NEIC
PESTICIDE SPRAY EVALUATION
MICHIGAN DEPARTMENT OF AGRICULTURE AND
U.S. DEPARTMENT OF AGRICULTURE
GYPSY MOTH SPRAY PROGRAM
September 1980
EJBD
ARCHIVE
EPA
331-
R-
80-
002
oEPA
national enforcement investigations center
denver federal center bldg 53, box 25227 denver. ro 80225
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E3BO
fi-
fe-
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
PESTICIDE SPRAY EVALUATION
MICHIGAN DEPARTMENT OF AGRICULTURE AND
U.S. DEPARTMENT OF AGRICULTURE
GYPSY MOTH SPRAY PROGRAM
September 1980
Robert Campbell
Repository Material
'ermanent Collection
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
and
Region V
Chicago, Illinois
US EPA
Headquarters and Chemical Libraries
EPA West Bldg Room 3340
Mallcode3404T
1301 Constitution Ave NW
Washington DC 20004
202-566-0556
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CONTENTS
I INTRODUCTION.
II OBSERVATIONS/EVALUATION OF SEVIN-4-OIL PROGRAM 3
OBSERVATIONS 3
EVALUATION •• • 5
III OBSERVATIONS/EVALUATION OF DIMILIN® 6
OBSERVATIONS 6
EVALUATION 8
RECOMMENDATIONS 9
APPENDICES
A OBJECTIONS TO SPRAYING (NEWSPAPER ARTICLES)
B PHONED RECOMMENDATIONS TO EPA REGION V
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I. INTRODUCTION
The Michigan Department of Agriculture (MDA) and the United States
Department of Agriculture, Animal and Plant Health Inspection Service,
Plant Protection and Quarantine Program (USDA, APHIS, PPQ) Cooperated in a
gypsy moth [ Porthetria dispar (Linn.)] eradication program during the
spring of 1980. The objective of the program was to provide maximum pro-
tection to the forestry, recreation, and aesthetic resources in the State
of Michigan.
Approximately 24,744 acres within a boundary of 48,160 acres were
scheduled to receive two applications of gypsy moth control pesticides
within 10 days.
The 1980 integrated gypsy moth management program necessitated the use
of two proven chemical pesticides, Sevin-4-Oil and Dimilin . In addition,
experiments were to be conducted using two formulations of Disparlure (a
synthesized sex lure trap bait to attract male gypsy moths), mass trapping,
and sterile male release as possbile effective interventions.
The areas selected for Sevin-4-Oil treatment were in southern Michigan
and consisted of Calhoun, Oakland, and Van Buren counties. These three
counties contained a gross area of 3,200 acres with a proposed treatment
area of 2,220 acres. Immediately prior to spraying activities, adverse
public response to spraying in Oakland country reduced the total pesticide
application area to a total of 1,600 acres [Appendix A].
Dimilin® applications were principally confined to central northern
Michigan in the counties of Clare, Isabella, Mecosta, Montcalm, and Osce-
ola. The total area scheduled to receive treatment consisted of 22,544
acres. For a period, this program was in jeopardy as a result of objec-
tions to the spraying expressed by a group of organic farmers located in
the proposed treatment area [Appendix A].
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As in previous years, the USDA/MDA conducted an intensive public re-
lations program to advise individuals within the application areas to exer-
cise caution during the spraying period. This information was provided
through public meetings, the news media, the Cooperative Extension Service,
township supervisors, and local government units.
Because of environmental and possible legal considerations associated
with the USDA and MDA program, the EPA, Region V Pesticides Enforcement
Division requested the NEIC to provide technical review and evaluation of
the USDA/MDA gypsy moth eradication program procedures, and their compli-
ance with the Federal Insecticide, Fungicide, and Rotenticide Act (FIFRA).
Observations from May 14 to May 24, 1980 included: (1) evaluation of
pesticide storage, (2) mixing and loading operations, (3) application meth-
ods and techniques, (4) cleanup and disposal, (5) personnel safety. No
attempt was made to evaluate the USDA/MDA pesticide monitoring program.
