US Environmental Protection Agency
Office of Pesticide Programs
Reregistration Eligibility Decision (RED)
for Chloropicrin
July 9, 2008
-------
United States Prevention, Pesticides EPA 738-R-08-009
Environmental Protection and Toxic Substances July 2008
Agency (7508P)
Reregistration Eligibility Decision
(RED) for Chloropicrin
-------
Reregistration Eligibility Decision (RED) for Chloropicrin
Approved by:
List [A]
Case No. 0040
Steven Bradbury, Ph.D.
Director
Special Review and Reregistration Division
Date:
T
-------
Glossary of Terms and Abbreviations
AGDCI
ai
aPAD
BCF
CFR
cPAD
CSF
CSFII
DCI
DEEM
DFR
DNT
EC
EDWC
EEC
EPA
EUP
FDA
FIFRA
FFDCA
FQPA
GLN
IR
LCso
LD5
'50
LOC
LOAEL
MATC
mg/kg/day
mg/L
MOE
MRID
Agricultural Data Call-In
Active Ingredient
Acute Population Adjusted Dose
Bioconcentration Factor
Code of Federal Regulations
Chronic Population Adjusted Dose
Confidential Statement of Formulation
USDA Continuing Surveys for Food Intake by Individuals
Data Call-In
Dietary Exposure Evaluation Model
Dislodgeable Foliar Residue
Developmental Neurotoxicity
Emulsifiable Concentrate Formulation
Estimated Drinking Water Concentration
Estimated Environmental Concentration
Environmental Protection Agency
End-Use Product
Food and Drug Administration
Federal Insecticide, Fungicide, and Rodenticide Act
Federal Food, Drug, and Cosmetic Act
Food Quality Protection Act
Guideline Number
Index Reservoir
Median Lethal Concentration. A statistically derived concentration of a
substance that can be expected to cause death in 50% of test animals. It is
usually expressed as the weight of a substance per weight or volume of
water, air, or feed, e.g., mg/1, mg/kg, or ppm.
Median Lethal Dose. A statistically derived single dose that can be
expected to cause death in 50% of the test animals when administered by
the route indicated (oral, dermal, inhalation). It is expressed as a weight
of substance per unit weight of animal, e.g., mg/kg.
Level of Concern
Lowest Observed Adverse Effect Level
Maximum Acceptable Toxicant Concentration
Micrograms Per Gram
Micrograms Per Liter
Milligram Per Kilogram Per Day
Milligram Per Liter
Margin of Exposure
Master Record Identification Number. EPA's system for recording and
-------
MUP
NOAEL
OPP
OPPTS
PAD
PCA
PDF
PHED
PHI
ppb
PPE
ppm
PRZM/EXAMS
RAC
RED
REI
RfD
RQ
SCI-GROW
SAP
SF
SLC
TGAI
USDA
USGS
UF
UV
WPS
tracking studies submitted.
Manufacturing-Use Product
No Observed Adverse Effect Level
EPA Office of Pesticide Programs
EPA Office of Prevention, Pesticides, and Toxic Substances
Population Adjusted Dose
Percent Crop Area
USDA Pesticide Data Program
Pesticide Handler's Exposure Data
Pre-harvest Interval
Parts Per Billion
Personal Protective Equipment
Parts Per Million
Tier II Surface Water Computer Model
Raw Agriculture Commodity
Reregi strati on Eligibility Decision
Restricted Entry Interval
Reference Dose
Risk Quotient
Tier I Ground Water Computer Model
Science Advisory Panel
Safety Factor
Single Layer Clothing
Technical Grade Active Ingredient
United States Department of Agriculture
United States Geological Survey
Uncertainty Factor
Ultraviolet
Worker Protection Standard
-------
Table of Contents
Abstract 9
I. Introduction 11
II. Chemical Overview 12
A. Chemical Identity 12
B. Use and Usage Profile: 12
C. Regulatory History 14
III. Summary of Risk and Benefit Assessments and Links to Agency Documents 15
A. General Overview of Soil Fumigants 15
B. Human Health Risk from Chloropicrin 15
C. Environmental Fate and Ecological Risks 18
D. Benefits 21
IV. Risk Management and Reregi strati on Decision 24
A. Determination of Reregistration Eligibility 24
B. Public Comments and Responses 25
C. Regulatory Position 26
1. Regulatory Rationale 26
a. Chloropicrin Pre-Plant Soil Uses 26
i. Human Health Risk Management 27
1. Bystander Risk Mitigation 28
a. Buffer Zones 28
i. General Buffer Zone Requirements 29
ii. PERFUM Model Inputs 31
iii. PERFUM Model Outputs 35
iv. Buffer Zone Distances 35
v. Buffer Zone Reduction Credits 43
vi. Buffer Zone Impacts 47
b. Posting 47
i. Posting Requirements 48
c. Use Prohibitions 51
2. Occupational Mitigation 51
a. Handler Definition 51
b. Handler Requirements 51
c. Respiratory Protection 52
i. Respiratory Requirements 53
d. Tarp Perforation and Removal 55
e. Entry Prohibitions 55
ii. Other Mitigation 59
1. Good Agricultural Practices (GAPs) 59
2. Fumigant Management Plans (FMPs) 65
3. Emergency Preparedness and Response 68
a. First Responder Education 69
b. Site-Specific Response and Management 69
i. Fumigation Site Monitoring 69
-------
ii. Response Information for Neighbors 70
c. Emergency Preparedness and Response Considerations 72
4. Notice to State Lead Agencies 74
5. Soil Fumigation Training for Applicators and Other Handlers 74
a. Training for Applicators Supervising Fumigations 75
b. Training Materials for Handlers 76
c. Soil Fumigation Training Considerations 77
6. Community Outreach and Education Programs 78
iii. Environmental Risk Mitigation 79
b. Residential Structure Warning Agent Use Mitigation 79
i. Occupational Risk Mitigation 80
1. Respiratory Requirements 80
c. Chloropicrin Antimicrobial Use Mitigation 80
i. Bystander Risk Mitigation 80
ii. Occupational Risk Mitigation 80
1. Air Concentration 81
2. Respiratory Requirements 81
2. Endocrine Disrupter Effects 81
3. Endangered Species Considerations 82
D. Conclusions 82
V. What Registrants Need to Do 84
A. Manufacturing Use Products 84
1. Additional Generic Data Requirements 84
a. Data Requirements for Chloropicrin Soil Uses 85
i. Human Health 85
1. Toxicity 85
2. Residue Chemistry 85
3. Occupational and Residential Exposure 85
ii. Environmental Fate and Ecological Effects 86
1. Environmental Fate 86
2. Ecological Effects 86
iii. Other 88
b. Chloropicrin Warning Agent Uses 89
c. Antimicrobial Uses 89
2. Labeling for Manufacturing-Use Products 89
B. End-Use Products 90
1. Additional Product-Specific Data Requirements 90
2. Labeling for End-Use Products 90
Appendix A 120
Appendix B 124
Appendix C 125
-------
Chloropicrin Reregistration Eligibility Decision Team
Office of Pesticide Programs:
Biological and Economic Analysis Assessment
T J Wyatt, Ph.D., Senior Agricultural Economist
Jonathan Becker, Ph.D., Senior Science Advisor
Bill Chism, Ph.D., Senior Agronomist
David Donaldson, Agricultural Economist, Team Leader
Colwell Cook, Ph.D., Entomologist
Nicole Zinn, Biologist
Stephen Smearman, Economist
Leonard Yourman, Ph.D., Plant Pathologist
John Faulkner, Ph.D., Economist
William Phillips, II, Ph.D., Agronomist
Tara Chandgoyal, Ph.D., Plant Pathologist
Jin Kim, Ph.D., Economist
Andrew Lee, Ph.D., Economist
Angel Chiri, Ph.D., Entomologist, Team Leader
Elisa Rim, Economist
Nikhil Mallampalli, Ph.D., Entomologist
Sunil Ratnayake, Ph.D., Botanist
Environmental Fate and Effects Risk Assessment
Mah Shamim, Ph. D. Branch Chief
Faruque Khan, Ph.D. Senior Fate Scientist
James Felkel, M.S. Wildlife Biologist
Gabriel Rothman, M.S. Environmental Scientist
Health Effects Risk Assessment
Elissa Reaves, Ph.D., Toxicologist/Risk Assessor
Charles Smith, Environmental Scientist/Risk Assessor
Yvonne Barnes, Chemist
Ruth Allen, MPH, Epidemiologist
Monica Hawkins, MPH, Environmental Health Scientist
Antimicrobial Risk Assessment Team
Heather Garvie, Chemical Review Manager
Diane Isbell, Reregistration Team Leader
Timothy Leighton, Environmental Scientist
Cassi Walls, Ph.D., Chemist
Timothy Dole, Industrial Hygienist
-------
Chloropicrin Reregistration Eligibility Decision Team, cont.
Registration Support
Mary Waller, Product Manager
Tamue Gibson, Product Manager
Kathy Monk, Senior Advisor
Risk Management
Andrea Carone, Chemical Review Manager
Steven Weiss, Industrial Hygienist, Chemical Review Manager for Methyl Bromide
Eric Olson, Team Leader
John Leahy, Senior Advisor
Office of General Council:
Andrea Medici
Office of Enforcement and Compliance:
David Stangel
-------
Abstract
This document presents the Environmental Protection Agency's (hereafter the Agency or
EPA) decision regarding the reregi strati on eligibility of the registered uses of chloropicrin
(tri chl oronitromethane).
The Agency has determined that chloropicrin is eligible for reregi strati on provided that
the risk mitigation measures identified in this document are adopted and labels are amended to
implement these measures. Throughout this document measures described as "required" are the
measures necessary to be eligible for reregi strati on. Additionally registrants must address data
gaps identified in this document.
Concurrent to EPA's review of the soil fumigant uses of chloropicrin, EPA assessed the
risks and developed risk management decisions for four other soil fumigants: dazomet, methyl
bromide, metam sodium/potassium, and a new active ingredient, iodomethane. Risks of a fifth
soil fumigant, 1,3-dichloropropene (1,3-D), were also analyzed along with the other soil
fumigants for comparative purposes. The Reregi strati on Eligibility Document (RED) for 1,3-D
was completed in 1998. The Agency evaluated these soil fumigants concurrently to ensure that
human health risk assessment approaches are consistent, and that risk tradeoffs and economic
outcomes were considered appropriately in reaching risk management decisions. This review is
part of EPA's program to ensure that all pesticides meet current health and safety standards.
Chloropicrin acts as a nonselective soil fumigant with fungicidal, herbicidal, insecticidal,
and nematicidal properties. The supported uses of chloropicrin include: (1) pre-plant soil
fumigations (e.g., agricultural and commercial greenhouse); (2) empty grain bins and empty
potato storage house/cellar fumigations; (3) residential uses (warning agent for sulfuryl fluoride);
and (4) other specialized fumigations (e.g., spot tree replant sites and remedial wood treatments).
Of the supported uses, chloropicrin is mainly used as an agricultural pre-plant soil fumigant. The
Agency has received requests to voluntarily cancel the empty grain bin and empty potato
storage/house cellar fumigations. Because these uses will be cancelled, this document does not
propose mitigation for these scenarios.
Due to chloropicrin's volatility there is no reasonable expectation that finite residues will
be incurred in/on any raw agricultural commodity when these products are applied according to
label directions. Therefore, this fumigant does not require food tolerances and there is no
expectation of risk from dietary exposure.
The Agency has identified potential human health risks associated with the above
supported uses of chloropicrin. Due to chloropicrin's potential to move off-site, EPA is
concerned with inhalation exposure to handlers, bystanders, and workers. To reduce inhalation
exposures and to address associated risks of concern for pre-plant soil fumigations, EPA is
requiring a number of mitigation measures such as:
buffer zones,
posting,
monitoring and respiratory protection,
restrictions on the timing of tarp perforation and removal operations,
-------
entry prohibitions,
mandatory good agricultural practices (GAPs),
fumigant management plans (FMPs),
emergency preparedness and response,
training, and
community outreach and education programs.
To address bystander and occupational risks for remedial wood treatments, the Agency is
requiring a number of label statements and respiratory protection.
The Agency also has concerns regarding ecological and environmental risk when
chloropicrin is used as a pre-plant soil fumigant. The Agency believes that many of the
mitigation measures required above to address human health risk (e.g., buffer zones, timing of
tarp perforation and removal, GAPs), will indirectly address ecological risk. The Agency is also
requiring label statements to mitigate chloropicrin's potential to leach into ground and/or surface
water.
Some chloropicrin end-use products are packaged as 100% chloropicrin, while other
products contain mixtures of chloropicrin with methyl bromide, 1,3-D, and iodomethane. In
these combination products the percent active ingredient for chloropicrin ranges from 20-67%
when combined with methyl bromide, 15-60% when combined with 1,3-D, and 2-75% when
combined with iodomethane. In addition, chloropicrin is used solely as a warning agent to
indicate possible hazardous concentrations of methyl bromide1 (chloropicrin is formulated at 2%
or less by weight for pre-plant soil fumigations) and sulfuryl fluoride (chloropicrin is introduced
into residential structures prior to the sulfuryl fluoride fumigation).
Separate RED documents have been completed for methyl bromide (will be published
concurrently with chloropicrin), sulfuryl fluoride (1993), and 1,3-D (1998). Iodomethane was
granted a one year time-limited registration while chloropicrin, methyl bromide, metam
sodium/potassium, and dazomet were going through reregi strati on. The time-limited
iodomethane registration will be extended as necessary to allow submission of revised labels
which will include, as appropriate, general mitigation required in the REDs for the other soil
fumigants. Upon approval of those labels, the time limit will be removed. In accordance with
Agency policy, if the required risk mitigation measures differ for two active ingredients in a
product, the more stringent mitigation measure is required on product labels.
The Agency is issuing this decision document for chloropicrin, as announced in a Notice
of Availability published in the Federal Register. Due to the broad scope of the decision for the
soil fumigant group, there will be a 60-day public comment period for this document to allow
stakeholders the opportunity to review and provide comments on issues related to the
implementation of the risk mitigation measures.
1 Current labels reflect use of chloropicrin as a warning agent for methyl bromide during structural fumigations.
The use of methyl bromide for structural fumigations is not eligible for reregistration. As a result the warning agent
use for chloropicrin formulations with methyl bromide for structural fumigations was not evaluated.
10
-------
I. Introduction
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended in 1988 to
accelerate the reregi strati on of products with active ingredients registered prior to November 1,
1984. The amended Act calls for the development and submission of data to support the
reregi strati on of an active ingredient, as well as a review of all submitted data by the EPA.
Reregi strati on involves a thorough review of the scientific database underlying a pesticide's
registration. The purpose of the Agency's review is to reassess the potential risks arising from the
currently registered uses of the pesticide, to determine the need for additional data on health and
environmental effects, and to determine whether or not the pesticide meets the "no unreasonable
adverse effects" criteria of FIFRA.
This document presents the Agency's reregi strati on eligibility decision for the supported soil
(agricultural, greenhouse, and tree replant), warning agent, and antimicrobial wood preservative uses
of chloropicrin. The document consists of five sections. Section I contains the regulatory
framework for reregi strati on. Section II provides chloropicrin's use and usage profile. Section III
provides a general fumigant overview and also summarizes chloropicrin's human health and
ecological risk assessments, as well as benefit assessments. Section IV presents the Agency's
reregi strati on eligibility and risk management decisions. Section V summarizes label changes
necessary to implement the risk mitigation measures outlined in Section IV. The revised risk
assessment documents and related addenda are not included in this document, but are available in the
chloropicrin docket EPA-HQ-OPP-2007-0350 at https://www.regulations.gov. Unless otherwise
noted, all Agency documents are available for review in the chloropicrin docket. Documents
published during Phases 1-4 are available at https://www.regulations.gov, docket number EPA-HQ-
OPP-2006-0661.
11
-------
II. Chemical Overview
A. Chemical Identity
Chemical Structure:
Cl
Cl-
Empirical Formula:
Common Name:
CAS Registry Number:
OPP Chemical Code:
Case Number:
Technical Registrants:
Cl ฐ
CC13NO2
Chloropicrin
76-06-2
081501
0040
Niklor Chemical Company, Inc., Arysta Life Sciences North
America Corporation, ASHTA Chemicals, Inc., and Trinity
Manufacturing, Inc. All 4 companies are part of the Chloropicrin
Manufacturers' Task Force (CMTF).
B. Use and Usage Profile:
Pesticide Type:
Target Pests:
Chloropicrin is a broad spectrum fumigant with fungicidal,
herbicidal, insecticidal, and nematicidal properties. Chloropicrin
supported uses include: pre-plant soil fumigant use at agricultural
sites, tree replant sites, and greenhouses; a warning agent use in
residential structures before sulfuryl fluoride fumigations; and an
antimicrobial remedial wood treatment use. Chloropicrin is
currently labeled for use in empty grain bins and empty potato
storage/house cellars, but the Agency has received requests to
voluntarily cancel these uses.
When used as a pre-plant soil fumigant in agricultural settings and
in greenhouses, chloropicrin is used to control weeds, nematodes,
insects, and various soil borne pathogens.
In existing orchards chloropicrin is used to treat small areas to
control weeds, nematodes, insects, and various soil borne
pathogens.
12
-------
Formulations:
Methods of Application:
Chloropicrin is also used to control internal wood decay caused by
fungi and insects in wood poles, timbers, pilings, and glue-
laminated beams.
Chloropicrin can be formulated as a soluble concentrate/liquid,
pressurized gas, pressurized liquid, emulsifiable concentrate, and a
ready-to-use product. All chloropicrin products are classified as
restricted use pesticides (RUP). The "Restricted Use" classification
restricts a product, or its uses, to use by certified pesticide
applicators or those working under the direct supervision of a
certified applicator.
As a pre-plant soil fumigant chloropicrin is either injected (e.g., by
shank) into the soil or applied via drip irrigation. These
applications can either be tarped or untarped.
Chloropicrin is used in existing orchards for tree replant purposes.
Tree site applications take place in small treated areas (10' x 10')
where chloropicrin is injected at least 18 inches into the soil using
a replant wand.
When used as a warning agent prior to sulfuryl fluoride residential
structure fumigations, a tent must first be put up around the
structure. Chloropicrin is then placed in the center of the structure
in either a shallow pan or onto absorbent material. A fan is then
placed to direct the air stream over the pan or absorbent material to
accelerate the chloropicrin's evaporation. Chloropicrin should be
applied 5-10 minutes before sulfuryl fluoride is introduced into the
structure.
For remedial wood treatment, chloropicrin is either poured/injected
or applied with encapsulated vials into pre-drilled holes. For
utility pole treatment, holes are drilled at a 45 degree angle and
chloropicrin is poured/injected or applied with encapsulated vials
into all of the holes. After the chloropicrin has been applied, the
holes are immediately plugged.
Application Rates:
For pre-plant soil fumigation use the following are the supported
maximum application rates:
o 350 Ibs active ingredient (ai) per acre for tarped, shank
injection applications;
o 175 Ibs ai per acre for untarped, shank injection
applications;
o 350 Ib ai per acre for deep (at least 18 inches) untarped,
shank injection applications;
13
-------
o 300 Ibs ai per acre for drip irrigation applications
(including greenhouses);
o 500 Ibs ai per acre for tree hole replant applications, this is
equivalent to 1 Ib of chloropicrin per 100 square feet.
When used as a warning agent prior to sulfuryl fluoride residential
fumigations 1 fluid ounce ai of chloropicrin is used per 10,000-
15,000 cubic feet.
Labels indicate that the amount of chloropicrin used for remedial
wood treatment is based on the size of the pole. Pole applications
range from 4 ounces ai up to 1 1A pints ai for larger poles.
Annual U.S. Usage: According to 2007 Agency use information, about 10 million
pounds of chloropicrin are used annually for pre-plant soil
fumigations. This amount may differ from what has been
presented in the Agency's revised risk assessments since that data
reflected usage data from 2002-2004.
C. Regulatory History
First registered in the U.S. in 1975.
A registration standard was issued in 1982.
Data Call-in's (DCIs) issued in September 1990 and October 1995.
14
-------
III. Summary of Risk and Benefit Assessments and Links to Agency Documents
A. General Overview of Soil Fumigants
Soil fumigants are pesticides that form gasses when applied to soil. Once in the soil, the
fumigants work by controlling pests that can disrupt plant growth and crop production. Soil
fumigants play a very important role in agriculture, but they also have the potential to pose risk
concerns to people involved in the application (handlers), workers who re-enter fumigated fields
(workers), and people who may be near the treated area (bystanders).
B. Human Health Risk from Chloropicrin
The main risk of concern for handlers, workers, and bystanders associated with the soil
uses of chloropicrin is from acute inhalation exposure as a result of fumigant off-gassing.
Chloropicrin handlers also are at risk from direct fumigant exposure during applications. The
term handler refers to persons involved in the application of chloropicrin. For soil applications,
handlers also include persons involved in tarp perforation and removal. The term worker in this
document refers to persons performing non-handler tasks (e.g., planting) within the application
block, after the fumigation process has been completed. The term bystander refers to any person
who lives or works in the vicinity of a fumigation site.
In addition to the soil uses of chloropicrin, there are other uses that the Agency has
assessed and included in this RED. Chloropicrin's use as a warning agent was also evaluated in
the Agency's revised human health risk assessment. Chloropicrin is also used as an
antimicrobial to control internal wood decay in wood poles, timbers, pilings, and glue-laminated
beams. These uses were assessed in a different document than the pre-plant soil and warning
agent uses.
Estimating exposure to fumigants is different from non-fumigant pesticides due to
fumigants' volatility and ability to move off site during and after application. For example,
pesticide spray drift is the physical movement of pesticide particulate or droplets from the target
site during the application and soon thereafter. In the case of soil fumigants, the pesticide moves
as a gas (not as particulate or droplets) and movement off-site can occur for an extended period
after application. Importantly, fumigants have a well-documented history of causing large-scale
human exposure incidents up to several thousand feet from treated fields. Assessing fumigant
exposure takes into account the size of the fumigated field, the amount of fumigant applied, and
the rate at which the fumigant escapes from the treated field.
The term "flux rate" or "emission rate" defines the rate at which a fumigant off-gasses
from a treated field. Many factors influence the emission rate from treated fields. Factors such
as the application method, soil moisture, soil temperature, organic matter levels, water
treatments, the use of tarps, biological activity in the soil, soil texture, weather conditions, soil
compaction, and others influence the amount of fumigant that comes off the field and is available
to move off-site to areas where bystanders may be located.
