There’s no getting around that, blame who you want or what factors are involved, it ain’t gonna fly.

When they swab a tank, say full of Demand CS, and they find 0.029%, you are actually in violation of the law and the label rate.

And there is Zero Tolerance for not being spot on.  Using too much, you know an extra glug, is worse than being under.

You’ll probably get a compliance order on how you will remedy.  Simple, come up with a plan and train.  And that’s not overly reactive on the PMRA’s part.

The Zero Tolerance bugs me a bit though, and I personally believe they should have a +/- 2% in the equation.

Unless you’re mixing all your chemicals in a lab, you may find it difficult to meet the exact number every time.    Kinda why scientist use several replications when doing any experiment.