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II. OBSERVATIONS/EVALUATION OF SEVIN-4-OIL PROGRAM
Spraying activities for Calhoun County were conducted from the Kellog
Regional Airport in the town of Battle Creek. The area treated in the
county consisted of approximately 1,200 acres in Section 25, the south Jj
and the NE h of Section 24, and the north h of Section 36. The area was
essentially urban.
OBSERVATIONS
Pre-Application
f5\
Prior to application activities both Sevin-4-Oil* and Dimilin ** were
stored in a well-marked, secure USDA shed on the outskirts of Battle Creek.
Helicopeter spray system calibration was conducted by USDA personnel
and adjusted to produce a 75 ft swath of spray at an equivalent rate of
1 lb/ acre to conform with contract specifications.
Mixing the final formulation was accomplished at a remote area of the
Kellog Regional Airport by pumping both the Sevin-4-Oil and diesel fuel
into a 1,000-gal-capacity truck-mounted holding tank. Agitation produced
within the tank resulted in a homogenous mixture. The ratio of ingredients
was 32 oz. of Sevin-4-Oil to 8 oz. of fuel.
Loading the final pesticide mix into the helicopter holding tanks was
done by a hose with appropriately equipped shut-off valves; this procedure
* Sevin-4=0il EPA Reg. No. 264-323.
** Dimilin EPA Reg. No. 148-1258.
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4
is called "open loading". Personnel conducting the mixing and loading op-
eration wore proper safety clothing and made every effort to prevent
spills.
Application
When weather permitted, spray activities commenced during the earliest
morning hours. On May 19, 1980 at 9:30 a.m., Sevin-4-Oil was sprayed in
Calhoun County. The spray helicopter applied the pesticide in an essen-
tially east-west, west-east course at an approximate altitude of 60 to 75 ft.
Correct alignment of the spray paths was controlled by ground crews manning
aerial kytoons (balloons). At the completion of each pass, the kytoons
were moved about 75 ft along the perimeter of the unsprayed area to create
a target for the next spray path. Throughout the entire spraying operation
a spotter plane observed the procedure from a higher altitude and supervised
the overall operation. All personnel maintained radio communication during
the entire application.
Spraying operations terminated at about 11:30 a.m. because increased
wind velocity created potential uncontrolled spray drift. About 4 of the
assigned area had been treated when application ceased. On the following
day, May 20, weather conditions were suitable to complete the spraying.
Post-Application
Procedures for the cleanup of used containers closely followed the EPA
guidelines. All pesticide containers (55-gal drums) were triple-rinsed and
stored in a security warehouse for later collection by a local barrel re-
conditioning company.
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EVALUATION
The pesticide spraying program of Sevin-4-Oil in Calhoun County re-
flected extensive planning by both USDA and the MDA. All operations ad-
hered to the prescribed planned procedures except for several minor infrac-
tions involving protective clothing. Close scrutiny and training of less
experienced personnel could remedy this.
Improved safety practices are necessary for the ground crews respon-
sible for positioning the kytoons. Unlike the crews marking the boundaries
of a proposed section, the crews controlling the spray paths are subjected
to repeated contact with pesticide particles each time the aircraft fin-
ishes or begins a run. It is stated in the program regulations that "all
members of kytoon crews will wear raincoats and a head covering of their
choice during spraying operations". Although crew members during this
operation wore adequate headgear and gloves, they were provided with inade-
quate raingear (ponchos) which did not sufficiently cover them. Satisfac-
tory protection could be provided with throw-away, long-sleeved coveralls
or raingear which covers the wrists and reaches below the knees. Full-face
protection using a face shield would, for example, also contribute to em-
ployee safety. If these crews are involved in more concentrated dosages of
pesticide spary, respirators and goggles will also be necessary.
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III. OBSERVATIONS/EVALUATION OF DIMILIN® PROGRAM
The base of operations for the central Michigan Dimilin program was
the Airport at Mt. Pleasant. The area treated comprised 22,544 acres dis-
persed in the counties of Clare, Isabella, Mecosta, Montcalm, and Osceola.
The target areas are essentially rural.