15
-------
Chloropicrin can cause eye, nose, throat, and upper respiratory irritation. Results from a
chloropicrin human sensory irritation study indicate that eye irritation is the most sensitive effect.
The Agency selected a reversible acute endpoint from the human study. EPA used this study to
determine a bench mark concentration level (BMCLio) of 73 ppb [0.073 parts per million (ppm)].
At this level EPA does not expect eye or nose irritation, or upper respiratory changes. Most of
the study participants detected chloropicrin within 20-30 minutes at 0.15 ppm. This level
corresponds to mild irritation without leading to more severe irritation and respiratory effects. In
addition, the human study shows that persons exposed to 0.15 ppm of chloropicrin, did not
experience irritation effects 1 hour after the exposure ended, and also no irritation effects were
seen the following day.
Based on the human study, a margin of exposure (MOE) of 1 defines the Agency's level
of concern (LOG) for acute inhalation exposure. The uncertainty factors have been removed due
to a) chloropicrin's mode of action (MO A) of sensory irritation,2 and b) evaluation of the most
sensitive human subpopulation to sensory irritants (young adults, average age 23).3
The Agency has high quality data that shows at 0.15 ppm (which corresponds to an MOE
of 0.50) humans begin to sense chloropicrin without leading to more serious effects. While there
are uncertainties about the effects of chloropicrin at higher concentrations and at exposure
durations longer than 1 hour, data do suggest that effects would not become more severe unless
the concentration of chloropicrin increases. Therefore, the Agency is confident that the human
study provides high quality information regarding the dose-response in humans at the levels that
lead to minor, reversible effects.
In assessing risks from chloropicrin, the Agency considered multiple lines of evidence,
using the best available information from monitoring studies, modeling tools, and from incident
reports.
Monitoring: For the human health risk assessments completed for chloropicrin and the
other soil fumigants within the group, several field-scale monitoring studies were
considered, as well as monitoring of workers and handlers involved in various tasks.
These studies quantify chloropicrin concentrations in and around fields at various times
and distances during and after applications. Many of these data indicate that there can be
risks of concern associated with chloropicrin use at a broad range of distances from
treated fields. However, these data are limited in their utility because they provide results
only for the specific conditions under which the study was conducted.
Modeling: Models enable the use of data from monitoring studies to estimate
concentrations and potential risks under a wide range of conditions and use patterns.
EPA used Version 2.1.4 of the Probabilistic Exposure and Risk model for Fumigants
(also called the PERFUM model), to evaluate potential risks at distances around treated
For details on guidance documents and framework the Agency used to determine chloropicrin's see, "MOA Mode
of Action, Eye Irritation, and the Intra-Species Factor: Comparison of Chloropicrin and MITC" June 25, 2008. (DP
Barcode 293356)
3 For a more detailed explanation of the study see, "Chloropicrin: Final Revised HED Human Health Risk
Assessment. June 18, 2008. (DP Barcode 348674).
16
-------
fields. PERFUM incorporates actual weather data and flux distribution estimates, then
accounts for changes and altering conditions. Analyses based on a variety of model
outputs were used to compare the potential risks at a range of distances. The PERFUM
model and users manual are public domain and can be downloaded at
http ://www. exponent, com/perfum/.
Bystander, handler and worker incident reports: Incidents for the soil fumigants
generally occur at a low frequency relative to the total number of fumigant applications
performed annually. However, when incidents occur, there are often many people
involved. Incidents involving handlers and workers tend to occur more often than
incidents with bystanders.
Reconstructing incidents to examine the exact factors which led to the incident can be
difficult, especially when bystanders are involved since all the factors that contributed to
the incident may not have been documented. Some of the factors that have been linked to
incidents in the past have included equipment failure, handler accidents, applicator failure
to adhere to label recommendations and/or requirements, and temperature inversions.
Bystander incidents have occurred both close to fumigated fields and up to two miles
away from the fumigated field.
Based on these lines of evidence, and as described in more detail in the risk assessments,
EPA has determined that chloropicrin risks to handlers, workers, and bystanders are of concern
given current labels and use practices. The human health risk assessments indicate that
inhalation exposures to bystanders who live and work near agricultural fields and greenhouses
where chloropicrin fumigations occur have the potential to exceed the Agency's LOG without
additional mitigation measures. There are also risks of concern for occupational handlers
involved in chloropicrin applications and tarp perforation/removal activities, and for workers
who may re-enter treated areas shortly after fumigation or tarp perforation has been completed.
The Agency does not have risk concerns for bystanders when chloropicrin is used prior to
sulfuryl fluoride residential structure fumigations. When chloropicrin is used to treat wood
decay, the Agency has identified potential acute inhalation risks to bystanders and handlers. The
Agency's concern for acute inhalation exposure to bystanders and handlers is based on the same
data described above. The Agency also does not have a risk concern for dietary exposure
(including drinking water exposure).
For more information about the specific information in the Agency's human health risk
analyses, refer to the documents listed below:
Chloropicrin Final Revised HED Human Health Risk Assessment June 18, 2008. (DP
Barcode 348674)
MO A Mode of Action, Eye Irritation, and the Intra-Species Factor: Comparison of
Chloropicrin and MITC. June 25, 2008. DP Barcode 293356.
Factors Which Impact Soil Fumigant Emissions - Evaluation For Use In Soil Fumigant
Buffer Zone Credit Factor Approach. June 9, 2008. (DP Barcode 306857)
EPA-HQ-OPP-2007-03 50-0009, Review of Fumigants Group Incident Reports.
17
-------
EPA-HQ-OPP-2007-0350-0010, Summary Fumigants Group Incident Reports.
EPA-HQ-OPP-2007-0350-0011, Summary Fumigants Group Incidents DP Barcode
D326938.
For more information on the antimicrobial use of chloropicrin please see the following
documents:
Revised Occupational and Residential/Bystander Assessment of the Antimicrobial Use
(Remedial Wood Treatment) of Chloropicrin for the Reregi strati on Eligibility Decision
(RED) Document (Phase 3 Comment Period). PC Code 081501, DP Barcode D314399.
February 14, 2008.
Updated Label Language for the Antimicrobial Uses of Chloropicrin (PC Code 081501)
for the Reregi strati on Eligibility Decision Document. May 13, 2008.
C. Environmental Fate and Ecological Risks
The Agency's environmental fate and ecological effects risk assessment indicates that
there are some concerns for non-target organisms that may be exposed to fumigants.
Since chloropicrin is highly volatile and is a gas at room temperature and standard
pressure, inhalation is the major exposure pathway for non-target terrestrial animals. For aquatic
organisms, exposure in surface water could result from runoff with dissolved chloropicrin from
fumigated fields.
The Agency evaluated the potential exposure of birds and mammals through inhalation
exposure to chloropicrin using air monitoring data and values derived from exposure modeling.
The Agency has not established LOCs for inhalation risk in animals; standard dietary LOCs were
used. Comparison of modeled exposure concentrations to acute mammalian inhalation toxicity
data did not result in exceedence of the endangered species LOG when exposure concentrations
from PERFUM were used. Chronic exposure to chloropicrin from treatment of individual fields
is not expected.
The potential for inhalation risk to birds was not quantified, because avian inhalation
toxicity data were not available. The potential risk to non-target terrestrial plants was also not
evaluated due to lack of toxicity data.
Exposure to aquatic animals and plants was simulated using the Pesticide Root Zone
Model (PRZM) and Exposure Analysis Modeling System (EXAMS), although there is some
uncertainty in their ability to fully account for the transport of chemicals as volatile as
chloropicrin. Risk quotients exceeded the acute LOG for fish for two of six modeled scenarios
(FL strawberry and FL tomato) and the endangered species LOG for all six scenarios modeled.
The acute LOCs for aquatic invertebrates (endangered species and non-endangered species
LOCs) were exceeded for two of six scenarios (FL strawberry and FL tomato) although the lack
of a definitive toxicity endpoint means that risk could not be completely discounted from the
other four scenarios modeled. Chronic risk to aquatic animals was not evaluated due to lack of
18
-------
data, but volatilization of chloropicrin from surface water would greatly reduce residues of
chloropicrin over time.
1. Hazard
Based on limited data, chloropicrin is considered very highly toxic to both fish (lowest
LC50 = 5.14 ppb) and aquatic invertebrates (lowest LC50 < 71 ppb). Chloropicrin is also
considered highly toxic to mammals. The acute mammal inhalation LD50 is 0.114 mg/L (male
rats) and the developmental NOAEL in rabbits is 0.003 mg/L (LOAEL 0.008 mg/L, based on
abortions and decreased fetal weights). The mammal acute oral LD50 value (used in a
preliminary analysis) is 37.5 mg/kg (highly toxic). The Agency does not have avian inhalation,
terrestrial/aquatic plant, or estuarine/marine aquatic life data.
2. Exposure
a. Environmental Fate
The high vapor pressure (23.8 mm @ 25ฐC), high Henry's Law Constant (2.05 X 10"3
atm M3/mole), and low soil adsorption coefficient (Koc 36.05 L kg"1) of chloropicrin suggest that
volatilization is the most important environmental route of dissipation. Direct photolytic
degradation (ti/2 <8 hrs) of chloropicrin is the primary route of dissipation in the atmosphere,
which suggest it is not a significant threat to deplete stratosphere ozone layer. Due to the fact that
volatilization is significant and occurs rapidly, the importance of other competing processes such
as leaching, biotic and abiotic degradation, and adsorption to the soil particles will certainly
depend on chloropicrin's emission rate from fumigated fields. This is because the emission rate
determines the amount of chloropicrin left for other processes and its residence time in the soil
system. However, if chloropicrin remains in soil, it also degrades with half-lives ranging from
3.7 to 4.5 days with CC>2being the terminal breakdown product. Since chloropicrin is highly
soluble in water and has low adsorption in soil, it can potentially leach into groundwater and to
surface water through runoff under a flooded condition. The low octanol/water partition
coefficient of chloropicrin also indicates that it is not likely to be bioconcentrated in tissues of
aquatic organisms.
b. Terrestrial Exposure
The Industrial Source Complex Short Term Version 3 (ISCST3) model was used to
calculate potential air concentrations to which terrestrial animals might be exposed via
inhalation. Air concentrations at the field edge and at distances away from a 40-acre field edge
were simulated, considering various application rates and methods, including if tarps were used.
The highest air concentration of 0.019 mg/L was estimated. The values used for this assessment
yield conservative air concentration estimates because considering a constant flux rate does not
allow for diurnal/nocturnal changes that may occur, which when coupled with the appropriate
wind speed and stability category, can result in lower concentrations. The meteorological inputs
also will provide a conservative estimate of exposure because the wind direction is considered to
be perpendicular (pointed downwind) to the treated field for the entire 24 hours represented in
the calculation. This is not a normal situation in the atmosphere for most locations.
19
-------
PERFUM was used to refine the potential risks to terrestrial organisms. Twelve different
application scenarios (e.g., broadcast, bedded, tarped, untarped, drip irrigation,
Bakersfield/Ventura sites, application rates up to 350 Ib ai/A) were modeled. The highest 90th
percentile air residue across these scenarios is 0.004219 mg/ m3, for 40 acres, broadcast,
untarped, 0-5 meters radius from the field edge, 8-12 hours after application at 175 Ib ai/A.
This value is significantly less than the greatest value simulated using the ISCST3 model.
Available ambient monitoring data for chloropicrin indicates a maximum ambient air
concentration of 0.000014 mg/L. Although it is possible that birds and mammals could be
exposed to chloropicrin repeatedly by ranging between treated fields, the historical ambient air
concentration was considered to determine the potential for chronic inhalation exposure.
c. Aquatic Exposure
Aquatic exposure was simulated using the combined PRZM and EXAMS surface water
models. Estimated environmental concentrations (EECs) resulting from application of 350 Ib
ai/A and 175 Ib ai/A were simulated for six crop scenarios (CA tomatoes, CA onions, FL
tomatoes, FL strawberries, NC sweet potatoes, and NC tobacco). The calculated EECs were on
the order of 1.0 ug/L or less for the California and North Carolina scenarios, but were on the
order of 70 ug/L for the Florida scenarios.
There is an uncertainly in estimating chloropicrin exposure in water bodies due to post-
application tarping of the treated area. If tarping is used to minimize the volatilization of
chloropicrin, the loading of the chemical through runoff will be limited until the tarp is
perforated or removed from the field. The present version of the PRZM model and the selected
crop scenarios have limited capabilities in capturing the load of applied chemical under a post-
application tarp scenario. Therefore, the estimated concentrations of chloropicrin in water bodies
may be upper bound for tarped scenarios since the load of chloropicrin from runoff is considered
in the PRZM/EXAMS simulation.
Because chloropicrin is highly soluble in water and has low adsorption in soil, residual
chloropicrin in soil can potentially leach into groundwater under continuous irrigation and/or
high rainfall events. However, consideration of the potential for groundwater contamination
must take into account the fact that irrigation is applied with the intent of keeping chloropicrin
within a small depth range around the root zone (and not below to groundwater). In addition,
degradation of chloropicrin under a tarped field, and limited dissipation of material though a tarp
would reduce the amount of residues which might be transported to groundwater by a potential
heavy rainfall soon after the tarp is removed.
3. Risk
a. Terrestrial Risk
A risk quotient derived from the maximum EEC from the ISCST3 model and acute
mammalian toxicity data was 0.17. Although the Agency has not set LOCs for inhalation risk to
20
-------
terrestrial animals, this value exceeds the standard endangered species LOG used in ecological
dietary risk assessments. The maximum EEC from the refined PERFUM model, however,
results in a maximum RQ below the endangered species LOG. Comparison of ambient
chloropicrin concentrations in air from historical monitoring data to chronic rabbit inhalation
toxicity data resulted in a RQ below the standard chronic LOG of 1.0.
Risk to birds from inhalation exposure to chloropicrin could not be assessed using the
ISCST3 or PERFUM exposure estimates because avian inhalation toxicity data were not
available. The potential for risk to non-target terrestrial plants was also not evaluated due to lack
of toxicity data.
b. Aquatic Risk
Risk quotients exceeded the acute LOG for fish for two of six modeled scenarios (FL
strawberry and FL tomato), and the endangered species LOG for all six scenarios. The acute
LOCs for aquatic invertebrates (endangered species and non-endangered species) were exceeded
for two of six scenarios (FL strawberry and FL tomato), although the lack of a definitive toxicity
endpoint means that risk could not be completely discounted from the other four scenarios
modeled. Chronic risk to aquatic animals was not evaluated due to a lack of data, but
volatilization of chloropicrin from surface water would greatly reduce residues of chloropicrin
over time.
For more information about the specific information in the Agency's assessment of
environmental fate and ecological risks, refer to the following document:
Revised Screening Ecological Risk Assessment for the Reregi strati on of Chloropicrin.
DP Barcode 348669. April 16, 2008.
D. Benefits
Soil fumigation can provide benefits to both food consumers and growers. For
consumers it means more fresh fruits and vegetables can be cheaply produced year-round
because severe pest problems can be efficiently controlled. Growers benefit because crops
grown in fumigated soil produce fewer blemished products, which translates into an increase in
marketable yields. Fumigation can also provide benefits to growers by increasing crop
management flexibility. This includes shorter crop rotational intervals (i.e., less time when fields
are left fallow), improved ability to meet quarantine requirements (which are imposed when
states or other jurisdictions require a pest-free harvested product), and consistent efficacy against
critical pests. The magnitude of benefits depends on pest pressure, which varies over space and
time, and the availability and costs associated with the use of alternatives.
Since chloropicrin is often used in combination with other fumigants, it is difficult to
estimate an exact benefit for chloropicrin alone. Agency assessments (e.g., chloropicrin's use in
pepper production) indicate that if chloropicrin were no longer available, growers could
experience large yield losses. These losses combined with increases in production costs that are
higher than revenue could cause growers to stop pepper production.
21
-------
Other benefits of chloropicrin include its use as a methyl bromide alternative and
chloropicrin's role as a warning agent which makes people aware of potential exposures to other
fumigants such as methyl bromide.
There are a number of benefit assessments that have been completed by the Agency to
estimate the value of fumigants to various industries. Below is a list of the specific benefit
assessments that include chloropicrin.
EPA-HQ-OPP-2007-03 50-0017, Summary of the Benefits of Soil Fumigation with
Chloropicrin in Crop Production.
EPA-HQ-OPP-2007-03 50-0018, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam Sodium in Cucurbit Production.
EPA-HQ-OPP-2007-03 50-0019, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam Sodium in Eggplant Production
EPA-HQ-OPP-2007-03 50-0020, Assessment of the Benefits Soil Fumigants (Methyl
Bromide, Chloropicrin, Metam-Sodium, Dazomet) Used by Forest Tree Seedling
Nurseries.
EPA-HQ-OPP-2007-03 50-0021, Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin, Dazomet, and Metam Sodium for Use in Raspberry
Nurseries, Fruit and Nut Deciduous Tree Nurseries, and Rose Bush Nurseries in
California.
EPA-HQ-OPP-2007-03 50-0022, Assessment of the Benefits of Soil Fumigation with
Chloropicrin and Metam-sodium in Onion Production.
EPA-HQ-OPP-2007-0350-0023, Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin, and Metam Sodium in Grape Production.
EPA-HQ-OPP-2007-03 50-0024, Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin and Metam Sodium in Tree Nut Production.
EPA-HQ-OPP-2007-03 50-0025, Assessment of the Benefits of Soil Fumigation with
Chloropicrin and Metam Sodium in Pome Fruits Production.
EPA-HQ-OPP-2007-03 50-0026, Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin, and Metam Sodium in Stone Fruit Production.
EPA-HQ-OPP-2007-03 50-0027, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam Sodium in Bell Pepper Production.
EPA-HQ-OPP-2007-03 50-0028, Assessment of the Benefits of Soil Fumigation with
Metam Sodium in Potato Production.
EPA-HQ-OPP-2007-0350-0029, Assessment of Soil Fumigation with Chloropicrin,
Methyl Bromide and Metam-sodium in Strawberry Production.
EPA-HQ-OPP-2007-0350-0030, Assessment of the Benefits of Chloropicrin, Methyl
Bromide, Metam-sodium and Dazomet Use In Strawberry Nursery Runner Production.
EPA-HQ-OPP-2007-03 50-0031, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam-sodium on Sweet Potato Production.
EPA-HQ-OPP-2007-03 50-0032, Assessment of the Benefits of Soil Fumigation with
Chloropicrin in Tobacco Production.
22
-------
EPA-HQ-OPP-2007-0350-0033, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam Sodium in Tomato Production.
EPA-HQ-OPP-2007-03 50-0034, Assessment of the Benefits of Soil Fumigation with
Metam-Sodium in Carrot Production.
EPA-HQ-OPP-2007-03 50-003 5, Assessment of the Benefits of Soil Fumigation with
Metam Sodium in Peanut Production.
EPA-HQ-OPP-2007-0350-0036, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, Metam Sodium and Dazomet in Ornamental Production.
EPA-HQ-OPP-2007-0350-0037, BEAD'S Planned Impact Assessments on Agricultural
Sites with Significant Use of Soil Fumigants (Chloropicrin, Dazomet, Methyl Bromide,
Metam Potassium, and Metam Sodium.
23
-------
IV. Risk Management and Reregistration Decision
A. Determination of Reregistration Eligibility
Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission of
relevant data concerning an active ingredient, whether pesticides containing the active ingredient
are eligible for reregi strati on. The Agency has previously identified and required the submission
of the generic (i.e., active ingredient specific) data required to support reregi strati on of products
containing chloropicrin.
The Agency has completed its assessment of the dietary (including drinking water),
residential, occupational, and ecological risks associated with the use of pesticides containing the
active ingredient chloropicrin. Dietary (food) risks were not quantitatively assessed because
there are no food/feed uses of chloropicrin. In addition to the risk assessments, the Agency
completed benefit assessments on crops with significant chloropicrin usage.4
In Phase 5, the Agency published a risk mitigation options paper.5 This document
detailed potential mitigation options and sought public comment on these options. The following
is the list of mitigation options discussed in the Agency's paper:
Buffer zones;
Sealing methods;
Timing of applications;
Application block size limitations;
Respiratory protection;
Tarp cutting/removal procedures;
Entry-restricted period;
Application method/practice restrictions;
Fumigant management plans (FMPs);
FMP certification;
Responsible parties;
Record keeping/reporting/tracking;
Restricted Use Pesticide Classification (this option does not apply to
chloropicrin, since it is already a RUP);
Notification and posting;
Good agricultural practices(GAPs);
Fumigant manuals; and
Stewardship programs.
4 EPA-HQ-OPP-2007-0350-0037, BEAD'S Planned Impact Assessments on Agricultural Site with Significant Use
of Soil Fumigants
5 EPA-HQ-OPP-2007-03 50-0003, Risk Mitigation Options to Address Bystander and Occupational Exposures from
Soil Fumigant Applications
24
-------
Based on a review of the chloropicrin data and public comments on the Agency's
assessments for the active ingredient chloropicrin, the Agency has sufficient information on the
human health and ecological effects as well as the benefits of chloropicrin to make a decision as
part of the reregi strati on process under FIFRA. The Agency has determined that most of the
supported uses of chloropicrin will not pose unreasonable risks or adverse effects to humans or
the environment provided that the risk mitigation measures and label changes outlined in this
RED are implemented. The Agency does not have adequate data to evaluate the risks associated
with untarped chloropicrin drip applications that are buried a minimum of 5 inches. The CMTF
has just submitted a study, and provided the study is acceptable and the Agency can determine
appropriate risk mitigation, this use will be eligible for reregi strati on.
Based on its evaluation of chloropicrin, the Agency has determined that chloropicrin
products, unless labeled and used as specified in this document, would present risks inconsistent
with FIFRA. Accordingly, should a registrant fail to implement any of the risk mitigation
measures identified in this document, the Agency may take regulatory action to address the risk
concerns from the use of chloropicrin. If all changes outlined in this document are incorporated
into the product labels, then current risks for chloropicrin will be adequately mitigated for the
purposes of this determination under FIFRA.