OBSERVATIONS
Pre-Application
jg»
The 25-Ib containers of Dimilin were transported from Battle Creek
and stored at the Mt. Pleasant Airport in a security building distinctly
posted with warning signs.
Five fixed-wing aircraft were checked and calibrated by USDA person-
nel, and their flat fan spraying systems were adjusted to provide a flow
rate of h gal/acre at 40 psi over a swath with 75 ft.
The pesticide spray solution was prepared at a secluded area of the
airport. Before mixing, the dilution water obtained from the Mt. Pleasant
municipal supply was acidified to a pH of 6.5 to 7.0 with phosphoric acid.
To assure a pesticide application rate of 0.015 Ib/acre, the mixture ratio
®
of ingredients to dilution water was 25 Ib of Dimilin to 200 gal of water.
These mixtures were prepared on a batch basis usually 600 to 800 gal at a
time.
The aircraft were loaded using a closed metered pumping system which
reduced the liklihood of spillage.
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Application
The Dimilin® treatment program began during the early morning hours
May 22, 1980. Weather conditions were favorable. Kytoon crews were in
position and five fixed-wing aircraft were treating three sections under
the supervision of three MDA observer planes.
Aerial spraying was accomplished by two planes flying in tandem at an
altitude of about 50 to 60 ft. Spray paths were marked by red aerial ky-
toons (balloons) manned by ground personnel. At the completion of each
pass, the kytoons were moved 150 ft along the road bordering the treatment
area.
Organic farmers and others objecting to pesticide applications did not
want their land sprayed. Therefore, to prevent any mishaps, the perimeters
of these sensitive areas were clearly marked with white kytoons. The spray
plane pilots were directed not to fly over these areas. Spraying activities
in the vicinity of a sensitive area (organic farm) were observed by EPA
personnel and every precaution to avoid overspary of this area was fol-
lowed.
Upon completion of spraying operations on May 24, 1980 about h of the
I3l
8,800 ha (22,000 acres) had received their first treatment of Dimilin .
Post-Application
Procedures for the cleanup of used containers closely followed the EPA
guidelines: all containers were triple-rinsed, punctured, and stored in a
security warehouse area.
Disposal of used containers does not pose an immediate problem in the
State of Michigan. Although the state does not have a dump site especially
designed for the disposal of highly toxic or environmentally damaging com-
pounds or containers, referred to as a Class I dump site, the Michigan De-
partment of Natural Resources issues special permits to allow controlled
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dumping at selected sites. This is the procedure being followed during the
1980 gypsy moth eradication program.
EVALUATION
Observations during the first few days of the Dimilin program indi-
cated that it was well planned with every effort made to make it success-
ful. However, a few unsafe practices were noted in the mixing-loading
zone. The contractor personnel conducting the mixing did not have proper
protective clothing, wearing short-sleeve shirts during mixing. Moreover,
in performing the mixing, the 25-lb pesticide containers were emptied
through the top portal of the mixing tank. A cover was not immediately
placed over the opening to prevent the escape of Dimilin dust into the
surrounding atmosphere. To prevent contact with this dust by the crews
supervising loading operations, employees should be provided with suitable
safety equipment such as respirators and goggles. Personnel not so equip-
ped need to remain a safe distance from the mixing area.
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RECOMMENDATIONS
1. Kytoon crews marking the spray paths during Sevin-4-Oil application
should be equipped with long-sleeved throw-away coveralls or knee-
length raincoats, face shields, or respirators and goggles.
2. Proper safety clothing should be worn constantly during pesticide
mixing operations.
®
3. A method should be devised to prevent the escape of Dimilin dust from
the mixing tank during the mixing operation.
4. Ground crews supervising loading operations should be equipped with
suitable safety equipment or retreat a safe distance during the pesti-
cide mixing operation.
These recommendations were conveyed to Mr. Carl Erickson, Pesticide In-
spector, Region V in a telephone conversation on May 28, 1980 [Appendix B].