A substantial amount of research is currently underway or is expected to begin in the near
term to (1) address current data gaps, and (2) refine understanding of factors that affect fumigant
emissions. Additionally, a number of new methods and technologies for fumigation are
emerging. EPA plans to move the soil fumigants forward in Registration Review, from 2017 to
2013, which will allow EPA to consider new data and information relatively soon, determine
whether the mitigation included in this decision is effectively addressing the risks as EPA
believes it will, and to include other soil fumigants which are not part of the current fumigant
group review.
The Registration Review process for chloropicrin and the other soil fumigants will also
include a comprehensive endangered species assessment. Once that endangered species
assessment is completed, further changes to chloropicrin labels may be necessary.
B. Public Comments and Responses
The Phase 3 public comment period on the preliminary risk assessments and related
documents commenced November 29, 2006 and ended on February 28, 2007. The Agency
documents and comments can be found in the chloropicrin docket, EPA-HQ-OPP-2006-0661.
The Agency's responses to comments received are available in the new chloropicrin docket,
EPA-HQ-OPP-2007-0350. Both dockets can be found at www.regulations.gov.
After the Phase 3 comment period, the Agency revised the human health risk assessment,
completed benefit assessments, and developed risk mitigation options. These documents were
put out for public comment on May 2, 2007 and the comment period ended on November 3,
2007. Comments on issues which were significant to many stakeholders and directly influenced
EPA's decisions are highlighted in this decision document, as well as EPA's responses to those
25
-------
comments. The following documents include the EPA's responses to comments. These
documents are located in the chloropicrin docket, EPA-HQ-OPP-2007-0350.
RESPONSE TO PUBLIC COMMENTS. The Health Effects Division's Response to
Comments on the Agency's April 12, 2007 document, Chloropicrin: RevisedHED
Human Health Risk Assessment for Phase 5 (Docket EPA-HQ-OPP-2007-0350). June 18,
2008. DP Barcode 348676.
Response to Phase 5 Public Comments on the Phase 4 Chloropicrin Reregi strati on Risk
Assessment. April 16, 2008. DP Barcode 348669.
Review of Stakeholder Submitted Impact Assessments of Proposed Fumigant Buffers,
Comments on Initial Buffer Zone Proposal, and Case Studies of the Impact of a Flexible
Buffer System for Managing By-Stander Risks of Fumigants. June 25, 2008. DP
Barcode 353940.
Response to Phase 5 BEAD Related Public Comments Received on the Reregi strati on of
Chloropicrin, Dazomet, Metam Potassium, Metam Sodium, and Methyl Bromide. June
25, 2008. DP Barcode 353940.
Phase 6 Response to Substantive Public Comments on Antimicrobials Division's
Occupational and Residential Assessments for the Reregi strati on Eligibility Decision
(RED) Documents for the following chemicals: Methylisothiocyanate (MITC), Metam
Sodium, Dazomet, and Chloropicrin. February, 14, 2008.
SRRD's Response to Phase 5 Public Comments for the Soil Fumigants, July 2008.
C. Regulatory Position
1. Regulatory Rationale
The Agency has determined that the supported uses of chloropicrin are eligible for
reregi strati on provided the risk mitigation measures outlined in this document are adopted and
label amendments are made to reflect these measures. This decision considers the risk
assessments conducted by the Agency and the significance of chloropicrin use.
a. Chloropicrin Pre-Plant Soil Uses
As summarized in Section III, there are risks of concern to humans and the environment
resulting from chloropicrin use. Understanding these risks, and also the benefits of chloropicrin
(also outlined in Section III), the Agency's goal for this decision is to be protective, especially of
severe and irreversible effects, encourage best practices, and to reduce the potential impacts on
benefits. To reach this goal, EPA considered a range of factors including:
exposure characteristics of bystander and other populations exposed to chloropicrin;
hazard characteristics of chloropicrin (the chloropicrin endpoint is based on a minor and
reversible effect, eye irritation);
hazard characteristics of other fumigants that are combined with chloropicrin;
available information on levels of exposure, feasibility, cost, and effectiveness of various
risk mitigation options;
bystander, handler and worker incident reports;
26
-------
potential impacts of mitigation on growers' ability to produce crops;
uncertainties and assumptions underlying the risk and benefit assessments; and
public comments.
Considering these factors, EPA determined that a suite of complimentary measures
designed to reduce risks, along with a flexible approach allowing for some site-specific
decisions, would best meet the overall objective of reducing risk and minimizing impacts on
users.
The following is a summary of the rationale for managing risks associated with the
supported uses of chloropicrin. Where labeling revisions are warranted, specific language is set
forth in the summary tables in Section V of this document.
i. Human Health Risk Management
The human health risk assessment indicates that inhalation exposures to bystanders,
handlers, and workers who live and work near agricultural fields and greenhouses where
chloropicrin fumigations occur have the potential to exceed the Agency's level of concern
without additional mitigation measures. To reduce the potential for chloropicrin exposure to
bystanders, handlers, and workers and to address associated risks of concern, EPA is requiring a
number of mitigation measures which include:
buffer zones,
posting,
monitoring and respiratory protection,
restrictions on the timing of tarp perforation and removal operations,
entry prohibitions,
mandatory good agricultural practices (GAPs),
fumigant management plans (FMPs),
emergency preparedness and response, and
notice to state lead agencies.
The Agency also believes that registrant developed training and community outreach and
education programs, which are also implemented by the registrant, will help reduce risk.
Additionally, EPA is interested in working with registrants to identify additional measures that
could be implemented as part of product stewardship. These additional measures should include
efforts to assist users' transition to the new label requirements.
Some of the required mitigation measures only address one group of potentially exposed
individuals (i.e., bystanders, handlers, or workers), while other measures will help reduce risk to
more than one group. All mitigation measures are designed to work together to reduce
exposures, enhance safety, and facilitate compliance and enforcement. The Agency has based its
risk mitigation decision on a flexible approach which EPA believes will be protective and allow
users to make site-specific choices to reduce potential impacts on benefits of the use. While
some of these measures, buffer zones for example, can be used to estimate MOEs, others such as
emergency preparedness and response and community outreach and education will contribute to
bystander safety, but are difficult to express in terms of changes to quantitative risk estimates
27
-------
such as MOEs. However, EPA has determined that these measures, working together, will
prevent unreasonable adverse effects on human health.
1. Bystander Risk Mitigation
Bystanders are persons who live and/or work near fumigated fields and could be
potentially exposed to fumigant emissions that travel off-site. In some cases the bystanders are
workers performing agricultural tasks in nearby fields. If they are employed by the grower who
has control of the fumigated field, they are more likely to be aware that a fumigant application
has occurred.
Bystander risks for people that live near treated fields differ from other human health
risks evaluated under FIFRA, for example residential and worker reentry risks. Unlike
residential exposures resulting from use of products to control pests in and around the home,
non-occupational bystanders receive no direct benefit from the pesticide which was applied
elsewhere. These bystanders have not made a decision to purchase a pest control product or
service, and as a result they have little access to information about the product (e.g., hazards,
safety information, first aid, etc.) or symptoms of exposure. Additionally, non-occupational
bystander exposures to fumigants are largely involuntary and unanticipated. In this regard non-
occupational bystander exposure is similar to dietary exposure in that people consuming foods or
drinking water expect to be safe from possible adverse effects associated with pesticide residues
that could be present in their food and drinking water.
Unlike workers, non-occupational bystanders typically receive no safety information or
training related to the pesticide to which they may be exposed. Whereas workers are generally
expected to play an active role in protecting themselves from pesticide risk, no such expectation
exists for non-occupational bystanders. Workers who experience symptoms of pesticide
exposure are also more likely to link their symptoms to the pesticide and take steps to receive
appropriate treatment. Conversely, bystanders are much less likely to attribute adverse effects to
pesticide exposures or to have access to information needed to take appropriate steps to mitigate
the effects of the exposure. Thus, EPA's mitigation includes elements of emergency
preparedness and response, notice to state lead agencies, training, and community outreach and
education as well as labeling changes.
a. Buffer Zones
The human health risk assessment indicates that bystanders may be exposed to
chloropicrin air concentrations that exceed the Agency's level of concern. In general, the risk
from inhalation exposures decreases as the distance between bystanders and the treated field
increases. Because of this relationship, the Agency is requiring that a buffer zone be established
around the perimeter of each application block where chloropicrin is applied. The Agency
acknowledges that buffer zones alone will not mitigate all bystander inhalation risks or eliminate
incidents caused by equipment failure, human error, and weather or other events (e.g.,
temperature inversions). The Agency, however, does believe that buffer zones along with the
other mitigation measures required by this decision will mitigate risks so that bystanders will not
experience unreasonable adverse effects.
28
-------
The Agency considered various buffer zone schemes ranging from fixed buffer zones for
every chloropicrin application to site-specific buffer zones. During the most recent comment
period, the Agency received input in favor of a flexible buffer approach that would allow
fumigant users to determine the buffer zone distance based on site conditions and application
practices. While the Agency believes that site-specific buffer zones would provide the most
flexibility for users, the EPA currently does not have sufficient data to support this scheme. As a
result, the Agency developed a scalable buffer zone system that does provide flexibility by
setting buffer zones for different application methods at various acreages and application rates.
These distances have been captured in "Look-up Tables" presented below in Tables 2, 3, 4, 5, 6,
7, and 8 in the Buffer Zone Distances section on page 35.
Version 2.1.4 of the Probabilistic Exposure and Risk model for Fumigants (also called
the PERFUM model) combined with monitoring data and incident data were used to characterize
the risk for specific buffer zone distances corresponding to the range of application scenarios
anticipated. A CD containing all of the PERFUM input/output files and files with the PERFUM
MOE/air concentration analysis that were considered for this decision are available upon request
at the OPP Docket Office. Additional information on the PERFUM inputs and outputs can be
found in the Agency's risk assessment3, in a June 2006 a peer-reviewed article describing the
model (http://www.sciencedirect.com/science/journal/13522310), and/or the PERFUM user's
guide which can be download from the internet (http://www.exponent.com/perfum/)
i. General Buffer Zone Requirements
The following describes the general buffer zone requirements for chloropicrin and other
soil fumigants currently going through the reregi strati on process:
"Buffer zone" is an area established around the perimeter of each application block or
greenhouse where a soil fumigant is applied. The buffer zone must extend from the edge of
the application block or greenhouse perimeter equally in all directions.
All non-handlers including field workers, nearby residents, pedestrians, and other bystanders,
must be excluded from the buffer zone during the buffer zone period, except for transit (see
exemptions section).
An "application block" is a field or portion of a field treated with a fumigant in any 24-hour
period (see Figures 1 and 2 for further explanation).
The "buffer zone period" starts at the moment when any fumigant is delivered/dispensed to
the soil within the application block and lasts for a minimum of 48 hours after the fumigant
has stopped being delivered/dispensed to the soil.
Buffer zone distances
Buffer zone distances must be based on look-up tables on product labels (25 feet is the
smallest distance regardless of site-specific application parameters).
For selective replant fumigations in an orchard using hand held application methods (e.g.,
deep injection auger probes), the minimum buffer zone will be 25 feet measured from the
center of each injection site (i.e., tree hole).
29
-------
Authorized entry into buffer zones
Only authorized handlers who have been properly trained and equipped according to EPA's
Worker Protection Standard (WPS) and label requirements may be in the buffer zone during
the buffer zone period.
Buffer zone proximity
To reduce the potential for off-site movement from multiple fumigated fields, buffer zones
for products containing chloropicrin from multiple application blocks may not overlap
(including blocks fumigated by adjacent property owners; see below for exemptions for areas
not under the control of owner/operator of application block). Prohibiting buffer zones from
overlapping will address potential for bystander exposure from multiple fields.
No fumigant applications will be permitted within 0.25 miles of schools, state licensed day
care centers, nursing homes, assisted living facilities, elder care facilities, hospitals, in-patient
clinics and prisons if occupied during the buffer zone period.
Exemptions for transit through buffer zones
Vehicular and bicycle traffic on public and private roadways through the buffer zone is
permitted. "Roadway" means that portion of a street or highway improved, designed or
ordinarily used for vehicular travel, exclusive of the sidewalk or shoulder even though such
sidewalk or shoulder is used by persons riding bicycles. In the event a highway includes two
or more separated roadways, the term "roadway" shall refer to any such roadway separately.
(This definition is based on the definition of roadway in the Uniform Vehicle Code prepared
by the National Committee on Uniform Traffic Laws and Ordinances. See
http://www.ncutlo.org/ for more details)
Bus stops or other locations where persons wait for public transit are not permitted within the
buffer zone.
See Posting section on page 47 for additional requirements that may apply.
Structures under the control of owner/operator of the application block
Buffer zones may not include buildings used for storage such as sheds, barns, garages, etc.,
UNLESS,
1. The storage buildings are not occupied during the buffer zone period, and
2. The storage buildings do not share a common wall with an occupied structure.
See Posting section on page 47 for additional requirements that may apply.
Areas not under the control of owner/operator of the application block
Buffer zones may not include residential areas (including employee housing, private
property, buildings, commercial, industrial, and other areas that people may occupy or
outdoor residential areas, such as lawns, gardens, or play areas), UNLESS,
1. The occupants provide written agreement that they will voluntarily vacate the buffer zone
during the entire buffer zone period, and
2. Reentry by occupants and other non-handlers must not occur until,
o The buffer zone period has ended, and
o Two consecutive air samples for chloropicrin taken in the structure at least 1 hour
apart indicate less than 0.15 ppm chloropicrin is present.
30
-------
Buffer zones may not include agricultural areas owned/operated by persons other than the
owner/operator of the application block, UNLESS,
1. The owner/operator of the application block can ensure that the buffer zone will not
overlap with a buffer zone from any adjacent property owners, and
2. The owner/operator of the areas that are not under the control of the application provides
written agreement to the applicator that they, their employees, and other persons will stay
out of the buffer zone during the entire buffer zone period.
Buffer zones may not include publicly owned and/or operated areas (e.g., parks, rights of
way, side walks, walking paths, playgrounds, athletic fields, etc), UNLESS,
1. The area is not occupied during the buffer zone period,
2. Entry by non-handlers is prohibited during the buffer zone period, and
3. Written permission to include the public area in the buffer zone is granted by the
appropriate state and/or local authorities responsible for management and operation of the
area.
See Posting section on page 47 for additional requirements that apply.
ii. PERFUM Model Inputs
The major input parameters for the PERFUM model were: application rates, application
block sizes, application method emission studies, weather conditions, and target air concentration
(based on acute inhalation endpoint and uncertainty factors). The following summarizes the key
points for each of these input parameters.
Rates
o Agricultural Field
Although labels currently allow higher rates, the Agency modeled the maximum rates
supported by the CMTF. These rates are listed in Section IIB on page 12 . Buffer zones were
determined for the maximum rates as well as increments less than the maximum application rate.
This was done to allow flexibility in the buffer approach while taking into consideration current
typical use patterns. According to 2007 Agency proprietary data about 93% of chloropicrin
usage is at rates less than 125 Ibs ai/A. The Agency completed a series of benefit assessments by
crop and region that include a more detailed analysis of use rates.
o Greenhouse
The maximum application rate for greenhouse drip applications is 300 Ibs ai/A. This is
the same rate used in outdoor agricultural field drip applications.
Rates for bedded or strip applications (Ib ai per treated area) were converted to broadcast
equivalent application rate to determine the minimum buffer zone distance. In Figures 1 and 2
(shown below), the dashed line represents the perimeter of the field, the shaded area is the
portion of the field that is treated, and the un-shaded area is the untreated portion of the field.
Assuming both fields are 10 acres, and only 50% of field in Figure 2 is fumigated, the rate per
31
-------
treated acre is 400 Ibs ai/A for both Figure 1 and 2. The broadcast rate for Figure 1 is 400 Ib
ai/A but the effective broadcast equivalent rate for Figure 2 is 200 Ibs ai/A.
Labels may express rates as Ibs per treated acre under the application instructions but
they must identify buffer zone distances based on the broadcast or effective broadcast equivalent
rates.
Figure 1. Broadcast Application Figure 2. Bedded Application
Block Size
o Agricultural Field
The Agency has limited information regarding the size of the application blocks typically
treated in a given day, but estimates that each crew or application rig treats less than 40 acres for
most scenarios. However several commercial applicators have indicated that they sometimes use
multiple rigs and crews to treat blocks greater than 80 acres per day.
Buffer zone distances were determined for 1, 5, 10, 20, 30, 40, 50, 60, 80, and 120 acres.
The application block size pertains to size of the field and not the size of the area treated.
The area inside the dashed lines in both Figures 1 and 2 is the application block. In this example
the application block size for both figures is 10 acres. For both figures, 10 acres would be used
to determine the buffer zone distance.
o Greenhouse
Greenhouse soil fumigations can take place in a wide range of structure sizes. The
Agency modeled the following 5,000; 10,000; 15,000; 20,000; 25,000; 30,000; 35,000; 40;000;
45,000; and 50,000 ft2.
Emission Studies and Weather Data
o Agricultural Field
The Phase 5 risk assessment modeled the following emissions studies combined with the
listed weather data sets for pre-plant agricultural field soil use.
32
-------
Table 1. Emission Studies and Weather Data for Chloropicrin Applications
Application Method
Shank, bed, tarp
Shank, bed, untarp
Shank, broadcast, tarp
Shank, broadcast, untarp
Drip, surface, tarp
Emission Study Location
Phoenix, AZ
Phoenix, AZ*
Phoenix, AZ*
Yakima, WA
Bradenton, FL
Phoenix, AZ*
Salinas, CA (virtually
impermeable film, VIF, tarp)
Salinas, CA (poly tarp)*
Douglas, GA (poly tarp)
Weather Data Modeled
Ventura, CA
Bakersfield, CA
Yakima, WA
Flint, MI
Tallahassee, FL
Bradenton, FL
Ventura, CA
Bakersfield, CA
Yakima, WA
Flint, MI
Tallahassee, FL
Bradenton, FL*
Ventura, CA*
Bakersfield, CA
Flint, MI
Yakima, WA
Flint, MI
Flint, MI
Tallahassee, FL
Bradenton, FL
Ventura, CA*
Bakersfield, CA
Yakima, WA
Flint, MI
Tallahassee, FL
Bradenton, FL
Ventura, CA
Bakersfield, CA
Yakima, WA
Flint, MI
Tallahassee, FL
Bradenton, FL
Ventura, CA
Bakersfield, CA
Yakima, WA*
Flint, MI
Tallahassee, FL
Bradenton, FL
Yakima, WA
Flint, MI
Tallahassee, FL
Bradenton, FL
The asterisks (*) in Table 1 represent the emission studies and weather data that were
used to frame the buffer zone distances. These are the most conservative estimates based on the
33
-------
Agency's risk assessment, which used all of the valid and available emissions studies for
chloropicrin, as well as weather data that are representative of regions of the country where
chloropicrin is commonly used. Please note that the Agency did not use the Salinas, CA drip
irrigation study with the VIF tarp for a baseline even though the human health risk assessment
shows that the PERFUM outputs are the largest. The Salinas, CA poly tarp study was used
instead because the VIF study was conducted in 2000, and the Agency does not believe that the
study reflects current high barrier film technology. The Agency also used the shank untarped
broadcast emission study as a surrogate to help frame the buffer zones for the deep (at least 18
inches) untarped broadcast application method. Each modeling run used five years of weather
data (i.e., 1825 potential application days) for each location. The Agency realizes that emissions
studies vary regionally and that more regionally representative emissions data would reduce
uncertainty in determining buffer zone distances. While the Agency has emissions studies for
the shank, broadcast, application method in Phoenix, AZ, Yakima, WA, and Bradenton, FL, the
buffer zones are based on the most conservative results from the Phoenix, AZ study. At this
time, the Agency did not use a site-specific approach for this decision because of data gaps for
many of the application methods, the variation among regions, and the complexity of
implementation.
The Agency did not use the Phoenix, AZ shank, bed, tarp emission study as the baseline
for the shank, bed, tarp buffers presented in Table 2. Instead the Phoenix, AZ broadcast, shank,
tarp study was used. This is because the Phoenix, AZ tarp-bedded study began at 7:00 pm, and
the Agency does not believe that nighttime applications are a common practice. In response to
an Agency question regarding limiting applications to the daytime, the CMTF commented that,
"Currently all field applications of chloropicrin are conducted during daylight hours.6" Because
of the late start time, the peak flux rates occurred during the night when atmospheric conditions
are typically more stable which therefore generated larger buffer distances. The Agency is not
restricting chloropicrin applications to daylight hours, however the Agency is requiring that the
buffer zone distance increase 25% for all products containing chloropicrin for shank, bedded,
tarp applications if applications are made between one hour before sunset and one hour after
sunrise.
o Greenhouse
A flux study was not used. Instead a 24-hour continuous single emission was used in the
modeling runs. This is based upon current California permit conditions. Ventura, CA weather
data was used.
Target Air Concentration
o Agricultural Field and Greenhouse
Based on several factors including the severity and reversibility of the effect, and the
quality of the hazard database, the buffer zone distance target is to reach an air concentration of
0.073 ppm which equates to an MOE of 1. At minimum, if the target MOE was not reached, half
6 EPA-HQ-OPP-2007-0350-0150. Comments on USEPA's Chloropicrin Revised Risk Assessments Phase 5.
Chloropicrin Manufacturers' Task Force.
34
-------
of the target (MOE 0.5), which corresponds to minor, reversible effects, was achieved with the
buffer zone distance selected.
Hi. PERFUM Model Outputs
The PEFRUM model outputs are presented in percentiles for "whole field" and the
"maximum distance" distributions. The model also provides outputs as distributions of air
concentrations from which MOEs can be estimated. The following summarizes the key points
for each of these output parameters.
The maximum distance distribution is a compilation of the farthest predicted distances
(i.e., the farthest downwind points) over 5 years of weather. The whole field distribution differs
because it includes all points around the perimeter of the application block for the same period.
Another way to consider the difference between the distributions is that maximum distance
results are a subset of the whole field results and that maximum distances allow for more
resolution at the upper percentiles of this distribution. Version 2.1.4 of PERFUM also allows for
direct consideration of air concentrations at various distances around treated fields. These air
concentrations and MOEs were also considered in the decision making process.
An analysis based on a variety of PERFUM outputs was used in the buffer distance
determinations. This involved consideration of the typical maximum and whole-field results,
which are predictions of the distances where a target concentration of concern is achieved at
varying percentiles of exposure. In addition, a complementary approach, which determined the
percentiles of exposure for maximum and whole-field buffers at predetermined buffer distances,
was employed. Air concentration data were also used to calculate risk estimates (i.e., MOEs) at
predefined buffer distances and varied percentiles of exposure.
The chloropicrin buffers focused on reaching upper percentiles of the whole field
distribution from PERFUM modeling outputs, as well as achieving an MOE of 1 at the 95th
percentile air concentration or an MOE of 0.50 at the 99th percentile air concentration from
PERFUM outputs.
This overall approach allowed the Agency to utilize more of the information available
from PERFUM so that a more comprehensive view of the risks could be considered. Buffer
distances indicated by this type of analysis along with information from monitoring studies and
incidents were valuable in determining buffer distances to manage potential risks from
chloropicrin use when coupled with other mitigation measures.
iv. Buffer Zone Distances
o Agricultural Field
The Agency has developed buffer zones for different application methods, application
rates, and application block sizes. The buffer zones for the supported chloropicrin use scenarios
are presented in Tables 2, 3, 4, 5, 6, and 7. It should be noted that the distances in the lookup
35
-------
tables are not model outputs, although as described above the model outputs were used to inform
the selection of buffer zone distances.
o Greenhouse
The Agency has developed buffer zones for the different size structures (up to 50,000 ft2)
for greenhouse pre-plant soil fumigations. The maximum size greenhouse that can be fumigated
is 50,000 ft2. Also, all pre-plant greenhouse fumigations must be tarped.
The "greenhouse" industry sector is extremely varied because of the breadth of the
facilities that are used across the country and because of the nature of the products that are
produced. As a result, some clarification is required to interpret the buffer zone distances for
"greenhouses." In common "greenhouse" operations, many types of containerized ornamental
plants and vegetable starter sets are produced in either closed structures that will be referred to as
"greenhouses" or in other related nursery operations such as small fields, or in what are
commonly known as "shade" houses (i.e., essentially fields with an overhead sunblock, typically
a semi-transluscent black shade cloth). In the latter type of operation, cultural practices related
to chloropicrin use are essentially identical to the pre-plant field uses except they typically occur
on a smaller scale (e.g., 1 acre applications or less). As a result, the minimum buffer zone
distances for these types of use patterns must be determined from the applicable outdoor lookup
tables. For "greenhouses" the buffer zone distances will be based on Table 8.
Minimum and Maximum Buffer Zone Distances for Agricultural Field and
Greenhouse
A minimum buffer zone distance of 25 feet will be required regardless of site-specific
application parameters. In some instances the PERFUM model predicts that the risks reach the
target at the edge of the field, but the Agency believes that a 25 foot minimum buffer is a good
agricultural practice. While modeling may support no buffer in some cases, a minimum buffer is
being required because of variability in the emission rate over a field and other factors not
accounted for in the modeling. Application scenarios requiring buffer zones greater than /^ mile
(2,640 feet), with or without credits, are prohibited. EPA believes that for areas where
chloropicrin is used, buffers greater than 1A mile are not practical and are difficult to enforce. In
addition, application scenarios where the model reached its maximum distance before an
acceptable concentration was reached are prohibited.
Distances for Combination Products
As mentioned previously, products containing chloropicrin often include other active
ingredients, for example methyl bromide, 1,3-D, and iodomethane. Buffer distances have also
been developed for these fumigants. In accordance with Agency policy, when a pesticide
product contains more than one active ingredient, the product shall bear labeling for the active
ingredient with the more restrictive measures. When chloropicrin is formulated with methyl
bromide, the buffers generally are based on the fumigant with the greater amount of active
ingredient in the product, for example products with 67% methyl bromide and 33% chloropicrin,
methyl bromide has the larger buffer zone.
36
-------
Table 2. Tarp Bedded and Broadcast Buffer Zone Distances (feet)
Block
Size
(acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib ai acre)
35
25
25
25
25
25
25
35
50
SO
75
52,5
25
25
25
35
35
50
50
75
100
175
70
25
25
50
50
70
100
150
200
275
400
87.5
25
25
75
125
200
275
350
400
500
700
105
25
50
100
250
350
425
500
600
750
1050
122.5
50
75
175
350
475
600
700
SOO
1000
1375
140
75
125
250
450
600
750
900
1050
1250
1675
157.5
100
175
350
550
750
900
1100
1225
1475
2050
175
125
225
400
650
900
1050
1250
1450
1775
2375
192.5
135
275
450
750
1000
1200
1425
1625
2175
2775
210
150
300
550
850
1100
1400
1575
1825
2325
3150
245
175
375
650
1025
1400
1675
1975
2275
2775
3725
262.5
225
450
700
1150
1500
1775
2175
2375
2950
4000
280
250
475
750
1225
1575
1975
2375
2575
3150
4350
315
275
550
900
1375
1825
2250
2675
2950
3750
P
350
325
625
1000
1575
2075
2500
2950
3350
4150
P
Table 3. Tarp Bedded Buffer Zone Distances (feet) with 25% Increase
Block
Size
(acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib ai-'acre)
35
31
31
31
31
31
31
44
63
63
94
52.5
31
31
31
44
44
63
63
94
125
219
70
31
31
63
63
88
125
188
250
344
500
87.5
31
31
94
156
250
344
438
500
62.5
875
105
31
63
125
313
43 S
531
625
750
938
1313
122,5
63
94
219
438
594
750
875
1000
1250
1718
140
94
156
313
563
750
938
1125
1313
1563
2094
157.5
125
219
438
688
938
1125
1375
1531
1844
2563
175
157
281
500
813
1125
1313
1563
1813
2219
2968
192.5
169
344
563
938
1250
1500
1781
2031
2719
3469
210
188
375
688
1063
1375
1750
1969
2281
2906
3938
245
219
469
813
1281
1750
2094
2469
2844
3469
4656
262.5
281
562.5
875
1438
1875
2219
2719
2969
3688
5000
280
313
594
938
1531
1969
2469
2969
3219
3938
P
315
344
388
1125
1719
2281
2813
3344
3688
4688
P
350
406
781
1250
1969
2594
3125
3688
4188
5188
P
The 25 percent increase is only for tarped bedded applications that occur between 1 hour before
sunset and 1 hour after sunrise.
Table 4. Untarp Bedded Buffer Zone Distances (feet)
Block
Size
(acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib ai acre)
17.5
25
25
25
25
25
25
25
35
50
50
26.25
25
25
25
35
50
75
125
175
250
350
35
25
25
50
125
200
300
350
400
500
650
43.75
25
50
ISO
275
350
450
550
650
775
1025
52.5
50
100
200
375
550
650
725
825
1000
1400
61.25
100
175
300
500
675
800
925
1025
1225
1650
70
125
225
375
600
800
975
1100
1250
1475
2000
78.72
150
275
450
725
925
1100
1275
1475
1775
2375
87.5
175
325
550
825
1050
1275
1475
1675
2025
2575
96.25
175
375
600
925
1175
1425
1625
1875
2475
2950
105
200
400
650
1000
1300
1575
1775
2000
2550
3200
122.5
250
500
750
1175
1475
1775
2075
2375
2800
3750
131.3
275
525
825
1225
1625
1975
2225
2575
2900
3975
140
300
575
875
1350
1700
2175
2375
2775
3200
4350
157.5
325
625
1000
1475
1925
2350
2750
3075
3750
4725
175
350
700
1100
1650
2175
2550
3000
3550
4350
P
37
-------
Table 5. Untarp Broadcast Buffer Zone Distances (feet)
Block
Size
(acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib ai.-acre)
17.5
25
25
25
25
25
35
50
50
75
125
26.15
25
25
25
50
125
250
275
350
450
600
35
25
50
75
250
400
500
600
700
900
1200
43,75
50
75
250
450
625
800
900
1050
1275
1775
52.5
100
175
350
625
850
1025
1225
1400
1775
2375
61.25
150
275
450
800
1100
1275
1575
1775
2150
2950
70
175
350
600
975
1250
1575
1825
2075
2600
3350
78.75
200
400
700
1125
1475
1775
2100
2375
2950
3950
87.5
225
475
800
1250
1625
1975
2375
2550
3275
4350
96.25
275
550
900
1375
1825
2250
2575
2950
3575
P
105
300
600
950
1500
1975
2400
2850
3200
3950
P
122.5
350
700
1125
1775
2375
2850
3300
3800
P
P
131.3
375
750
1200
1875
2550
3050
3550
4175
P
P
140
400
800
1300
1975
2600
3225
3950
4350
P
P
157.5
450
900
1450
2225
2950
3750
4350
P
P
P
175
500
1000
1575
2575
3400
4325
P
P
P
P
Table 6, Untarp Broadcast Deep Buffer Zone Distances (feet)
Block
Size
(acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib ai'acre)
35
25
50
75
250
400
500
600
700
900
1200
52.5
90
175
350
625
850
1025
1225
1400
1775
2375
70
175
350
600
975
1250
1575
1825
2075
2600
3350
S7.5
225
475
800
1250
1625
1975
2375
2550
3275
4350
105
300
600
950
1500
1975
2400
2850
3200
3950
P
122.5
350
700
1125
1775
2375
2850
3300
3800
P
P
140
400
SOO
1300
1975
2600
3225
3950
4350
P
P
157.5
450
900
1450
2225
2950
3750
4350
P
P
P
175
500
1000
1575
2575
3400
4325
P
P
P
P
1.02.5
525
1050
1675
2775
3650
4500
P
P
P
P
210
600
1200
1875
2950
3800
P
P
P
P
P
245
700
1400
2200
3550
4350
P
P
P
P
P
262.5
750
1475
2350
3750
4575
P
P
P
P
P
280
800
1575
2550
4000
4725
P
P
P
P
P
315
S78
1775
2800
P
P
P
P
P
P
P
350
975
1975
3150
P
P
P
P
P
P
P
Table 7, Drip Irrigation Tarped Buffer Zone Distances (feet)
Block
Size
(acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib ai.-acre)
30
25
25
25
25
25
25
25
25
25
25
45
25
25
25
25
25
25
25
25
25
25
60
25
25
25
25
25
25
25
25
25
25
75
25
25
25
25
25
25
25
25
25
25
.90
25
25
25
25
25
25
25
25
25
25
105
25
25
25
25
25
25
25
25
25
25
120
25
25
25
25
25
25
25
25
25
25
135
25
25
25
25
25
25
25
25
50
50
150
25
25
25
25
25
25
35
35
50
75
165
25
25
25
25
25
25
35
50
50
100
180
25
25
25
25
25
35
50
50
50
100
210
25
25
25
35
35
35
50
50
75
175
225
25
25
25
35
50
50
75
100
125
225
240
25
25
25
50
65
75
125
125
150
275
270
25
25
25
65
85
125
145
175
225
325
300
25
25
50
75
125
150
175
225
275
400
P = Prohibited
Distances greater than 1A> mile (2,640 feet) are listed in the above tables. However, these
38
-------
buffers are prohibited if buffer zone credits, as described later in this document, do not
result in a buffer that is /^ mile (2,640 feet) or less.
Table 8. Buffer Zones for Pre-Plant Greenhouse Tarped Soil Fumigations
Structure Size
Buffer Zone
S /3,uuu square teet
> 25,000 square feet and < 30,000 square feet
> 30,000 square feet and < 35,000 square feet
> 35 000 snuare feet and < 40 000 snuare feet
25 feet
50 feet
30,000 square teet and < 35,000 square teet
35,000 square feet and < 40,000 square feet
40,000 square feet and < 45,000 square feet
75 feet
100 feet
> 40,000 square feet and < 45,000 square feet
> 45,000 square feet and up to 50,000 square feet
115 feet
130 feet
The buffer zones distances were not based on the selection of a specific percentile or
distribution from the PERFUM modeling results. Rather, EPA used a weight of evidence
approach to set the buffers which included consideration of the hazard profile of chloropicrin,
information from incident reports in particular factors that led to the incident and the effects seen
in people who were exposed, monitoring data (e.g., actual concentration measured at ranges of
distances in studies), stakeholder comments, along with comprehensive analysis of results from
PERFUM modeling and consideration of results using other models (e.g., Industrial Source
Complex model7). The analysis of PERFUM results considered distances at various percentiles
of the whole field and maximum distance distributions, and predicted MOEs for various
distances. The risk assessment characterizes additional types of analysis that were performed.
The following characterizes the risks associated with the buffer zones distances listed in Tables
2, 3, 4, 5, 6, 7 and 8:
Buffer zone distances are based on a reversible endpoint.
The PERFUM model was modified since the Agency last released its risk assessment for
public comment. Version 2.1.4 now provides outputs that show air concentrations at
each of the modeled ring distances. The Agency has used this information to estimate the
MOEs at various distances for each of the five weather stations. The buffer zone
distances selected for agricultural field and greenhouse pre-plant soil fumigations
generally reach the target MOE of 1 at high percentiles (>90%).
Buffers are protective of more severe effects. The MOEs at high percentiles (99th) of the
whole field reach half of the target MOE. This MOE corresponds to the 0.15 ppm
concentration of chloropicrin that can cause irritation without leading to more serious
respiratory effects.
It was assumed that chloropicrin air concentrations inside homes and other occupied
structures are equal to outside concentrations. These structures could act as a barrier
which in some cases may reduce potential inside air concentrations. However, there is
insufficient data to quantify differences between indoor and outdoor concentrations.
The use of GAPs, FMPs, and other mitigation measures required by this decision will
contribute to an additional decrease in risk (see GAP section on page 59 and FMP section
on page 65).
Projected Buffer Zone Distances for Major Crops
7 http://www.epa.gov/scram001/dispersion alt.htm#isc3
39
-------
Table 9 shows the various buffer distances for the pre-plant soil uses assessed by the
Agency during Phase 5 of the reregi strati on process. It also shows the percentile for the whole
and maximum field distributions for each buffer distance, as well as the MOE at the 95th and 99th
percentile air concentration of PERFUM.
Chloropicrin's target MOE is 1, and the MOEs in the table range from 0.50 to 6.9.
Although the buffer zone distances do not always reach the target at the 95th percentile air
concentration in PERFUM, the distances do reach half of the target at the 99th percentile air
concentration. This concentration corresponds to minor, reversible irritation effects observed in
the human study. Please note that the MOEs in the table are estimations. This is because the
buffer zones do not correspond exactly to PERFUM model outputs. For example, the buffer for
forest seedlings in the southeast for 10 acres at 135 Ibs ai/A is 250 feet. The corresponding MOE
at the 95th percentile air concentration is based on a buffer zone of 230 feet, therefore this
number is an underestimation.
All of the whole field percentiles in Table 9 are above 90 percent, and the maximum
percentiles range from 50 to 99 percent. Similar to the MOEs, the whole and maximum
percentiles presented in Table 9 are estimations. This is because the typical rates presented do
not exactly correspond to the rates modeled. For example for forest seedlings in the southeast,
the typical rate is 135 Ibs ai/A. The closest rate modeled is 140 Ibs ai/A. As a result the whole
and maximum field percentiles correspond to a rate of 140 Ibs ai/A, and not 135 Ibs ai/A.
Therefore 90% whole field and 55% maximum field are underestimations. That is, if the actual
rate is lower than the modeled rate, actual percentiles would be higher and the risk would be
lower.
o Example
Table 9 shows the corresponding maximum and whole field distribution for each buffer
zone based on an MOE of 1, as well as the MOE from the air concentration outputs from
PERFUM at the 95th percentile and 99th percentile.
Focusing on peppers as an example, the buffer zone for a 10 acre plot in California or
Michigan at a rate of 100 Ibs ai/A is 100 feet.
At 100 feet, the PERFUM model predicts the 90th percentile for the whole field
distribution and the 55th percentile for the maximum field distribution. The risk level
corresponding to this buffer zone distance at the 90th percentile whole field distribution is
equivalent to saying a person at any location on the perimeter of the buffer zone during the 24
hour period following the fumigation of a specific field during a 5-year period would have at
least a 90 percent chance of having of an exposure below the level of concern (i.e., MOE of lor
higher). The risk level corresponding to the buffer zone distances at the 55th percentile
maximum distribution is equivalent to saying a person at the location on the perimeter of the
buffer zone where the maximum concentration occurs during the worst case 24 hour period
following the fumigation of a specific field during a 5-year period would have a 55 percent
chance of having of an exposure below the level of concern (i.e., MOE of 1 or higher).
40
-------
Using the PERFUM model outputs of air concentrations to predict MOEs at the 95th and
99th percentile, at 100 feet for these application parameters, the MOE at the 95th percentile is
about 0.9 which is not significantly below the target MOE of 1. Also at the 99th percentile the
MOE is above 0.50.
41
-------
Table 9. Projected Buffer Zone Distances for Crops with Significant Chloropicrin Usage
Crop
Cucurbits
Carrot
Eggplant
Forest
Seedling
Onion
Orchard
Replant-
Grape &Nut
Orchard
Replant-
Pome
Orchard
Replant-
Stone
Pepper
Strawberry
Strawberry
Nursery
Sweet Potato
Tobacco
Tomato
Region
CA&
Southeast
Michigan
CA
CA&
Southeast
Southeast
West
Oregon
Washington
CA
Pacific NW
CA
Pacific NW
CA&MI
Southeast
CA
FL
CA&
Southeast
Texas
All States
CA&FL
Ml
Application
Method
Tarp
Broadcast/Bed
Tarp
Broadcast/Bed
Bed
Tarp Bed
Tarp Broadcast
Tarp Broadcast
Bed
Compaction
Bed
Compaction
Deep Bed
Compaction
Deep Bed
Compaction
Tarp Bed
(Deep)
Deep Bed
Compaction
Tarp Bed
Tarp Bed
Tarp Bed
Tarp Bed
Tarp Broadcast
Tarp Bed
Tarp Bed
Tarp Bed
Tarp Bed
Rate
(Ib
ai/A)
50
70
18
75
135
116
34
22
12
50
43
68
100
75
117
143
200
10
80
133
114
Block
Size
(acres)
10
40
10
40
80
10
40
10
20
10
20
40
40
20
30
5
20
30
5
10
40
10
40
10
20
10
20
10
40
10
40
10
40
10
40
10
40
Buffer Zone
(ft) Distances
without
credits
25
50
50
100
50
75
275
250
450
175
350
300
100
25
25
100
35
35
225
100
425
75
275
175
350
350
550
550
1400
25
25
75
275
250
750
175
600
Whole and
Maximum Field
Percentiles
(MOE=1)
Whole
95
90
95
90
90
95
95
90
90
90
90
90
97
97
95
90
99
99
90
90
90
95
95
90
90
95
90
95
95
99
99
90
90
90
90
90
90
Max
75
55
75
55
65
75
70
55
55
50
55
50
80
85
75
50
97
90
50
55
55
70
70
50
55
60
55
65
65
99
99
60
55
55
55
50
55
MOE at 95th and
99th Percentile of
PERFUM 2
95th
1.4
1
1.1
0.8
0.9
1
1
0.9
1
0.9
1
0.9
0.9
1.8
1.6
0.9
1.3
1.2
0.9
0.9
0.9
1.1
1
0.9
0.9
1.1
1
1
1.1
6.9
4.5
1
0.9
0.9
1
1
1
99th
0.9
0.6
0.7
0.5
0.6
0.7
0.6
0.5
0.6
0.5
0.6
0.5
0.6
1.3
1.1
0.5
0.9
0.8
0.5
0.5
0.5
0.7
0.6
0.5
0.5
0.6
0.5
0.5
0.5
4.7
3.1
0.6
0.6
0.5
0.5
0.5
0.5
42
-------
The Agency believes that the buffer zone distances described above, combined with other
risk mitigation measures detailed herein, will provide protection against any unreasonable
adverse effects.
v. Buffer Zone Reduction Credits
The Agency has undertaken a significant effort to evaluate available empirical data,
modeling, and literature regarding the factors and control methods that may reduce emissions
from soil fumigants. For details on the Agency's analysis please see, "Factors Which Impact Soil
Fumigant Emissions - Evaluation for Use In Soil Fumigant Buffer Zone Credit Factor
Approach,"8 in the chloropicrin docket. The Agency has also coordinated and led forums to
discuss this issue at the 2006 and 2007 Methyl Bromide Alternatives Outreach (MBAO)
Conferences with leading researchers and other stakeholders. A general description of the
MBAO sessions can be found at http://mbao.org.
Based on the Agency's analysis of the current data, the Agency has developed
chloropicrin buffer zone reduction credits for: high barrier tarps (40%), high barrier tarps used in
combination with the Symmetry application system (50%), potassium thiosulfate (KTS)
applied over tarped fields (5%), soils with high organic matter (10%), and soils with high clay
content (10%). The chloropicrin buffer zone credits are additive, but the total credit cannot
exceed 50 percent. To take advantage of the credits for high barrier tarps, Symmetry, and
KTS, users can modify their current application practices. Organic matter and clay content are
difficult to change and this credit may only be applicable for areas where these characteristics
already exist. Changing current practices or site conditions to utilize these credits comes with a
cost, but the Agency believes that in addition to reducing bystander risk and the size of buffer
zones, the credits for high barrier tarps, Symmetry application system, and KTS have the
potential to increase efficacy. Also the use of high barrier tarps could reduce application rates.
High Barrier Tarps
EPA has determined that a 40% buffer credit for chloropicrin is appropriate for the
following high barrier tarps: Bromostopฎ (1.38 mil), IPM Clear VIF (1.38 mil), Eval/Mitsui
(1.38 mil), Hytiblock 7 Black (0.00125"), XL Black Blockade (0.00125"), and Hytibar (1.5 mil).
This credit is based on several field studies detailed in the Agency's factors document.8 The
field studies include work by Dr. Husein Ajwa from the University of California Davis,9
researchers from the United States Department of Agriculture's Agricultural Research Service
(USDA-ARS) and the University of California, Riverside,10 and studies sponsored by Arysta
Life Sciences North America Corporation.11'12 In addition, laboratory studies completed by
Factors Which Impact Soil Fumigant Emissions - Evaluation for Use in Soil Fumigant Buffer Zone Credit Factor
Approach, June 9, 2008, DP Barcode: 306857
9 Ajwa, H. Fumigant emission Reductions by using Low Permeability Film and Thiosulfate Water Seal. 2007
Methyl Bromide Alternatives Outreach Conference. http://mbao.org/2007/PDF/Preplant/PPl/Ajwa(6).pdf.
10 Papiernik, S., et al. (2004) Effect of Surface Tarp on Emissions and Distribution of Drip Applied Fumigants.
Environmental Science Technology. 38, 4254-4262.