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APPENDIX A
OBJECTIONS TO SPRAYING
(Newspaper Articles)
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A-l
Aerial spraying to kill
insects sparks flaps
Sunday, May 18,1980
By JAMES L KERWIN
NMI SUII WHIM
Fears that aerial sprays or
Insecticides may pose a risk to
pregnant women — while elimi-
nating populations of birds and
ecologically valuable insects —
have triggered furors In several
targeted Michigan communi-
ties
In Bloomfleld Township, a
planned aerial spraying of 600
acres of wooded residential area
by the State Department of Agri- •
culture — to eradicate o
concentration of dreaded gypsy
moth caterpillars — was can-
celed by the township board of
supervisors last week following
o public protest.
Object of the current protests is
the chemical Sevin. manufactured
by Union Carbide The department
soys tlie chemical has been used for
27 years throughout the world —
without any reported ill effects — to
treat vegetables, fruits, poultry and
livestock for pests It is sold in retail
stores to home gardeners
SINCE THE 1960's the state has been
trying to check the spread of the
gypsy moih with the use of traps,
various hormones and sprays The
moth caterpillar began stripping for-
ests in New England and Pennsylva-
nia in the 19SO's and hitched rides
Shaded area on map indicates
the 600 acres to be sprayed.
west on cars and recreational
vehicles
But wherever the state has sought
to halt the spread It has run into
difficulty.
The Dloomfeld critics voice the
concerns of most protesters To
some, the issue bolls down to trees
,vs the health risk to humans and
wildlife
Critics of aerial spraying argue
that It causes birth defects and may
be carcinogenic (a cancer-causing
agent)
"Nature is too complex to try fix-
ing Spraying is only buying a little
time There are safer alternatives,"
insists James P Wells, a botanist at
Continued on Pag* 10B
Continued from Page 1B j
; Cranbrook Institute who helped lead •
the protect in Bloomfleld Township !
WELLS SAYS, "too often, in getting
rid of one pest, the habitat is chang^
ed so much that another moves in "
He says the public doesn't trust
government researchers "after PBB
and Three Mile Island "
But Homer Case, a Bloomfleld
Township supervisor caught in the
center of the controversy, replies
bluntly "Hogwash " "
"Scvm hasn't been proven danger-
ous The stuff is on the vegetables
you buy in the market and nobody
thinks anything about that." said
Case, whose family has been using
chemicals for three generatnons in
raising fruits
"1 handled by hand arsenated lead
and DDT and I'm still healthy, insists
the M-year-old supervisor, who bos
held his township post for 24 years. -
"The whole hullaloo comes from
the outcry over the use of Agent
Orange in Vietnam." said Case Agent
Orange is a defoliant that has been
suspected of causing cancer and
genetic diseseas
THE FUROR OVER chemical spray-
ing isn't confined to Bloomfleld
Township State officials have been
engaged in court battles outstate
over the use of Dimlm, a more potent
chemical, in wooded areas infested
with the g)psy moth
But under coui t guidelines to pro-
tect organic farming, the state is pro-
ceeding with aerial applications of
Dimlm this week in the Kalamazoo-
Battle Creek area as well as in five
counties in central Michigan >•,'
Critics of aerial spraying say tbe
federal government's ban last March
against use of a powerful presticide
I — 2.4.5-T — on forests of Oregon and
Washington should be extended to
other chemicals Some women in
Washington and Oregon blamed
2,4.5-T for miscarriages
Even the experts within the Envi.