11 EPA MPJD 472952-03 Baker, F.; Arndt, T. (2007) Direct and Indirect Flux Determination of lodomethane and
Chloropicrin Under Field Conditions Following Tarped/Raised Bed/Shallow Shank Injection of Midas 50:50 in
43
-------
Ajwa which are also described in the Agency's factors document, were used to support the
credit.13 The Agency believes that the actual percent of emission reduction could be higher, but
that a 40% credit is appropriate based on uncertainties in the available data. Other high barrier
tarps could qualify for credits if supporting data are provided to the Agency.
The use of high barrier tarps may not be feasible or applicable to all situations where
chloropicrin is currently used. For example, growers using broadcast applications have reported
that high barrier tarps are difficult to use because of problems with gluing or bonding the edges
of the tarps together. Researchers and other stakeholders are reportedly exploring alternate
methods to accomplish this task (e.g., using propane gas to weld the tarps together).
Tarp emission reduction data reviewed by EPA show that tarps have varying degrees of
effectiveness. There is no current standard to evaluate tarps, and in the absence of a standard,
EPA has established conservative buffer reduction factors based on available data. EPA
requested assistance from USDA's Agricultural Research Service (ARS) in this effort to identify
those tarps that have demonstrated low permeability and reduced emissions under field
conditions.14 USDA's research includes a hybrid field-lab performance test where tarps are
stretched out over beds, subjected to atmospheric and soil conditions, and then tested in the lab.
The Agency believes that this approach to evaluating the permeability of agricultural tarps could
simulate more realistic field conditions, and EPA requested the results of tarp permeability
testing currently being conducted in support of USDA's Area-wide Pest Management Projects
for both the Pacific Region and the South Atlantic Regions.
In a response to EPA's request, USDA indicated that at least several months are needed
for external peer review, and that it was not able to provide the data in a timeframe useful for
EPA's current decisions.15 USDA did offer to provide samples of tarps taken from its ARS
experiments for testing in EPA laboratories. EPA is pursuing the feasibility of this option.
EPA plans to work with USDA, registrants, and other stakeholders to develop a protocol
for measuring the performance of tarp materials (i.e., using the mass transfer coefficient for each
fumigant) and performance criteria that could be used to evaluate additional tarps to derive
emission credits. Although there are several protocols being evaluated, there is no consensus on a
method. The Agency's factors document8 discusses methods that could be employed. Guidelines
for conducting flux studies in the field to use as point of comparison to performance testing are
already well established.
Bainbridge, GA. Project Number: 1619W, 1619W/1. Unpublished study prepared by PTRL West, Inc, Paragon
Research Services, Pacific Ag Group. 590 p. [Black Hytiblock]
12 EPA MRID 472952-04; Baker, F.; Arndt, T. (2007) Direct and Indirect Flux Determination of lodomethane and
Chloropicrin Under Field Conditions Following Tarped/Raised Bed/Shallow Shank Injection of Midas 50:50 in Hart
Michigan. Project Number: 1646W, 1646W/1. Unpublished study prepared by PTRL West, Inc, Paragon Research
Services, Pacific Ag Group. 590 p. [Black Blockade]
13 Ajwa, H., A. 2007. Testing Film Permeability to Fumigants Under Laboratory and Field Conditions. 2007 Methyl
Bromide Alternatives Outreach Conference. http://mbao.Org/2007/PDF/Preplant/PP3/Ajwa(16).pdf
14 EPA-HQ-OPP-2007-0350-0161. USDA's Agricultural Film Testing
15 EPA-HQ-OPP-2007-0350-0162. USDA Letter to Pete Caulkins on Agricultural Film Testing.
44
-------
EPA (through OPP's Environmental Stewardship Branch) has proposed to co-fund a
grant with USDA-ARS for several flux studies in the southeastern U.S. These studies would
provide (1) field data on the emission reduction potential of certain low permeability barrier
films to support possible, additional, buffer reduction credits as well as to (2) help develop an
affordable and reliable hybrid field-lab test to evaluate the many barrier films available to
growers. EPA has also prepared a document to describe possible research and study designs to
reduce uncertainties in understanding emission factors in the context of different films and seals,
agricultural practices, and environmental conditions.16 During the 60-day comment period the
Agency anticipates learning more about ongoing and planned research from the scientific
community that will address these uncertainties to help the Agency identify potential studies that
would help refine the current risk-based mitigation decisions. The EPA will defer decisions
regarding calling-in any data to address uncertainties identified with regard to these and other
factors until comments provided during the 60-day comment period have been reviewed.
TM
High Barrier Tarps with Symmetry Application System
TM
The Agency has determined that a 50% credit is appropriate when the Symmetry
application system is used with approved high barrier tarps (which currently includes only the
tarps listed above) and the application rate is less than 100 Ibs ai/A. The high barrier tarps
receive a 40% credit and Symmetry receives a 10% credit. This credit is based on studies
sponsored by Arysta Life Sciences North America Corporation.11'12 Due to limited information
regarding how the application system reduces emissions without high barrier tarps or at higher
application rates, the Agency believes the credit, while conservative, is appropriate.
Potassium Thiosulfate (KTS) and Tarps
EPA has determined that a 5% credit is appropriate for applications of potassium
thiosulfate. A field study conducted by Dr. Husein Ajwa9 indicates reductions in chloropicrin
emissions when KTS is applied to the top of tarps after the fumigation. If KTS is used in
conjunction with one of the approved high barrier tarps, the buffer zone can be reduced by 45%.
If KTS is used with any other tarp, the buffer zone reduction credit is 5%.
To receive the KTS credit, immediately following the fumigation, users must apply 25
gallons of KTS per acre with enough water to wet the soil to a depth of 10 mm by sprinkler.
Soil Conditions
Inherent soil conditions (e.g. organic matter and soil type) like high barrier tarps and KTS
do have an impact on fumigant emissions. However, soil conditions differ from the high barrier
tarp and KTS credits because soil conditions are factors that are essentially beyond a grower's
ability to change. Although a grower may not be able to manipulate organic matter or soil type,
the Agency's factors document indicates that soil conditions can reduce fumigant emissions, and
is offering credits for these conditions. EPA acknowledges that some variability in soil
characteristics within a given field is likely. If users are unsure whether the fields they intend to
Health Effects Division Recommendations for Fumigant Data Requirements. June 2008. DP Barcode 353724
45
-------
treat meet the criteria for a credit, they may consult with their local agriculture extension office
or soil conservation district for assistance in determining soil characteristics.
The Agency's factors document not only reviews available literature regarding soil
conditions, but also describes modeling exercises that estimate the impact of organic matter and
soil type using the Chain_2D model.8 Chain_2D is a first principles model that takes into
consideration factors such as boundary layers or moisture that could impact fumigant emissions.
The Agency used Chain_2D as modified by Dow AgroSciences' Steve Cryer and Ian van
Wesenbeek in the sensitivity analysis.17 Cryer and van Wesenbeek modified the original source
code to create a more usable graphical user interface, this included incorporating a new air/soil
boundary condition proposed by Wang in 1998.18 See the Agency's factors document for details
about the model.8
Based on the review of available literature and modeling with CHAIN_2D, EPA believes
a 10% buffer zone credit is appropriate if the application block contains soil with organic matter
of greater than or equal to 3%, and a 10% credit is appropriate if clay content is at least 27%.
The Agency's Chain_2D sensitivity analysis suggests that organic matter can have a
small impact on emissions. There is generally a high correlation between the organic matter
content of the soils and the dissociation constant (Kd) value. Increasing K d value by 10 or 25%
generally reduced emissions by 10 or 20% (figures 141-147 of the Agency's factors document8).
Generally, clay loam and sandy clay loam soils tended to show significantly lower
emissions than other soil types, sometimes showing 50% lower reductions. Conversely, loamy
sand and loam soils tended to show higher emissions than other soil types (figures 161-167 of the
Agency's factors document8).
Buffer Zone Credit Example
The Agency's analysis of the available data indicate that credits for high barrier tarps, the
Symmetry application system with high barrier tarps, KTS used with tarps, organic matter and
soil type are appropriate for chloropicrin. Below is an example of how the credits could be
applied.
Focusing on peppers again as an example, the buffer zone for a 10 acre plot in California
or Michigan at a rate of 100 Ibs ai/A is 100 feet without credits. If the grower uses Bromostopฎ
(1.38 mil) high barrier tarp, the buffer zone can be reduced by 40 percent. The resulting buffer
for this example is 60 feet. If KTS is used in conjunction with the Bromostopฎ (1.38 mil) high
barrier tarp the resulting buffer would be 55 feet.
17 Cryer, S.A. (2007) Air/Soil Boundary Conditions For Coupling Soil Physics and Air Dispersion Modeling.
Unpublished report of Dow AgroSciences LLC (Report # DN241493)
18 Wang, D; Yates, S.R.; Jury, W.A. (1998) Temperature Effect on Methyl Bromide Volatilization: Permeability of
Plastic Cover Films. J. Environ. Qual. 27, 821-827.
46
-------
Other Buffer Zone Credits Considered
Other factors such as soil moisture content, field preparation, water sealing, and
application injection depth could not be used to justify credits based on the available data.
However, EPA has established mandatory good agricultural practices (GAPs) for these
conditions. See the GAP section on page 59 of this document for further discussion.
The Agency has used the best available data to estimate potential chloropicrin bystander
risks and has both quantitatively and qualitatively evaluated the impact of potential emission
control measures on bystander risk. The Agency recognizes that there is substantial research
being conducted by stakeholders to further quantify emission reductions, and will consider such
data in future decisions if new data becomes available. Such data may also support the Agency's
decisions on additional emission credits in the future.
vi. Buffer Zone Impacts
EPA acknowledges that even with the use of credits, there could be significant economic
impacts to some growers who may not be able to accommodate large buffers based on their
current application practices. As part of the most recent public comment period on fumigant risk
assessments and proposed mitigation, several stakeholders submitted analyses estimating the
impact of buffer zones around fumigated agricultural fields. The Agency's review of these
studies and discussion of an EPA contracted study using the same approach for Kern County,
California is included in the docket.19 While buffers may restrict certain application practices,
this decision allows growers the flexibility to modify their practices to achieve smaller buffers;
for example treat smaller application blocks, or switch to a lower emission application method.
Available data indicate that for some crops and regions, pest control efficacy may be improved
with high barrier tarps that may enable growers to use the buffer zone credits and utilize lower
application rates, resulting in further reductions of the buffer zone distances. Some growers in
the southeast are commonly using high barrier tarps and lower rates at present.
The Agency has also looked at how buffer zones have impacted California practices19.
Buffer zones are currently required in California for methyl bromide pre-plant soil fumigations.
While there is no required buffer zone for chloropicrin in California, some counties require the
methyl bromide buffer zones for chloropicrin, other counties have larger restrictions, and still
some counties have no buffer zone requirements. The Agency's document explains how
California strawberry growers have modified their fumigation practices as a result of the buffer
zones, and also the impact of these changes.
b. Posting
Posting is recognized as an effective means of informing workers and others about areas
where certain hazards and restrictions exist. Current soil fumigant labels require treated areas to
19 Review of Stakeholder Submitted Impact Assessments of Proposed Fumigant Buffers, Comments on Initial Buffer
Zone Proposal, and Case Studies of the Impact of a Flexible Buffer System for Managing By-Stander Risks of
Fumigants. June 25, 2008. (DP Barcode 353940)
47
-------
be posted, and handlers are required to wear specific PPE when they are in a treated area. For
buffer zones to be effective risk mitigation, bystanders, including agricultural workers in nearby
areas, need to be informed of the location and timing of the buffer to ensure they do not enter
areas designated as part of the buffer zone.
i. Posting Requirements
In addition to alerting bystanders, posting a buffer zone will help handlers determine
where and when they are required to use PPE. As described below, handlers working in buffers
during the buffer zone period must use label-specified PPE and meet other requirements under
the WPS. Therefore, EPA has determined that to ensure the protectiveness of buffers for
bystanders and handlers, the perimeter of the fumigant buffer zones must be posted as described
below and in the example that follows.
Posting of a buffer zone is required except when one of the following conditions exist:
(1) a physical barrier that is reasonably likely to prevent bystander access to the buffer
zone (e.g., a fence or wall) separates the edge of the buffer zone from bystander access.
OR
(2) the area within 300 feet of the edge of the buffer zone is controlled by the application
block owner/operator. That is, if land under someone else's control is within 300 feet
from the edge of the buffer zone, the buffer zone must be posted.
A buffer within 300 feet of an area that includes worker housing must be posted even if
the area is under the control of the land owner/operator.
Buffer zone posting signs must:
o Be placed at all usual points of entry and along likely routes of approach from areas
where people not under the land operator's control may approach the buffer zone.
o When there are no usual points of entry, be posted in the corners of the buffer zone,
between the corners of the buffer zone, and along sides so that one sign can be
viewed (not read) from the previous one. Some examples of points of entry include,
but are not limited to, roadways, sidewalks, paths, and bike trails.
Buffer zone posted signs must meet the following criteria:
o The printed side of the sign must face away from the treated area toward areas from
which people could approach.
o Signs must remain legible during entire posting period and must meet the general
standards outlined in the WPS for text size and legibility (see 40 CFR ง170.120).
o Signs must be posted before the application begins and remain posted until the buffer
zone period has expired.
o Signs must be removed within 3 days after the end of the buffer zone period.
o Registrants must provide generic buffer zone posting signs which meet the criteria
above at points of sale for applicators to use.
Exception: If multiple contiguous blocks are fumigated within a 14-day period, the entire
periphery of the contiguous blocks' buffer zones may be posted. The signs must remain posted
48
-------
until the last buffer zone period expires and signs may remain posted until 3-days after the buffer
zone period for the last block has expired.
Additional requirements for treated area posting:
The treated area posted signs must remain posted for no less than the duration of the entry
restricted period after treatment.
Treated area signs must be removed within 3 days after the end of the entry-restricted
period.
Signs must meet the general standards in the WPS for placement, text size, and location
(40CFRง170.120).
Contents of Signs
The treated area sign (currently required for
fumigants) must state the following:
~ Skull and crossbones symbol
- "DANGER/PELIGRO,"
~ "Area under fumigation, DO NOT
ENTER/NO ENTRE,"
~ "[Name offumigant] Fumigant in USE,"
~ the date and time of fumigation,
~ the date and time entry prohibition is lifted
~ Name of this product, and
~ name, address, and telephone number of the
certified applicator in charge of the fumigation.
The buffer zone sign must include the
following:
Do not walk sign
- "DO NOT ENTER/NO ENTRE,"
~ "[Name offumigant] Fumigant BUFFER
ZONE,"
~ the date and time of fumigation,
~ the date and time buffer zone restrictions are
lifted (i.e., buffer zone period expires)
~ Name and EPA registration number of the
product applied, and
~ name, address, and telephone number of the
certified applicator in charge of the fumigation
49
-------
To clarify the posting requirements, the following example has been included.
Figure 3. Posting Example
Buffer zone
100 ft
N
f
0
Treated field
100ft
350ft
Property
Operator's
Residence
Red Houses = Structure within 300 feet of the buffer zone edge. Yellow dots = posted signs
The structures in red are (1) within 300 feet of the edge of the buffer zone, and (2) there
is no physical barrier between the two structures and the buffer zone, and (3) the land
operator does not control these structures.
Although the property operator's building (striped building) is within 100 feet of the
edge of the buffer zone, since it is controlled by the property operator, no posting of the
buffer zone is necessary here.
There is a road within 100 feet of the edge of the buffer zone. Since there is a possibility
of people from the road entering the buffer zone area, the buffer zone needs to be posted
in the northwest corner.
Buffer Zone Posting Considerations
The Agency received comments on the burden for applicators to post the entire perimeter
of a buffer zone due to the large distance it covers. In an effort to reduce the burden on growers,
but retain the posting requirement for situations where people are most likely to enter a buffer
zone, EPA believes posting an area where people are most likely to enter buffers will be
protective. USDA also noted that as growers break their fields into smaller application blocks to
result in smaller buffer zones, the posting requirements would be burdensome in that users would
need to put up and take down signs for multiple adjacent, sequential applications. To address
this concern, EPA is allowing signs for contiguous application blocks to be placed on the edge of
the buffer zone area for all blocks treated within a 14-day period. EPA believes this will be
protective and potentially less burdensome.
50
-------
c. Use Prohibitions
The Agency does not have adequate data to evaluate the following application scenario:
untarped, drip, buried (a minimum of 5 inches). The CMTF has recently submitted a study to the
Agency. If data are acceptable and allow EPA to develop appropriate mitigation for this use
pattern, this use will be eligible for reregi strati on; otherwise it will be prohibited.
2. Occupational Mitigation
a. Handler Definition
Based on stakeholder comments, a clarification of EPA's definition of handler activities,
as currently defined in the WPS and fumigant labels, is needed. Persons engaged in any of the
following activities will be defined as handlers on product labels.
Persons participating in the application as supervisors, loaders, drivers, co-pilots, shovelers,
or as other direct application participants;
Persons taking air samples to monitor fumigant air concentrations;
Persons cleaning up fumigant spills;
Persons handling or disposing of fumigant containers;
Persons cleaning, handling, adjusting, or repairing the parts of fumigation equipment that
may contain fumigant residues;
Persons installing, repairing, operating irrigation equipment in the fumigant application block
or surrounding buffer zone during the buffer zone period;
Persons entering the application site or surrounding buffer zone during the buffer zone period
to perform scouting or crop advising tasks;
Persons installing, perforating (cutting, punching, slicing, poking), removing, repairing, or
monitoring tarps - until
o After tarps are perforated and removed if tarp removal is completed less than 14 days
after application, or
o 14 days after application is complete if tarps are not perforated and removed during
those 14 days, or
o 48 hours after tarps are perforated if they will not be removed prior to planting.
b. Handler Requirements
Currently all handlers involved in a chloropicrin application must be under the
supervision of a certified applicator who may not necessarily be on-site. Since many incidents
are caused by human error and equipment failure, EPA believes the presence of onsite trained
personnel will help to reduce these risks. Therefore, a certified applicator must maintain visual
contact with any fumigant handler while the fumigant is being incorporated into the soil. The
person monitoring other handlers may also be engaged in fumigant handling tasks during the
monitoring period and two qualified monitors may monitor one another simultaneously.
51
-------
Before applying this product, the certified applicator supervising that application must
have, within the preceding 12 months, successfully completed a chloropicrin training program
made available by the registrant (see Soil Fumigation Training for Applicators and Other
Handlers section on page 74). The FMP as described on page 65 must document when and
where the training program was completed.
For cases when the certified applicator leaves the site after the application portion of the
fumigation process is complete and other parties will be performing handler tasks (e.g., tarp
perforation/removal, water application, etc.), the certified applicator must communicate in
writing to the site owner/operator and other handlers key information needed to comply with
label requirements (e.g. PPE requirements, location of buffers, when buffer zone ends, reentry
restrictions, minimum times for perforating tarps, etc.).
When handlers are fixing tarps, moving irrigation equipment or performing other
handling tasks as defined above, the Agency is requiring at least two WPS trained handlers be
present for all activities. Due to the volatile nature of the fumigants there is a possibility that
handlers could be overcome with the vapors and have difficulty leaving the area while they are
performing handling tasks. Therefore, EPA is requiring at least two WPS trained handlers be on
site during all post-fumigation handling activities.
c. Respiratory Protection
The Agency's risk assessment indicates that inhalation risks exceed the Agency's level of
concern for many handler activities. The human study indicates that the eye and nose irritation
associated with acute chloropicrin exposure do not carryover, and therefore the Agency is most
concerned about protecting handlers and workers from acute inhalation exposure. Taking into
account the risks identified in addition to stakeholder comments, the Agency has developed the
respiratory protection scheme below. In addition to the respiratory protection requirements, the
Agency believes that GAPs, FMPs, and other mitigation measures will reduce inhalation risks to
levels below the EPA's level of concern.
During the most recent public comment period, the Agency received comments from
fumigant applicators that respirators are not necessary because (1) chloropicrin's warning
properties are sufficient to alert handlers if there has been an unsafe exposure, (2) respirators
inhibit communication which could cause an accident; and (3) in warm weather respirators can
cause heat stress and other ailments. On the other hand, some stakeholders are in favor of
mandatory respiratory protection because they believe if fumigants are continued to be used that
respirators are the only effective means to protect workers from chloropicrin exposures. These
stakeholders have also stated that handlers will not be given access to respirators and other PPE
unless it is required on the label.
Current chloropicrin labels state that the acceptable air concentration is 0.1 ppm, and
require air-purifying respirators when the air concentration of chloropicrin exceeds 0.1 ppm, and
SCBA when the air concentration exceeds 4 ppm. The labels, however, do not require
52
-------
monitoring. The 4 ppm level was the old IDLH (immediately dangerous to life and health) level.
20
This level has since been revised to 2 ppm/
i. Respiratory Requirements
The following air monitoring procedures must be followed for all agricultural field and
greenhouse pre-plant soil applications of chloropicrin. When chloropicrin is used in combination
with other fumigants like methyl bromide, iodomethane, and 1,3-D, the mitigation may differ
due to the different risks of the other fumigant. According to Agency policy, the most stringent
mitigation must be followed.
Air monitoring samples for chloropicrin must be collected at least every 2 hours in the
breathing zone of a handler performing a representative handling task.
If at any time: (1) chloropicrin concentrations are greater than or equal to 0.15 ppm, or
(2) any handler experiences sensory irritation, then an air-purifying respirator must be
worn by all handlers at the handling site.
If two consecutive breathing zone samples taken at least 30 minutes apart, show levels
have decreased to less than 0.15 ppm for chloropicrin, then handlers may remove the
respirators.
If at any time: (1) a handler experiences any sensory irritation when wearing a respirator,
or (2) any air sample is greater than or equal to 1.5 ppm for chloropicrin, then all handler
activities must cease and handlers must be removed from the application block and
surrounding buffer zone until corrective action has been taken.
During the corrective actions if chloropicrin air concentrations are greater than or equal
to 1.5 ppm, a SCBA must be worn.
In order to resume work activities:
o Two consecutive air samples for chloropicrin taken at the handling site at least 30
minutes apart must be less than 1.5 ppm for chloropicrin.
o During the collection of air samples an air purifying respirator must be worn by
the handler taking air samples.
o If chloropicrin concentrations are greater than or equal to 0.15 ppm, then handlers
resuming their handler activities must wear air-purifying respirator.
There are several commercial systems for monitoring chloropicrin air concentrations.
Chloropicrin colorimetric tubes are available from varied manufacturers including:
Matheson/Kitagawa, Sensidyne, and Draeger. The devices used to meet the monitoring
requirements in this decision must have sensitivity of at least 0.15 ppm for chloropicrin.
Respirator cartridges used with air-purifying respirators
Currently, there are no air-purifying respirator cartridges certified by the Mine Safety and
Health Administration-National Institute for Occupational Safety and Health (MSHA-NIOSH)
for protection against chloropicrin. NIOSH/OSHA does recommend respirators with organic
vapor cartridges for chloropicrin use. The EPA is requiring half-face respirators with organic-
'http://www.cdc.gov/Niosh/idlh/76062.html
53
-------
cartridges be used when a respirator is necessary. The EPA assumes that half-face respirators
have a protection factor of 10, therefore the respiratory protection will only be protective up to
chloropicrin concentrations of 1.5 ppm, and if measured concentrations exceed 1.5 ppm work
operations must cease. A self-contained breathing apparatus (SCBA) has a protection factor of
1,000, but must only be used for brief durations to take actions to reduce air concentration levels
or in case of an emergency. As a result the new IDLH of 2 ppm will not be a trigger to put on
SCBA. Respirator APR-cartridge combinations from other manufacturers will also be
considered by the Agency, provided written certification of their efficiency against chloropicrin
is provided.
Tarp Repair
An air purifying respirator must be worn by handlers performing tarp repair operations
before the entry prohibitions have ended. The Agency is requiring respiratory protection during
tarp repair since the duration of the activity is likely to be short and because chloropicrin
concentrations are unknown, but could be high, especially if the tarp repair occurs shortly after
the fumigation is completed.
Respirator fit testing, medical qualification, and training
The respirator protection factors described above are based on the following assumptions:
1) the respirator is fit-tested, 2) proper respirator training occurs, and 3) an annual medical
evaluation and clearance is done. Without these requirements, it is unclear whether the reduction
in inhalation exposure that is assumed by the protection factor will be achieved. In order to
ensure that the respiratory protection EPA is assuming is being achieved in the field, respiratory
requirements will include fit testing, respirator training, and annual medical evaluation. The
following language must be added to product labels:
"Employers must also ensure that all handlers are:
Fit-tested and fit-checked using a program that conforms to OSHA's requirements (see
29CFR Part 1910.134)
Trained using a program that confirms to OSHA's requirements (see 29CFRPart 1910.134)
Examined by a qualified medical practitioner to ensure physical ability to safely wear the
style of respirator to be worn. A qualified medical practitioner is a physician or other
licensed health care professional (PLHCP) who will evaluate the ability of a worker to wear a
respirator. The initial evaluation consists of a questionnaire that asks about medical
conditions (such as a heart condition) that would be problematic for respirator use. If
concerns are identified, then additional evaluations, such as a physical exam, might be
necessary. The initial evaluation must be done before respirator use begins. It does not need
to be repeated unless the health status or respirator use conditions change."
Respirator availability
The handler employer must confirm and document in the FMP that the following are
immediately available:
at least one air rescue device (e.g., SCBA) on-site in case of an emergency, and
54
-------
air-purifying respirators and cartridges for each handler.
d. Tarp Perforation and Removal
The Agency's risk assessment indicates that there is a risk concern for handlers during
the perforation (cutting, poking, punching, or slicing) and removal of tarps, particularly when
high barrier tarps are used. In addition to respiratory protection requirements described in the
Respiratory Requirements section on page 53, the Agency is requiring the following to mitigate
risks from inhalation exposure:
Tarps cannot be perforated until a minimum of 5 days (120 hours) have elapsed after the
fumigant injection into the soil is complete (e.g., after shank injection of the fumigant
product and tarps (if used) have been laid or after drip lines have been purged and tarps
have been laid, unless an adverse weather condition exists for broadcast applications).
If tarps will be removed after perforation, tarp removal cannot begin until at least 24
hours after tarp perforation is complete.
If tarps will not be removed after perforation, planting or transplanting cannot begin until
at least 48 hours after tarp perforation is complete.
If tarps are left intact for at least 14 days after fumigation injection into the soil is
complete, planting or transplanting may occur while the tarps are being perforated.
Adverse Weather Conditions Exemption for Broadcast Applications Only, see Figure 8:
Tarps may be removed before the required 5 days (120 hours) if adverse conditions will
compromise the integrity of the tarp, provided that:
o At least 48 hours have passed after the fumigant injection is complete,
o The buffer zone period is extended until 24 hours after tarp removal is complete,
and
o Subsequent fumigations of untreated areas within the application block do not
occur for at least 24 hours after tarp removal is complete.
To reduce exposure to handlers perforating tarps
o Tarps used for fumigations must be perforated only by mechanical methods.
o Perforation by hand or with hand-held tools is prohibited.
Each tarp panel used for broadcast fumigations must be perforated using a lengthwise cut.
This measure is to reduce the likelihood of the tarp blowing away prior to tarp removal.
e. Entry Prohibitions
Most of the current chloropicrin labels allow reentry to the treated field by workers 48
hours after application. When chloropicrin is used in combination with 1,3-D the labels permit
worker reentry into the treated field 5 days after application. The risk assessment indicates that
risks exceed EPA's LOG for workers entering fields after 48 hours. However, the risk
assessment indicates that extending this period decreases this risk. In addition, stakeholder
comments indicate that non-handler entry to perform post-application (i.e., non-handler) tasks is
generally not needed for at least 10 to 14 days following the completion of the application.
Due to the volatile nature of chloropicrin and the potential for worker exposure, the
Agency is prohibiting entry into the treated area by anyone other than a protected handler. The
55
-------
prohibition differs from a Restricted Entry Interval (REI), that are currently required for most
conventional pesticides, which contains exceptions for workers doing certain tasks before the
REI has expired (e.g., scouting). Workers permitted entry under the REI are prohibited for soil
fumigants.
EPA believes that risks will not exceed the Agency's LOG provided entry (including
early entry that would otherwise be permitted under the WPS) by any person - other than a
correctly trained and PPE-equipped handler who is performing a handling task - is prohibited
from the start of the application until:
5 days (120 hours) after application has ended for untarped applications, or
After tarps are perforated and removed if tarp removal is completed less than 14 days
after application, or
48 hours after tarps are perforated if they will not be removed prior to planting, or
5 days (120 hours) after application is complete if tarps are not perforated and removed
14 days after the application is complete.
Figures 4, 5, 6, 7, and 8 provide illustrations of tarp perforation/removal and entry prohibition
mitigation required for various chloropicrin applications. The intervals depicted are the
minimum that must be followed.
Figure 4. Untarp Bed or Broadcast Applications
5 days (120 hours)
56
-------
Figure 5. Tarps Removed Before Planting
5 days. (120 hours)
48 hours
Tarp Perforation
Begins
Tarp Perforation
Ends
J4 hours
Tarp Removal
Begins
-
Tarp Removal
Ends
Figure 6. Tarps NOT Removed Before Planting
48 hours
Tarp Perforation
Begins
Tarp Perforation
Ends
57
-------
Figure 7. Tarps NOT Removed Before Planting and NOT Perforated Until 14 days after the
application
Figure 8. Adverse Weather Condition Exemption (Broadcast applications only)
5 davs f 120 hoiirsl
Application
Begins
Buffer Zone
Period Begins
Entry
Prohibition
Begins
r- 1
, I
\ !
\ I
\ I
\ !
\ I
\ Application Buffer Zone
/Ends Penod Ends
Entry
Prohibition
Ends
48 hours Tarp Perforation
& Removal |
I
I
Tarp Removal is j
complete
58
-------
ii. Other Mitigation
Below are requirements for mandatory GAPs, FMPs, emergency preparedness and
response, and training and outreach that the Agency concludes are needed to mitigate risks and
the likelihood of incidents caused by human error, equipment failure, and weather events such as
temperature inversions.
1. Good Agricultural Practices (GAPs)
Since the application methods and work practices of the handlers have direct impact on
the amount of fumigant applied and emitted, the Agency believes that labeling should describe
proven practices that will reduce risks to handlers, bystanders, and the environment. Registrants,
applicators, growers, and other stakeholders have consistently reported to the Agency that GAPs
are the best mitigation measure to reduce the amount of fumigants applied and emitted.
The following GAPs must be followed during all fumigant applications. The registrants
have the option to develop additional optional GAPs to be listed on product labels. All
measurements and other documentation planned to ensure that the mandatory GAPs are achieved
must be recorded in the FMP and/or the post-application summary report.
Tarps (when tarps are used in chloropicrin applications)
A written tarp plan must be developed that includes:
o schedule and procedures for checking tarps for damage, tears, and other problems
o plans for determining when and how repairs to tarps will be made, and by whom
o minimum time following injection that tarp will be repaired
o minimum size of tarp damage that will be repaired
o other factors used to determine when tarp repair will be conducted:
schedule, equipment, and methods used to perforate tarps
aeration plans and procedures following perforation of tarp, but prior to tarp removal
or planting/transplanting
schedule, equipment, and procedures for tarp removal
The written tarp plan must be included in the site specific FMP as described in the FMP section
on page 65.
Weather Conditions
Prior to fumigation the weather forecast for the day of the application and the 48-hour period
following the fumigant application must be checked.
Do not apply fumigant if ground-level winds are less than 2 mph.
Applications must not occur during a temperature inversion or when temperature inversions
are forecasted to persist for more than 6 consecutive hours for the 36-hour period after
application.
o Visual features that could indicate an inversion is occurring are misty conditions
during day or night, and clear night skies.
59
-------
Detailed local forecasts for sky conditions, weather conditions, wind speed, and forecasted
temperature inversions may be obtained on-line at http://www.nws.noaa.gov.
For further guidance, contact the local National Weather Service Forecasting Office.
Soil Temperature
The maximum soil temperature at the depth of injection shall not exceed 90 degrees F at the
beginning of the application.
o If air temperatures have been above 100 degrees F for more than three hours in any of the
three days prior to application, then soil temperature shall be measured and recorded in
the FMP.
Soil Moisture
The soil must be moist two to six inches below the surface. The amount of moisture needed
in this zone will vary according to soil type and shall be determined using standard feel
testing methods (see below). Surface soil generally dries rapidly and must not be considered
in this determination.
If there is insufficient moisture two to six inches below the surface, the soil moisture must be
adjusted. If irrigation is not available and there is adequate soil moisture below six inches,
soil moisture can be brought to the surface by discing or plowing before injection. To
conserve existing soil moisture, pretreatment or treatment tillage should be done as close to
the time of application as possible.
Soil Moisture Determination
The soil shall contain at the time of application enough moisture two to six inches below the
surface to meet the following criteria as appropriate for the soil texture.
For fine textured soils (clay loam, silty clay loam, sandy clay, silty clay, sandy clay loam
and clay) there must be enough moisture so that the soil is pliable, not crumbly, but does not
form a ribbon when squeezed between the thumb and forefinger.
For coarse soils (sand and loamy sand) there must be enough moisture to allow formation of
a weak ball when compressed in the hand. Due to soil texture, this ball is easily broken with
little disturbance.
For medium textured soils (coarse sandy loam, sandy loam, and fine sandy loam) there
must be enough moisture to allow formation of a ball which holds together with moderate
disturbance, but does not stick between the thumb and forefinger.
For fields with more than one soil texture, soil moisture content in the lightest textured
(most sandy) areas must comply with this soil moisture requirement. Whenever possible, the
field should be divided into areas of similar soil texture and the soil moisture of each area
should be adjusted as needed. Coarser textured soils can be fumigated under conditions of
higher soil moisture than finer textured soils; however, if the soil moisture is too high,
fumigant movement will be retarded and effectiveness of the treatment will be reduced.
Previous and/or local experience with the soil to be treated or the crop to be planted can often
serve as a guide to conditions that will be acceptable. If there is uncertainty in determining
the soil moisture content of the area to be treated, local extension service or soil conservation
service specialist or pest control advisor (ag consultant) should be consulted for assistance.
Soil Preparation
60
-------
Soil shall be properly prepared and at the surface generally be free of clods that are golf ball
size or larger. The area to be fumigated shall be tilled to a depth of 5 to 8 inches.
Field trash must be properly managed. Residue from a previous crop must be worked into the
soil to allow for decomposition prior to fumigation. Little or no crop residue shall be present
on the soil surface. Crop residue that is present must not interfere with the soil seal.
Soil Sealing
For Broadcast Untarped Applications: Use a disc or similar equipment to uniformly mix the
soil to at least a depth of 3 to 4 inches to eliminate the chisel or plow traces. Following
elimination of the chisel trace, the soil surface must be compacted with a cultipacker, ring
roller, and roller in combination with tillage equipment.
For Bedded Applications: Performed beds shall be sealed by disruption of the chisel trace
using press sealers, bed shapers, cultipackers, or by re-shaping (relisting, lifting and
replacing, etc.) the beds immediately following injection. Beds formed at the time of
application shall be sealed by disrupting the chisel trace using press sealers, or bed shapers.
Soil Sealing for Tarped Applications: The use of a tarp does not eliminate the need to
minimize chisel traces prior to application of the tarp, such as by using a nobel plow or other
injection shank that disrupts the chisel traces.
Chloropicrin Bedded and Broadcast Shank Applications: Additional GAPs
In addition to the GAPs required for all chloropicrin soil fumigation applications, the following
GAPs apply for injection applications:
Tarps (when tarps are used in chloropicrin applications)
Tarps must be installed immediately after the fumigant is applied to the soil.
Soil Preparation
Trash pulled by the shanks to the ends of the field must be covered with tarp, or soil,
depending on the application method before making the turn for the next pass.
Application Depth
For Tarped-Broadcast and Tarped-BeddedApplications: The injection point shall be a
minimum of 8 inches from the nearest final soil/air interface.
For Untarped-BeddedApplications: The injection point shall be a minimum of 12 inches
from the nearest final soil/air interface.
For Untarped-Broadcast Applications: The injection point shall be a minimum of 10 inches
from the nearest final soil/air interface.
Prevention of End Row Spillage
Do not apply or allow fumigant to drain onto the soil surface. For each injection line either
have a check valve located as close as possible to the final injection point, or drain/purge the
line of any remaining fumigant prior to lifting injection shanks from the ground.
Do not lift injection shanks from the soil until the shut-off valve has been closed and the
fumigant has been depressurized (passively drained) or purged (actively forced out via air
compressor) from the system.
61
-------
Calibration, Set-up, Repair, and Maintenance for Application Rigs
Brass, carbon steel or stainless steel fittings must be used throughout. Polyethylene
tubing, polypropylene tubing, Teflonฎ tubing or Teflonฎ -lined steel braided tubing
must be used for all low pressure lines, drain lines, and compressed gas or air pressure
lines. All other tubing must be Teflonฎ -lined steel braided.
Galvanized, PVC, nylon or aluminum pipe fittings must not be used.
All rigs must include a filter to remove any particulates from the fumigant, and a check
valve to prevent backflow of the fumigant into the pressurizing cylinder or the
compressed air system.
Rigs must include a flowmeter or a constant pressure system with orifice plates to insure
the proper amount of fumigant is applied.
To prevent the backflow of fumigant into the compressed gas cylinder (e.g. nitrogen,
other inert gas or compressed air), if used, applicators must:
o Ensure that positive pressure is maintained in the cylinder at not less than 200 psi
during the entire time it is connected to the application rig, if a compressed gas
cylinder is used. {This is not required for a compressed air system that is part of
the application rig because if the compressor system fails the application rig will
not be operable}.
o Ensure that application rigs are equipped with properly functioning check valves
between the compressed gas cylinder or compressed air system and the fumigant
cylinder. The check valve is best placed on the outlet side of the pressure
regulator, and is oriented to only allow compressed gas to flow out of the cylinder
or compressed air out of the compressed air system.
o Always pressurize the system with compressed gas or by use of a compressed air
system before opening the fumigant cylinder valve.
Before using a fumigation rig for the first time, or when preparing it for use after storage,
the operator must check the following items carefully:
o Check the filter, and clean or replace the filter element as required.
o Check all tubes and chisels to make sure they are free of debris and obstructions.
o Check and clean the orifice plates and screen checks, if installed.
o Pressurize the system with compressed gas or compressed air, and check all
fittings, valves, and connections for leaks using soap solution.
Install the fumigant cylinder, and connect and secure all tubing. Slowly open the
compressed gas or compressed air valve, and increase the pressure to the desired level.
Slowly open the fumigant cylinder valve, always watching for leaks.
When the application is complete, close the fumigant cylinder valve and blow residual
fumigant out of the fumigant lines into the soil using compressed gas or compressed air.
At the end of the application, disconnect all fumigant cylinders from the application rig.
At the end of the season, seal all tubing openings with tape to prevent the entry of insects
and dirt.
Application equipment must be calibrated and all control systems must be working properly.
Proper calibration is essential for application equipment to deliver the correct amount of
fumigant uniformly to the soil. Refer to the manufacturer's instructions on how to calibrate your
62
-------
equipment, usually the equipment manufacturer, fumigant dealer, or Cooperative Extension
Service can provide assistance.
Chloropicrin Drip Applications: Additional GAPs
In addition to the GAPs required for all chloropicrin soil fumigation applications, the following
GAPs apply for drip applications:
Soil Preparation
Till fields with known plowpans because they can lead to puddling of the fumigant due to
inadequate soil drainage.
Product and Dosage
Plan the application by calculating the amount of fumigant required at the appropriate
rate for the crop, acreage and target pest. Fumigant must be metered into the water
supply line and then passed through a mixing device, such as a centrifugal pump or static
mixer, to assure proper agitation.
System Controls and Integrity
The irrigation system (main lines, headers, drip tape) must be thoroughly checked for
leaks before the start of application. Leak detection requires that the irrigation system be
at full operating pressure. The amount of time needed at full operating pressure will vary
by irrigation system design. Look for puddling along major pipes (holes in pipes or leaky
joints), at the top and ends of rows (leaky connection, open drip tape), and on the bed
surface (damaged drip tape, malfunctioning emitters). Any leaks discovered during the
pre-application check must be repaired prior to fumigant application.
To inject fumigant, use a metering system (such as a positive pressure system, positive
displacement injection pump, diaphragm pump, or a Venturi system) effectively designed
and constructed of materials that are compatible with the fumigant and capable of being
fitted with system interlocking controls. Do not use containers pumps or other equipment
made of aluminum, magnesium or their alloys as chloropicrin can be corrosive to such
metals.
The system must contain:
o A functional check valve and low-pressure drain appropriately located on the
irrigation pipeline to prevent water source contamination and backflow;
o A functional, automatic, quick-closing check valve to prevent the flow of fluids
back toward the fumigant container;
o A functional, normally closed valve located on the intake side of the injection
point and connected to the system interlock to prevent the fumigant from being
withdrawn from the supply tank when the irrigation system is either automatically
or manually shut down;
o Functional interlocking controls to automatically shut off the fumigant injection
when the irrigation water flow stops or decreases to the point where fumigant
distribution is adversely affected.
Site of Injection and Irrigation System Layout
63
-------
Site of injection must be as close as practical to the area being treated (such as direct
injection of fumigant into the header pipe/manifold or into an aboveground delivery pipe
attached to the header). If the fumigant is injected into a main line, make sure the
irrigation pipe is able to be cleared of all fumigant as the fumigant may pool in low
sections of the pipe. Also make sure that valves on lateral lines of the main line are
closed, if these lateral lines lead to areas not being fumigation at the time of the
application.
System Flush
After application of the fumigant, continue to drip-irrigate the area with water to flush the
irrigation system. Do not allow the fumigant to remain in the irrigation system after the
application is complete. The total volume of water, including the amount used for
flushing the irrigation system, must be adequate to completely remove the fumigant from
the lines, but should be less than the amount that could over-saturate the beds (bed
collapse can occur from over-saturation). If common lines are used for both the fumigant
application and water seal (if a water seal is applied) these lines must be adequately
flushed before starting the water seal and/or normal irrigation practices.
Soil Sealing
Tarps must be put in place before the fumigation begins.
Tarps must be used for drip applications.
o Based on the Agency's review of the recently submitted data for untarped drip
applications, this GAP may change.
Tarp edges must be buried along the furrow and at the ends of rows.
Chloropicrin Tree Replant Application: GAPs
This application method is used when chloropicrin is applied to individual tree sites in an
existing orchard where shank or drip application are not possible.
In addition to the GAPs required for all chloropicrin soil fumigation applications, the following
GAPs apply for chloropicrin tree replant applications:
Site Preparation
Each individual tree-site must remove the tree stump and primary root system with a
back-hoe or other similar equipment, for example an auger.
The hole must be backfilled with soil before application.
Application Depth
The fumigant must be injected at least 18 inches into the soil.
System Flush
Before removing the application wand from the soil the wand must be cleared using
nitrogen or compressed air.
Soil Sealing
64
-------
After the wand is cleared and removed from the soil, the injection hole must be either
covered with soil and tamp or the soil must be compacted over the injection hole.
2. Fumigant Management Plans (FMPs)
The Agency is requiring FMPs to be completed before a fumigant application occurs.
FMPs will reduce risks by requiring that applicators develop a series of performance criteria for
their given application situation. These criteria are intended to minimize risks according to the
Agency's guidance provided below. Applicators must then review those criteria before a
fumigation occurs. The FMPs will also require that applicators verify compliance with the
criteria after application events are completed. In cases where errors may have occurred, a post-
application summary may also prevent similar problems from occurring during future
applications. As an additional benefit, the Agency believes FMPs will ensure that directions on
the product labels have been followed and that the conditions for the fumigation are documented.
FMPs should aide in the proper response of the applicator or others involved in the
application should an incident occur. A proper and prompt response will reduce the potential
risk to bystanders from potential high exposure situations (e.g., readily available first responder
contact information could reduce response times to impacted bystanders and carefully thought
out emergency response plans can help ensure appropriate actions are taken in case of unforeseen
events).