ronmental Protection Agency (EPA)
are divided as to the advisability of
aerial spraying '
Mama Marshall, director of EPA's
pesticide research program believes
Sevin "does not pose an imminent
hazaid " But she concedes "unneces-
sary exposure" should be avoided
and no one can conclude "Ilie risk is
zero"
IN HIS RESEARCH, WcllS Sa>S
othei r.PA researchers have found
Carbaiyl (from which Sevin is
made) causes birth detects in rats
and shouldn't be used near water —
where it can become a part of the
food chain
Officials of tbe agriculture depart-
ment, which conducts the aenal
spray programs for gypsy moth in
Michigan, claim precautionary steps
were being taken in Bloomfleld
Township
Lakes and ponds were off limits to
aerial spraying, as were school bus
stops The area around George Way
Elemtnary School was to be doused
at 6 30 a m, long before classes start-
ed The wooded area to be sprayed is
bounded by Telegraph. Long Lake
Lahser and Timberlake
But the spraying was called off
after, Case says, "outsiders stam-
peded" a hearing called to discuss
ihe program "They" were people
mostly outside the township, along
with environmentalists and Cran
brook people "
Mrs John Selick, who heads a
homeowner group within the area to
be sprayed, claims that 103 of 110
members in her organization backed
the spraying
"We carefully researched and dis-
cussed the sprajmg before we de-
cided we wanted it," she said
MUCH OF THE 600 acres to be
sprayed contains virgin growth ol
oak on which the gypsy moth
thrives It also likes the leaves of
maple and crab apple trees that a-
bound in the area
Case. Mrs Selick and other
residents are incensed over a leaflet
sent home with elementary students
from Way School, in the spray areas
which was headed "Important Warn-
ing"
The unsigned leaflet warned that
"one of the recent theories concern-
ing Reye's Syndrome (which has kill
ed four youngstes in Michigan so far
this year) is that the disease mat
have a direct relation to insecticide
spraying "
Way school officials say the leafle.
was distributed by "a small group" o
a Parent-Teachers Organization, ;
decision which is now being review
ed because of protests There is m
scientific evidence that the chemica
contributes to the ailment
CASE WANTS THE state and federa
officials "to resolve conllictm.
claims" so the spraj mg program ca:
be carried out next May Aeria
spraying is effective only when th.
larva emerges from its egg masse
and begins feeding on Icates Iron
mid to-late May
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(9
X
o
z
I
3
. MT PLEASANT-Chemical warfare against
the gypsy moth caterpillar will commence
tomorrow. Thursday, if central Michigan
weather conditions are favorable for aerial
I spraying
A ruling issued last Wednesday in the
Ingham County Circuit Court gave the
Michigan Department of Agriculture (MDA)
the go-ahead to conduct the spraying as
planned
An airplane loaded with the pesticide
Dimilm W 25 is slated for take-off from the Ml
Pleasant City Airport at daybreak to begin
MDA's 19SO gypsy moth management plan
The plan calls for Dimilm to be used in the
treatment of wooded areas in portions of Clare.
Isabella. Mccosta, Monlcalm . and Osccola
counties
Other chemical, trapping or biological
measures are planned for Bcrnen, Calhoun.
Van Burcn and Wayne counties
A planned spraying with the pesticide Sevin
over 600 acres of wooded residential property
in Oakland County was cancelled last week by
the Bloomfield Township board
Concerns among Bloomfield Township'
residents that Sevin may pose a human health
1 hazard match thnsc of area critics who oppose
the use of the more potent Dimilm.
MDA has enlisted the aid of the U. S.
Department of Agriculture (USDA) in con-
ducting and funding its program aimed at
eradicating the gypsy moth in Michigan.
Agriculture officials claim the pesticide.'
they use are safe, and that Dimilm, in par
ticular. is the most effective pesticide available
for eradicating the foliage-consuming pest.
If the gypsy moth is not controlled, they say
defoliating whole forests by the insect could
have a severe aesthetic and economic impact
on the state ' <
Last Wednesday's hearing before Judge Ray,
Hotchkiss was the result of a preliminary
injunction the judge issued against th,
spraying in 1978.
The 1978 court action was brought about by '
a Clare County based citizens group. Citizens
Against Chemical Contamination (CACC),
which formed that year to oppose the spraying.
Ann Hunt, a Surrey Township organic
farmer and co-chairwoman 'of CACC, said
Wednesday's ruling imposed the same
restrictions on the spray program that were
applied in 1979.
The 1978 injunction requires prior court
approval before MDA can conduct spray
programs Last year, the injunction was
modified to allow limited spraying in wooded
areas.