There is information from various sources that health and safety plans, FMPs in this
context, typically reduce workplace injuries and accidents by prescribing a series of operational
requirements and criteria. In fact, these plans are widely implemented in a variety of industries
and are recommended as standard approaches for occupational health and safety management by
groups such as American Industrial Hygiene Association21 (i.e., through "Administrative" and
"Workplace" controls). The Centers for Disease Control provides guidance for developing
health and safety plans in agricultural settings.22 The effectiveness of similar plans has also been
evaluated in the literature. Examples include "lookback" reviews conducted by the Occupational
Safety and Health Administration (OSHA) which essentially implemented standards in various
industries then reviewed their effectiveness in this process as they are required to determine
whether the standards should be maintained without change, rescinded or modified. OSHA is
required by Section 610 of the Regulatory Flexibility Act (5 U.S.C. 610) and Executive Order
12866 to conduct the lookback reviews. These reviews are conducted to make the final standards
more effective or less burdensome in achieving their objectives, to bring them into better
alignment with the objectives of Executive Order 12866, and to make them consistent with the
objectives of the Regulatory Flexibility Act. Two examples of "lookback" reviews that support
21 Ignacio and Bullock (2006) A Strategy For Assessing and Managing Occupational Exposures (Third Edition),
American Industrial Hygiene Association, AIHA Press 2700 Prosperity Avenue, Suite 250 Fairfax VA 22031 (ISBN
1-931504-69-5)
22 Karsky (2002) Developing a Safety and Health Program to Reduce Injuries and Accident Losses, Centers For
Disease Control National Ag Safety Database, available at http://www.cdc.gov/nasd/docs/d001501-
dOO 1600/dOO 1571/dOO 1571 .html
65
-------
the use of FMPs for soil fumigant health and safety management include: ethylene oxide use as a
fumigant/sterilant, and grain handling facilities requirements.
23
According to stakeholder comments, most of the information required for the site-specific
FMP is already being documented by users. Most industry stakeholders support mandatory
FMPs provided they are not too restrictive and do not result in an excessive administrative
burden.
Each site-specific FMP must contain the following elements:
General site information
o Site address or description of location
o Site operator/owner's name, address, and, phone number
o Map, aerial photo, or detailed sketch showing field location, dimensions, buffer
zones, property lines, public roads, bus stops, water bodies, wells, rights-of-ways
inside buffers, nearby application blocks, surrounding structures (occupied and
non-occupied), locations of posted signs for buffers, and sites requiring 1A mile
buffer zones (e.g., prisons, schools, hospitals, state licensed day care centers) with
distances from the application site labeled
Applicator information (license number, address, phone number, contact information for
person supervising the fumigation with location and date for completing the registrant's
chloropicrin training program)
Authorized on-site personnel (Names of all handlers and the tasks they are authorized and
trained to perform)
Application procedures
o Fumigation window (target application date, earliest and latest possible date of
fumigation)
o Product information (brand name, registration number)
o Type of fumigation (e.g., shank, broadcast, drip, raised bed, strip, etc.)
o Target application rate and application block size
Good Agricultural Practices (GAPs)
o Description of applicable mandatory GAPs (registrants may also include optional
GAPs)
o Measurements and other documentation planned to ensure GAPs are achieved
(e.g. measurement of soil and other site conditions, tarp
repair/perforation/removal plans, etc.)
Buffer zones
o Calculations and rationale for buffer zones distances (e.g. specify table from label
that distances are based on, rate and block size, applicable credits applied)
o Start and stop times for buffer zones
Respirators and other personal protective equipment (PPE) for handlers (respirator type,
respirator cartridge, and other PPE selection; verification that respirator training/fit-
testing/medical exams is current; and maintenance/storage procedures)
23 United States Department of Labor, Occupational Safety and Health Administration (2008) Lookback Reviews
available at http://www.osha.gov/dea/lookback.html
66
-------
Air monitoring
o Type of samples that will be collected (e.g., occupational, in occupied structures,
outside buffer zone area if site monitoring is conducted, etc.)
o When and where samples will be collected
o Duration of samples
o Sampling methods and equipment
o Name, address, and, phone number of person taking samples
Posting (names of persons who will post signs, location of posting signs, procedures for
posting and sign removal)
Site-specific response and management
o Fumigant site monitoring
Description of who, when, where, and procedures for monitoring buffer
zone perimeter
o Response information for neighbors
List of residences and businesses informed (neighboring property owners)
Method of sharing information
State and tribal lead agency notification
o Include the information that is sent to the lead agency
Plan describing how communication will take place between applicator, land
owner/operator, and other on-site handlers (tarp cutters/removers, irrigators, etc.)
Record keeping procedures
Emergency procedures (evacuation routes, locations of telephones, contact information
for first responders, local/state/federal contacts, key personnel and emergency
procedures/responsibilities in case of an incident, equipment/tarp/seal failure, odor
complaints or elevated air concentration levels outside buffer zone suggesting potential
problems, or other emergencies).
Hazard communication (product labels, material safety data sheets, etc.)
For situations where an initial FMP is developed and certain elements do not change for
multiple fumigation sites (e.g. applicator information, authorized on-site personnel, record
keeping procedures, emergency procedures, etc.) only elements that have changed need to be
updated in the site-specific FMP provided the following:
The certified applicator supervising the application has verified that those elements are
current and applicable to the application block before it is fumigated and has documented
the verification in the site-specific FMP.
Recordkeeping requirements are followed for the entire FMP (including elements that do
not change).
Once the application begins, the certified applicator and owner/operator of the application
block must provide a copy of the FMP to handlers who are involved in the fumigation, workers
in adjacent areas to the application block, and federal/state/local enforcement personnel, upon
request.
67
-------
Within 30 days of completing the application portion of the fumigation process, the
certified applicator supervising the application must complete a post fumigation application
summary that describes any deviations from FMP that have occurred, measurements taken to
comply with GAPs as well as any complaints and/or incidents that have been reported to
him/her. The summary must include the actual date of the application, application rate, and size
of application block fumigated.
In addition to recordkeeping requirements from 7 CFR part 110 "Recordkeeping
Requirements for Certified Applicators of Federally Restricted Use Pesticides," this decision
requires that both the applicator and owner/operator of the application block must keep a signed
copy of the site-specific FMPs and the post-application summary record for 2 years from the date
of application.
Applicators and other stakeholders have the flexibility to prepare FMPs templates or use
software with certain elements listed above in check-list and/or fill in the blank format. Below
are examples of other FMP templates available on the internet for structural fumigations that
may be useful to users when developing FMPs for chloropicrin soil applications:
http ://www. cardinalproproducts. com/Mi sc/FMP%20 Version%203. pdf
http://www.pestcon.com/techlibrary/fum_mgmt_plan.doc
http://www.agr.state.ne.us/division/bpi/pes/fumi gation_plan.pdf
http://www.agr.state.ne.us/division/bpi/pes/fumi gation_plan2.pdf
http ://nmdaweb .nmsu. edu/pesticides/Management%20Plans%20Required%20for%20Fu
migations.html
3. Emergency Preparedness and Response
EPA believes measures for ensuring preparedness for situations when accidents or
emergencies occur are an important part of the suite of measures necessary to address risks posed
by fumigants. Therefore, EPA is requiring such measures at the community level in the form of
education for first responders, and information for specific sites to ensure early detection and
quick response to situations as they arise.
Although EPA believes buffers and other mitigation will prevent many future incidents, it
is likely that some incidents will still occur due to accidents, errors, and/or unforeseen weather
conditions. Early detection and appropriate response to accidental chemical releases is an
effective means of reducing risk, as well as addressing the source of the release. Reducing risks
associated with incidents that may occur in the future is a key part of EPA's soil fumigant
decisions. By combining buffers with GAPs, FMPs, and effective emergency response, EPA is
able to reach a "no unreasonable adverse effects" finding under FIFRA.
To ensure that appropriate response mechanisms are in place in the event of a fumigant
exposure incident, EPA is requiring that registrants provide training and information, in the
context of their community outreach and education programs (see the Community Outreach and
Education Programs section on page 78), to first responders in high-fumigant use areas and
areas with significant interface between communities and fumigated fields. In addition,
68
-------
applicators must provide on-site monitoring of buffer zone perimeters in areas where residences
and other occupied structures are present. As an alternative to on-site monitoring, applicators
may provide emergency response information directly to neighbors. Each element is discussed
in more detail below.
a. First Responder Education
EPA is requiring registrants through their community outreach and education programs
see Community Outreach and Education Programs section on page 78, to ensure that emergency
responders have the training and information that they need to effectively identify and respond to
fumigant exposure incidents. EPA believes this will help ensure, in the case of a fumigant
accident or incident that first responders recognize the exposure as fumigant related and respond
appropriately. The information/training to be provided to first responders will include: how to
recognize the early signs and symptoms of fumigant exposure, how to treat fumigant exposures,
how fumigant exposure differs from other pesticide exposure, plus the material safety data
sheet(s) (MSDS) for the fumigant(s) applied.
The Agency is interested in comments from state and/or local officials about the extent to
which first responders are currently receiving information on soil fumigants, for example can
they recognize fumigant exposures, and are they aware of the appropriate steps to take to
mitigate the exposures and address the source of the exposure. In California, for example, where
soil fumigation is common in many areas, the state administers training and education for first
responders to help raise awareness and improve skills in responding to incidents. If registrants
can document that effective state programs are already in place, additional training may not be
required. However, registrants must work with state and local emergency response coordinators
to identify needs and opportunities to supplement any information already included in state and
local training for first responders about soil fumigants specifically.
b. Site-Specific Response and Management
i. Fumigation Site Monitoring
EPA has determined that monitoring of the buffer zone perimeter would be an effective
approach to protect bystanders. Under this approach, if measured concentrations anywhere along
the buffer perimeter reach a level of concern specified on product labels, or if the person
monitoring the air concentrations experiences eye irritation, an early sign of exposure to
concentrations that exceed the Agency's LOG, then the emergency response plan stated in the
FMP (see FMP section on page 65) must be implemented. If other problems occur, such as a
tarp coming loose, then the appropriate control plan must be activated. Because data indicate
that peak concentrations sometimes occur on the second day following applications, EPA
decided that this monitoring must be done for the full buffer zone period to ensure concentrations
do not exceed the action level which will be specified on product labels.
Specific requirements include:
Monitoring must take place from the beginning of the fumigant application until the
buffer zone period expires.
69
-------
Monitoring must be conducted by a certified applicator or someone under his/her
supervision.
Monitoring of air concentration levels of the fumigant must take place in the area
between the buffer zone and the residences or other occupied areas.
The person monitoring the air concentration levels must take readings starting
approximately 30 minutes from the start of application and at least once each hour during
the entire application and buffer zone period.
A direct reading detection device, such as a Draeger device, with a sensitivity of at least
0.15 ppm for chloropicrin must be used to monitor the air concentration levels of
chloropicrin.
If at any time (1) chloropicrin concentrations are greater than or equal to 0.15 ppm OR
(2) the person monitoring the air concentrations experiences sensory irritation, then the
emergency response plan stated in the FMP must be immediately implemented by the
person monitoring the air concentrations.
If other problems occur, such as a tarp coming loose, then the appropriate control plan
must be activated.
The results of the air concentration monitoring must be recorded in the FMP.
EPA is interested in comments from fumigant users, researchers, and equipment
manufacturers about the extent to which mechanical devices are available or are under
development that can both monitor air concentrations and also notify the person responsible for
the fumigation when air concentrations approach levels of concern. Such devices are routinely
used to monitor environmental conditions in laboratories, and could represent an effective
alternative to posting a person on site. EPA also requests input from stakeholders who have
experience conducting air monitoring and use of devices on whether more effective, efficient, or
practical alternative approaches exist. For example, with specific application methods,
fumigants, and/or regional weather conditions, what frequency and duration of sampling would
be equally as effective as what is specified in the mitigation?
While protective, this site monitoring might be burdensome for users fumigating in areas
with few or no people. Therefore, EPA is allowing users the alternative option of providing
emergency response information directly to neighbors.
ii. Response Information for Neighbors
As an alternative to on-site monitoring, the certified applicator supervising the fumigation
(or someone under his/her direct supervision) would need to ensure that residences and
businesses that meet the criteria outlined below have been provided the information below at
least 48 hours prior to fumigant application in a specified field. If after 2 weeks, the fumigation
has not yet taken place, the information must be delivered again.
Information that must be provided includes:
o Location of the application block
o Name of fumigant products(s) applied including EPA Registration
number
o Applicator and property owner/operator contact information
70
-------
o Location of buffer zones
o Time period in which the fumigation is planned to take place and the
duration of buffer zone period
o Early signs and symptoms of exposure to the fumigant(s) applied,
what to do, and who to call if you believe you are being exposed
(911 in most cases).
The method for distributing information to neighbors must be described in the FMP and
may be accomplished through mail, telephone, door hangers, or through other methods that can
be reasonably expected to effectively inform residences and businesses within the required
distance from the edge of the buffer zone.
Who Needs to be Informed?:
If the buffer zone is People within this distance
less than or equal to: from the edge of the buffer zone
must be informed:
Buffer < 100 feet 50 feet
100 feet < Buffer < 200 feet 100 feet
200 feet < Buffer < 3 00 feet 200 feet
Buffer > 3 00 feet 3 00 feet
71
-------
To clarify this option, the following example is provided:
IF the buffer zone is 125 feet, people within 100 feet of the buffer zone must be provided
emergency response information. So the red houses would need to be informed, but the
house would not.
This requirement does not impact the roadway or the property operator's residence (striped).
Figure 9. Example Site Map for Informing Neighbors
Roadway
Property
Operator's
Residence
If there are no residences or other occupied structures within 300 feet of the edge of the
buffer zone, no site monitoring or advising of neighbors will be required.
c. Emergency Preparedness and Response
Considerations
EPA received comments from many stakeholders about the Agency's Phase 5 proposal
for notification. Users have commented that notification is burdensome and that it is
unnecessary if buffer zones are also required. However, community groups have commented on
the importance of bystanders being informed when fumigations are occurring, since this group of
pesticides, compared to other pesticides, has a greater potential to move off site and affect people
not involved in the application. State regulators have different views on this requirement. Some
support the sharing of information with neighbors, and some states have notification
requirements for fumigations with certain products or for certain application methods. In
addition, some states require notification to chemically sensitive individuals in proximity to
pesticide applications. Others also had concerns about the enforceability of this type of measure
and the possible burden on the states to enforce a notification requirement.
72
-------
California currently requires notification of persons within 300 feet of a methyl bromide
buffer zone. California strawberry growers consider the 300 foot notification area for methyl
bromide applications to be an extension of the buffer zone. In areas where a large number of
people would need to be notified about a planned methyl bromide application, strawberry
growers state that they would rather not use methyl bromide because some communities could
mobilize to prevent the fumigation from taking place. Some stakeholders also commented that it
would be protective and less burdensome if EPA required the user to monitor fumigant air
concentrations at the edge of the buffer for 24 hours after the application to ensure the fumigant
does not move beyond the buffer at concentrations that exceed EPA's level of concern. If
concentrations of concern were detected, the user would be required to implement the emergency
response measures specified in the fumigant management plan.
EPA has concluded that bystanders could take steps to protect themselves if they had
basic information about fumigations and the appropriate steps to take if they experienced
symptoms of exposure. In a number of fumigant incidents that have occurred, the magnitude and
severity of the incident could have been significantly reduced if people had such information.
Similarly, having on-site monitoring will enable site managers to take remedial action (i.e.,
activate the control plan in the FMP) to lower emissions sooner, also resulting in fewer and less
severe exposures. And, if necessary, site managers would activate the emergency response
elements of the FMP.
Providing communities with information about local chemical releases is an important
part of emergency preparedness programs and is recognized as an effective means of addressing
risk at the local level. Some states, like Florida and Wisconsin, have requirements for providing
information to chemically-sensitive individuals about chemicals used nearby so they can take
steps to protect themselves from potentially harmful exposures (see http://edis.ifas.ufl.edu/pi004
and http://www.legis.state.wi.us/rsb/code/atcp/atcp029.pdf). Wisconsin also requires fumigators
applying metam sodium products through chemigation to provide written notice to the county
public health agency and to every individual or household within 1A miles of the chemigation
application site (see http://www.legis.state.wi.us/rsb/code/atcp/atcp030.pdf). EPA agrees that
information about how to recognize and address exposures can help citizens reduce potential
risk.
EPA understands that difficult challenges exist when agricultural land borders urban or
suburban communities. While EPA's decisions for the fumigants will not alleviate challenges
that already exist, EPA is allowing options for ensuring emergency preparedness in an effort to
lessen potential impact on growers.
If users opt, based on their site conditions, to provide emergency response information to
neighbors rather than monitor, EPA believes that scaling the size of the informed area will be
protective and helps address concerns expressed by some fumigant users. When the informed
area is scaled to the size of the buffer, small buffers which generally result from applications to
small areas, at low application rates, and/or using low-emission application techniques, will have
small or no areas to inform, while larger applications will have larger areas to inform.
73
-------
EPA is not requiring a specific method of providing the information to neighbors, but
rather that it be done in a way that effectively communicates, in a manner the recipients will
understand. Some methods may not result in documentation that would be retained. To address
concerns about enforcement, EPA is requiring that information on how and when the emergency
response information was delivered and to whom, be included in the FMP.
EPA is interested in input on the importance and usefulness of information specifying the
location of the application block and buffer. EPA recognizes that such information may be
difficult to convey clearly and concisely, especially if there are no easily recognizable land
marks nearby. While such information may be helpful, it may not be critical to ensuring an
appropriate response to early signs and symptoms of exposure.
4. Notice to State Lead Agencies
EPA believes that when state, tribal and local enforcement officials have information
about when and where applications take place they are better able to plan and execute
compliance assistance and assurance activities. Therefore, EPA is requiring notification of the
appropriate state or tribal lead agency before an application begins to assist enforcement
agencies in compliance monitoring.
The information that must be provided includes the following:
o Applicator contact information (name, telephone number, and applicator license
number)
o Property owner/operator contact information
o Location of the application block
o Name of fumigant(s) products(s) applied including EPA Registration number
o Time period in which the fumigation is planned to take place and the duration of
buffer zone period
Assuring compliance with new label requirements is an important component of the
fumigant risk mitigation package. Notice to enforcement officials allows them to target
inspections around periods when fumigations are expected to occur to ensure label requirements
designed to mitigate risks of concern for bystanders, handlers, and workers, have been followed
and that the conditions for the fumigation have been documented in the FMP. In states such as
California, where permitting processes are already in place, additional notice to state and tribal
lead agencies will not be required.
5. Soil Fumigation Training for Applicators and Other
Handlers
Soil fumigation is an inherently complex activity involving specialized equipment and
application techniques. Additionally, the mitigation measures required as part of these decisions
will introduce new requirements in the form of more detailed instructions and restrictions on soil
fumigations. Failure to adequately manage fumigant applications increases risks to handlers
74
-------
involved in the fumigation, workers nearby, and other bystanders. Incident data show that a
number of fumigant incidents are the result of misapplications, failure to follow label
requirements and safe use procedures, and other errors on the part of fumigant applicators.
Although states have certification programs, some of which include a specific category for soil
fumigation, there currently is not a consistent standard across states and regions where soil
fumigation is done, and the federal certification program currently has no category for soil
fumigation. Proposed changes in the federal certification program and worker safety regulations
to include a soil fumigation category are not, however, anticipated in the near future.
EPA believes that training is an effective way to increase applicators' skill and
knowledge so they are better prepared to effectively manage soil fumigation and are able to
understand and comply with revised labeling. EPA has determined that training, developed and
implemented by registrants to foster product stewardship, will help reduce potential risks
associated with failure to adequately manage the complexities of fumigation, and failure to
comply with fumigant product labeling. Additionally, EPA believes that providing safety
information to other fumigant handlers will help them understand and adhere to practices that
will help handlers protect themselves from risks of exposure.
It is important to note that training developed and provided by registrants as required by
this RED is separate and distinct from state certification programs. EPA encourages registrants,
in developing their training proposals, to work with states where their products are used to
identify opportunities to build on and complement state programs. However, the training
programs required as part of this decision will be separate from the state certification process and
will be developed and administered by registrants. Individual state regulatory agencies have the
option of working with registrants on these activities, but are not required to do so. It is
important to note that some fumigant registrants have already developed product-specific
training that will serve as a good basis for this expanded effort.
a. Training for Applicators Supervising
Fumigations
Registrants will be required to develop and implement training programs for applicators
in charge of soil fumigations on the proper use and GAPs for soil fumigants. EPA is requiring
registrants to submit proposals for these programs as data requirements in the Data Call-In that
will accompany this RED. The training programs must address, at minimum, the following
elements: how to correctly apply the fumigant; how to protect handlers and bystanders; how to
determine buffer zone distances; how to develop a FMP and complete the post fumigation
application summary; how to determine when weather and other site-specific factors are not
favorable for fumigant application; how to comply with required GAPs and document
compliance in the FMP. The training program must be made available to applicators at least
annually. The registrant shall provide documentation, such as a card or certificate, to each
applicator who successfully completes the training. This documentation shall include the
applicator's name, address, license number, and the date of completion.
The registrant must be able to provide to federal, state, or local enforcement personnel,
upon request, the names, addresses, and certified applicator license numbers of persons who
75
-------
successfully completed the training program, as well as the date of completion. Applicators
supervising fumigations must have successfully completed the program within the preceding 12
months and must document when and where the training program was completed in the FMP.
The registrants will be required to (1) develop a database to track which certified applicators
have successfully completed the training and (2) make this database available to state and/or
federal enforcement entities upon request. In addition, the applicator must provide to federal,
state, or local enforcement personnel, upon request, documentation that verifies completion of
the appropriate training program(s).
Product labels will state that before applying the product, the certified applicator
supervising the application must have successfully completed, within the preceding 12 months, a
chloropicrin training program made available by the registrant, and that the FMP must document
when and where the training program was completed.