Exempted from treatment with Dimilin,
both last year and this year, are the properties
of organic farmers who request the exemption
and incorporated villages
Persons who identify themselves as,organic
farmers in writing to MDA are allowed a 100-
foot buffer zone between their properties and a
designated spray area
The only incorporated village affected by the
ruling, according to Hunt, is Winn The Winn
•area is where MDA officials believe the
current gypsy moth infestation in central
Michigan originated
Incorporated villages, as designated in the
ruling, are allowed a 250-foot buffer zone, and
do not need to apply for the exemption, ac-
cording to Hunt
The Dimilin spraying is scheduled for two
applications in the designated areas Weather
permitting, the first application tomorrow will
be followed by another in seven to ten days
Dick Moore, district director for USDA's
Animal and Plant Health Inspection Service
(APHIS), said the treatment program should
be completed by June 12 or 14.
Hunt suggested that persons wishing to be
exempted from the spraying might consider
, putting in an organic garden to qualify.
Jeffrey Eibling, USDA plant protection and
quarantine inspector based in Mt Pleasant,'
said, however, that the exemption may apply
ro
only to bonafidc organic farmers
This may be a point of contention, he said
"People who have a 10 by 20 plot .. I don't
know if they'd be exempted or not."
Hunt noted that there still may be time in
get an exemption if the weather is unfavorable
for spraying tomorrow, and before the second
application.
The request for exemption must be made in
writing to Dean Lovitt (chief of MDA's plant
industry division), Michigan Department of
Agriculture, Lewis Cass Building, P 0. Box
,30017. Lansing. MI 48909
Areas in the Buyer's Guide circulation area
to be treated with Dimilin are listed below.
Spraying will be conducted primarily in the
wooded portions of the areas listed
ISABELLA COLSTY
Broomfield Township Sections 2 (EVi). 5
(S'/i). 8 through 17. 20 through 27, and 34
through 36
Deer field Township Sections 16 through 21.
and 28 through 33.
Fremont Township Sections 4 through 9, 16
through 17.20 through 21. and 28 through 33
Gilmore Township- Sections 5(W'/i)and 6
Holland Township: Sections 1 through 3, 4
(EVi). 9(E'/, andSVil. 10.12(N'/i),21 (S'/i), 25
(S'/j).26.28(N'/j).33and36
Sherman Township-Sections 25. and 36(NVi
and SWA)
Spraying in Isabella County will involve a
total designated spray area of 40,640 acres of
which 20,044 wooded acres will actually be
sprayed
CLARE COUNTS
Spraying in Section 31 of Surrey Township
involves a designated spray area of 640 acres
of which 560 wooded acres will actually be
sprayed
Dimilm spraying will also be conducted in
about 320 acres of Mccosta County's Sheridan
Township, 160 acres in Montcalm County's Day
Township and 320 acres in Ferns Township,
and 400 acres in Osceola County.
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APPENDIX B
PHONED RECOMMENDATIONS TO EPA REGION V
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RECORD OF
COMMUNICATION
O:
Carl Erickson
Pesticide Inspector, R-V
Q PHONE
Q OTHER
_____ £
CALL QDISCUSSION Q FIELD TFIIP [^CONFERENCE'
(SPECIFY)
(Record of item checked above)
FROM:
Bob
Campbell ^^ 5/?K/Bn
TIME
10:45am
SUBJECT ~
Michigan Gypsy Moth Control Program
Called to inform Mr. Erickson of my intended suggestions or recommendations
concerning safety precautions relating to the Michigan pesticide application
program. This information was related with the intention of implementing these
suggestions before the program was completed rather than waiting for submission
of a written report to Region V.
The following suggestions were conveyed to Mr. Erickson:
1. Additional protective clothing for the contracted applicator
conducting the mixing operation in the form of rainwear and boots.
Other necessary protection was worn.
2. Kytoon crews during Sevin application by helicopter should, in
addition to head gear and ponchos, wear face shield or goggles.
3. During mixing operations a method should be devised to prevent
escape of pesticide dust through the loading port.
4. Personnel in loading areas retreat to a safe distance during
mixing operations to prevent contact with escaping pesticide dust.
>)CLUSIONS. ACTION TAKEN OR REQUIRED
Mr. Erickson will relate this information to the appropriate parties super-
vising the spraying program.
^TIO.N COPIES
/Harp, Schneider
e°* Form 1300.4 (7-72) REPLACES EPA
MQ roau sjoo-s WHICH MAY BE USED UNTIL SUPPLY 15 EXHAUSTED.
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