EPA encourages registrants to include in their proposals additional stewardship elements
such as technical support information and resources for certified applicators and/or handlers
(e.g., hotlines to answer technical questions from applicators about product use and provide
emergency preparedness and response), and equipment verification programs to assist
applicators with calibration and testing of soil fumigation equipment. The Agency is soliciting
input during the post-RED comment period from states, user groups, registrants, and other
stakeholders on content and how best to implement training programs and other stewardship
elements.
b. Training Materials for Handlers
EPA has determined that registrants must prepare and disseminate training information
and materials for other fumigant handlers, i.e., those working under the supervision of the
certified applicator in charge of fumigations. EPA is requiring registrants to submit proposals
for these materials as data requirements in the Data Call-Ins that will accompany this RED. The
training materials must address, at minimum, the following elements: (1) what fumigants are
and how they work, (2) safe application and handling of soil fumigants, (3) air monitoring and
respiratory protection requirements for handlers, (4) early signs and symptoms of exposure, (5)
appropriate steps to take to mitigate exposures, (6) what to do in case of an emergency, and (7)
how to report incidents. Registrants must provide this training information through channels
open to the public (e.g., via a website). Pesticide labels will require that applicators supervising
fumigations provide this training information to handlers under their supervision before they
perform any fumigant handling task, or they must ensure that handlers have been provided the
required information within the preceding 12 months. The label will also require that the
training information be provided in a manner that the handler can understand. Applicators
supervising fumigations must ensure the FMP includes how and when the required training
information was provided to the handlers under their supervision. Below is the language that
must appear on the label.
"The certified applicator must provide fumigant safe handling information to each handler
involved in the application or confirm that each handler participating in the application has
received fumigant safe handling information in the past 12 months. "
76
-------
c. Soil Fumigation Training Considerations
In comments on fumigant risk management options, stakeholders were broadly
supportive of additional training for applicators and handlers. During the most recent comment
period, the vast majority of stakeholders, including growers, community groups, farm workers,
states, and registrants expressed strong support for increased training for applicators and other
handlers. Several comments noted that fumigant incidents affecting both fumigant workers and
bystanders could have been prevented or mitigated if applicators had better training about correct
practices and procedures.
The Agency agrees that additional training and technical support for fumigant applicators
and handlers will help educate and inform these workers, thus decreasing the likelihood of both
incidents and noncompliance. EPA believes fumigant-specific training for applicators and
handlers also will help reduce the magnitude and frequency of exposure incidents and, coupled
with the other mitigation measures described in this decision, will address risks of unreasonable
adverse effects from the use of soil fumigants.
As noted above, several states have high-quality certification programs for fumigators
which include exams to test the competency of fumigators. EPA recognized that for applicators
to become certified in those states, they must acquire the knowledge and skill necessary to pass
the exam. But several stakeholders commented that training opportunities are varied across the
country, and the scope and detail of information provided in available training is not consistent.
EPA is also concerned that information in existing programs will need to be updated as a result
of new requirements associated with this decision and the label changes which will result.
Although the federal program will be revised eventually and will establish a consistent standard,
EPA believes that registrants must play a central role in developing and delivering training in the
interim.
EPA stresses that registrant training programs will be separate from the state certification
process and will be developed and administered by registrants in coordination with EPA. EPA
will, however, work with state organizations and training experts to explore opportunities for the
registrant programs to supplement state programs to provide additional training opportunities for
fumigators. EPA will work with registrants in reviewing training program proposals and in
developing the content for the programs and materials. EPA will also work with states to
identify ways in which registrant training programs can be tailored to complement existing state
programs. EPA's goal in requiring registrant training is to add to training resources. EPA is
aware of the need to coordinate carefully with states to ensure that new training does not become
a burden on state agencies. EPA specifically requests comments from states on the best
implementation approaches to meet these goals, and plans to meet with states during and after
the public comment period to discuss options.
The Agency also expects that FMPs will serve as tools with which fumigant users can
maintain records of their compliance with training requirements in addition to the other measures
described in this document. Thus, FMPs would serve as an additional tool for verification state
enforcement personnel to verify compliance.
77
-------
6. Community Outreach and Education Programs
EPA understands from public comments, site visits, and stakeholder meetings, conducted
as part of the soil fumigant review, that there is often a fundamental lack of information and
communication within communities where soil fumigation occurs, which has raised health and
safety concerns among community members. This lack of information and communication has
led to inappropriate responses in cases where fumigants have moved off site and into
communities. This also has led in some cases to unwarranted concern and anxiety among
communities about the risks associated with the use of fumigants. The Agency believes that
outreach and education to communities where soil fumigation occurs is an important component
of the overall package of measures to address bystander risk. This outreach and education will
address the risk of acute bystander exposure by educating community members in high-use areas
about buffer zones and their characteristics and purpose; the importance of not entering these
zones; how to recognize early signs of fumigant exposure, and how to respond appropriately in
case of an incident. The first responder education discussed in the First Responder Education
section on page 69 is a significant part of this program.
Therefore, the Agency is requiring registrants to develop and implement community
outreach and education programs, including programs for first responders, to address these
needs. EPA encourages registrants' proposals to work with existing community resources, such
as community health networks, for dissemination of information and implementation of their
programs. Registrants' proposals must also include criteria and a plan for identifying and
selecting the communities that will be receive outreach programs.
Community outreach and education programs must include the following elements, at
minimum: (1) what soil fumigants are and how they work, (2) what buffer zones are, (3) early
signs and symptoms of exposure, (4) appropriate steps to take to mitigate exposures, (5) what to
do in case of an emergency, and (6) how to report an incident.
EPA expects registrants' proposals for the first responder programs described in the First
Responder Education section on page 69 will also be designed to integrate with existing local
first-response and emergency preparedness networks.
The community outreach and education proposal and supporting materials for
communities and first responders, as well as a plan for evaluating the effectiveness of the
programs, will be included as data requirements in the Data Call-In that will accompany this
RED.
As with the training for fumigant applicators and handlers, the community outreach and
education program that the Agency is requiring is intended to be part of the registrants' long term
product stewardship. State governments are not required to participate in the program, but have
the option of working with EPA and registrants to develop and track this and any other
stewardship components which the registrants may include in their proposals.
78
-------
iii. Environmental Risk Mitigation
As mentioned in Section III.C on page 18, the Agency is concerned about both aquatic
and terrestrial risks. The Agency believes that mitigation measures detailed in the Human Health
Risk Mitigation Section will also reduce ecological risks. Although buffer zones and GAPs do
not directly reduce the potential risk to ecological organisms, they do provide an incentive to
reduce fumigant application rates and individual treatment areas which in turn will contribute to
lower exposure and risks for non-target organisms.
The Agency still has concerns regarding chloropicrin's potential to leach into
groundwater and surface water, and therefore is requiring the following language for both tarped
and untarped chloropicrin applications, "While chloropicrin has certain properties and
characteristics in common with chemicals that have been detected in groundwater (chloropicrin
is highly soluble in water and has low adsorption to soil), volatilization is this chemical's most
important route of dissipation." The Agency recognizes that managing soil moisture is an
important factor that may be used to reduce peak emissions, and the requirements related to soil
moisture described in the GAP section will not result in the leaching of chloropicrin into ground
or surface water.
In addition to the language above, to reduce the potential for chloropicrin to leach into
groundwater when tarps are used in broadcast applications, tarps must be perforated and/or
removed before noon and only when rainfall is not expected within 12 hours. Falling
temperatures typically found in the late afternoon and evening will not promote dissipation of
remaining chloropicrin under the perforated tarp and rainfall may cause remaining chloropicrin
under the perforated tarp to leach into ground water. For raised bed applications, rainfall is not a
factor since planting occurs with the tarp in place and perforation and/or tarp removal occurs
after chloropicrin has dissipated.
When chloropicrin applications are not tarped, the Agency has concerns about
chloropicrin's potential to leach into both groundwater and surface water if a rainfall event
occurs shortly after application. Chloropicrin may impact surface water quality due to runoff of
rain water. This is especially true for poorly draining soils and soils with shallow ground water.
Leaching and runoff of this product will be reduced by avoiding applications when heavy rainfall
is forecasted to occur within 24 hours.
The Agency has received a new study which estimates the exposure concentrations of
chloropicrin in aquatic environments. In addition EPA is requiring several ecological fate and
effect studies to address data gaps identified in the ecological risk assessment. See Section V of
this document for details on those studies.
b. Residential Structure Warning Agent Use Mitigation
Details on the chloropicrin's use as a warning agent prior to sulfuryl fluoride applications
are included in the Agency's Final Revised Human Health risk assessment as listed in Section
III.B of this document.
The Agency reviewed monitoring studies completed by the California Air Resources
Board (CARB) of the California Environmental Protection Agency. These studies directly
79
-------
monitored chloropicrin. The results of these studies are below the Agency's level of concern for
bystanders.
i. Occupational Risk Mitigation
1. Respiratory Requirements
The Agency does not have exposure data to assess handler exposures when chloropicrin
is used as a warning agent before sulfuryl fluoride residential fumigations. As a result, the
Agency is requiring that all handlers wear respiratory protection. The Agency is not requiring
monitoring for this chloropicrin use due to the short duration of the expected handler activities.
In addition, the Agency does not anticipate that the level of chloropicrin would exceed 1.5 ppm
(the estimated upper working level of the respirator based on a 90% protection factor) based on
conservative estimates of labeled use rates.
In order to ensure that the respiratory protection EPA is assuming is being achieved for
this use, respiratory requirements for chloropicrin will include fit testing, respirator training, and
annual medical evaluation. These requirements are the same as detailed in the respiratory
protection section for pre-plant soil fumigation on page 54.
c. Chloropicrin Antimicrobial Use Mitigation
For details on the chloropicrin human health risk assessment for antimicrobial uses,
please refer to the revised occupational and residential/bystander assessment described in Section
III.B of this document.
The antimicrobial uses of chloropicrin are subject only to the mitigation listed below.
i. Bystander Risk Mitigation
The revised risk assessment indicates the potential for acute bystander exposure to
chloropicrin when it is used for remedial wood treatment. The Agency believes that requiring
the following will reduce this potential below the Agency's level of concern:
Plug the pre-drilled holes immediately after chloropicrin applications;
Do not treat structures^eams indoors; and
Do not drill an application hole through seasoning checks to apply product. If the hole
intersects a check, plug the hole and drill another. If more than 2 treatment holes
intersect an internal void or rot pocket, redrill the holes farther up the pole into relatively
solid wood.
ii. Occupational Risk Mitigation
The Agency's revised risk assessment indicates the potential for handler inhalation
during the transfer of chloropicrin into vials and during the pouring/injection of chloropicrin into
pre-drilled holes. To mitigate these risks, the Agency is requiring that applicators and handlers
wear a full face tight-fitting or loose-fitting helmet or hood style NIOSH/MSHA approved
80
-------
respirator at all times when handling chloropicrin during the transfer of the product into vials and
during the pouring/injecting of chloropicrin into pre-drilled holes. However, use of a respirator
is not being proposed for application of the vials once they are filled.
1. Air Concentration
If a spill or leak were to occur, some of the current labels require respiratory protection if
air concentrations of chloropicrin exceed 0.3 ppm at any time, while others require respiratory
protection if the air concentrations exceed 0.1 ppm. To rectify these differences, the Agency is
requiring that unprotected persons not be permitted entry into spill area or clean-up area until the
concentration of chloropicrin is determined to be less than 0.1 ppm.
2. Respiratory Requirements
Applicators and handlers that directly pour or inject chloropicrin into timbers or fill vials
must wear a full-face tight-fitting, or loose-fitting helmet or hood style NIOSH/MSHA approved
respirator when handling chloropicrin. Since the Agency is requiring a full-face respirator and
eyes are covered, and not a half-face respirator, all references to wearing goggles and/or full face
shields for this application use must be removed from the labels.
Applicators and handlers that are involved in the vial application method are not required
to wear a respirator (as the vials are already filled and capped). However, at least one air rescue
device (e.g., SCBA) and air-purifying respirators and cartridges for each handler must be
immediately available on-site in case of a spill or an emergency.
In order to ensure that the respiratory protection EPA is assuming is being achieved for
this use, respiratory requirements for chloropicrin will include fit testing, respirator training, and
annual medical evaluation. These requirements are the same as detailed in the respiratory
protection section for pre-plant soil fumigation on page 54.
2. Endocrine Disrupter Effects
EPA is required under the FFDCA, as amended by FQPA, to develop a screening
program to determine whether certain substances (including all pesticide active and other
ingredients) "may have an effect in humans that is similar to an effect produced by a naturally
occurring estrogen, or other such endocrine effects as the Administrator may designate. "
Following the recommendations of its Endocrine Disrupter Screening and Testing Advisory
Committee (EDSTAC), EPA determined that there were scientific bases for including, as part of
the program, androgen and thyroid hormone systems, in addition to the estrogen hormone
system. EPA also adopted EDSTAC's recommendation that the Program include evaluations of
potential effects in wildlife. When the appropriate screening and/or testing protocols being
considered under the Agency's Endocrine Disrupter Screening Program (EDSP) have been
developed and vetted, chloropicrin may be subjected to additional screening and/or testing to
better characterize effects related to endocrine disruption.
81
-------
3. Endangered Species Considerations
The Endangered Species Act requires federal agencies to ensure that their actions are not
likely to jeopardize listed species or adversely modify designated critical habitat. The Agency
has developed the Endangered Species Protection Program to identify pesticides whose use may
cause adverse impacts on threatened and endangered species, and to implement mitigation
measures that address these impacts. To analyze the potential of registered pesticide uses that
may affect any particular species, the Agency uses basic toxicity and exposure data developed
for the REDs and then considers ecological parameters, pesticide use information, geographic
relationship between specific pesticide uses and species locations, and biological requirements
and behavioral aspects of the particular species. When conducted, this species-specific analysis
will also consider the risk mitigation measures that are being implemented as a result of this
RED.
Following this future species-specific analysis, a determination that there is a likelihood
of potential effects to a listed species may result in limitations on use of the pesticide, other
measures to mitigate any potential effects, or consultations with the Fish and Wildlife Service
and/or the National Marine Fisheries as appropriate. If the Agency determines use of
chloropicrin "may affect" listed species or their designated critical habitat, the Agency will
employ the provisions in the Services' regulations (50 CFR Part 402). Until the species-specific
analysis is completed, the risk mitigation measures being implemented through this RED will
reduce the likelihood that endangered and threatened species may be exposed to chloropicrin at
levels of concern. The Agency is not requiring specific chloropicrin label language at the present
time relative to threatened and endangered species. If, in the future, specific measures are
necessary for the protection of listed species, the Agency will implement them through the
Endangered Species Program.
Chloropicrin has undergone a species-specific analysis for the California Red-Legged
Frog case. The Agency determined that chloropicrin is "likely to adversely effect" this species.24
The Agency's assessment is currently with the Fish and Wildlife Service. After the final
determination has been made, the Agency may require other mitigation.
D. Conclusions
In this document, the Agency has described a package of mitigation measures with
elements that are designed to work together to reduce risk to human health and the environment.
Due to the volatility of chloropicrin, the Agency believes that all of the mitigation measures
required by this decision will mitigate risks so that use of chloropicrin will result in no
unreasonable adverse effects.
Stakeholder comments and Agency analyses indicate that mitigation may impact the
economic benefits of fumigant use. One analysis completed by the Agency quantified the
potential impact of buffer zones. For details of that analysis, please see the document titled
"Review of Stakeholder Submitted Impact Assessments of Proposed Fumigant Buffers,
Comments on Initial Buffer Zone Proposal, and Case Studies of the Impact of a Flexible Buffer
System for Managing By-Stander Risks of Fumigants."19
'http://www.epa.gov/espp/litstatus/effects/redleg-frog/index.html#chloropicrin
82
-------
The Agency believes that some economic impact will occur in order to protect human
health and the environment from unreasonable adverse effects. However, the mitigation package
described in this document incorporates flexibility which allows users to make choices that
minimize potential impacts. For example, a current application practice might require a large
buffer that a user is not able to implement. However, instead of setting a fixed buffer for all
applications regardless of application-specific parameters, this decision allows growers the
flexibility to modify their practices to achieve smaller buffers; for example treat smaller
application blocks, or switch to a lower emission application method. Also, the buffer zone
reduction credits allow users to take advantage of site conditions (e.g., soil conditions) or other
emission reduction factors such as high barrier tarps to lessen the impact. In addition, the
Agency believes that flexibility decreases the impacts associated with respiratory protection
mitigation. Instead of requiring respirators for all handling tasks, the monitoring scheme
specifies when respiratory protection is needed. This mitigation is protective of handlers while
not increasing the burden to users by mandating respirators in such a way as to hinder
communication or force users into heat stress situations.
When chloropicrin is used as a warning agent and as an antimicrobial for remedial wood
treatments, the Agency believes that the required mitigation is protective and anticipates that it
will have minimal impact on the benefits.
Taking into consideration the totality of risk and benefit assessments and stakeholder
comments, the Agency believes the mitigation required in this document will be protective while
also minimizing impacts on fumigant users and applicators.
83
-------
V. What Registrants Need to Do
The Agency has determined that the products containing chloropicrin are eligible for
reregi strati on provided that the mitigation measures and label changes identified in this RED are
implemented. EPA recognizes that the extent and complexity of the mitigation needed for
chloropicrin will require continued coordination among state regulatory agencies, the EPA,
registrants, growers and other stakeholders. This is necessary to ensure that all provisions of the
RED are understood, that data are developed and evaluated expeditiously, and that bystander and
worker protection measures are implemented as soon as practicable. EPA also acknowledges
that certain provisions of the RED, such as the worker training program and community outreach
and education, will take time to develop in terms of both the content of the program as well as a
strategy for implementation.
EPA envisions the following approximate schedule for implementation of the chloropicrin RED:
July 2008 Chloropicrin RED issued
Fall 2008 Comment period closes
Early 2009 EPA responds to comments, amends RED if appropriate
Mid 2009 EPA issues product and generic DCIs
Mid 2009 Registrants submit revised labels to EPA
Late 2009 EPA reviews/approves new labeling
During 2009 Registrants develop worker and community training and education
plans and submit to EPA; plans approved and implemented
Early 2010 Products bearing new labels enter the market; training and
education programs expand.
2009-2012 Registrants develop data per DCI
2013 EPA begins Registration Review for chloropicrin and other fumigants
The Agency is issuing this decision document for chloropicrin, as announced in a Notice
of Availability published in the Federal Register. Due to the broad scope of the decision for the
soil fumigant group, there will be a 60-day public comment period for this document to allow
stakeholders the opportunity to review and provide comments on issues related to the
implementation of the risk mitigation measures. After considering public comment, the Agency
will issue a public determination as to whether modifications to this decision are appropriate.
Labeling
Registrants will need to amend their product labeling to incorporate the label statements set
forth in the Label Changes Summary Tables 10 and 22. The Agency will consider post-RED
comments prior to finalizing labeling. The Agency anticipates that label amendments will need
to be submitted approximately 1 year from the issuance of the RED.
A. Manufacturing Use Products
1. Additional Generic Data Requirements
84
-------
The generic data base supporting the reregi strati on of chloropicrin has been reviewed and
determined to be substantially complete. However, the data listed below are necessary to
confirm the reregi strati on eligibility decision documented in this RED.
a. Data Requirements for Chloropicrin Soil Uses
i. Human Health
1. Toxicity
There are no data requirements.
2. Residue Chemistry
There are no data requirements.
3. Occupational and Residential Exposure
See chart below.
OPPTS Guideline
Number
835.8100
835.8100
835.8100
Data Requirement
Field volatility from soil, to determine
flux for modeling purposes for
applications using water seals
Field volatility from soil, to determine
flux for modeling purposes for buried
drip irrigation applications.
Field volatility from soils, to determine
flux for modeling purposes for deep
broadcast untarped applications (> 18"
deep).
Study type
ORE
ORE
ORE
835.8100 - Field volatility from soil
Volatility studies are required for chloropicrin's soil uses to determine flux for modeling
purposes. These studies will allow the Agency determine appropriate buffer zones when water
seals are used and also for drip buried untarp applications. Data for the deep broadcast untarped
application will enable a more refined inhalation risk assessment to be completed for buffer zone
determinations.
85
-------
ii. Environmental Fate and Ecological Effects
1. Environmental Fate
There are no data requirements.
2. Ecological Effects
See chart below.
OPPTS Guideline
Number
Special Study
870.1300
850.1075
850.1010
850.1075
850.1025
850.1035
850.4225
850.4250
850.4400
850.3020
Data Requirement
Avian Acute Inhalation
Acute Inhalation Toxicity Test-Rat
Acute Fish Toxicity -bluegill and
rainbow trout
Acute Aquatic Invertebrate Toxicity
Acute Marine/Estuarine Fish
Acute Marine/Estuarine Mollusk
Acute Marine/Estuarine Shrimp
Seed Germination/Seedling Emergence
- Tier II.
Vegetative Vigor - Tier II.
Aquatic Plant Growth - Tier II
Honeybee Acute contact.
Study type
ECO
TOX
ECO
ECO
ECO
ECO
ECO
ECO
ECO
ECO
ECO
Special StudyAvian acute inhalation.
The current estimate of avian risk is based largely on the mammal assessment. This study will
enable an inhalation risk assessment specific to birds. Since the risk assessment for terrestrial
wildlife is focused on inhalation and this study will provide actual inhalation data rather than an
estimation based on acute oral data, it is of even higher priority than the acute oral study.
870.1300Acute inhalation toxicity test - rat.
The existing study (MRID 45117902) is classified by HED as Acceptable/Non-guideline. The
7/25/00 DER and 1/31/05 Revised HED Human Health Risk Assessment state: "The LC50
calculated for the study should not be considered to be a true LC50 for chloropicrin. Due to the
sacrifice of all live animals at day 3 of the study instead of day 14, and too large of exposure
particle sizes, the true LC50 could be lower." Thus, a new study will enable an improved wild
mammal risk assessment with reduced uncertainty.
86
-------
850.1075Acute Fish Toxicity - bluegill and rainbow trout.
The risk assessment is currently relying on supplemental data. Flow-through studies with
measured concentrations will greatly reduce uncertainty.
850.1010Acute aquatic invertebrate toxicity.
The risk assessment is currently relying on supplemental data. Flow-through studies with
measured concentrations will greatly reduce uncertainty.
850.1075Acute Marine/Estuarine Fish.
Given the use patterns of chloropicrin, marine/estuarine species could be exposed. This study
will enable a risk assessment specific for marine/estuarine species exposure.
850.1025Acute Marine/Estuarine Mollusk.
Given the use patterns of chloropicrin, marine/estuarine species could be exposed. This study
will enable a risk assessment specific for marine/estuarine species exposure. It will also improve
certainty with the endangered species risk assessment, as this test species may be more
representative of endangered freshwater mussels than the freshwater Daphnia.
850.1035Acute Marine/Estuarine Shrimp.
Given the use patterns of chloropicrin, marine/estuarine species could be exposed. This study
will enable a risk assessment specific for marine/estuarine species exposure. One toxicity value
is available from a study published in the scientific literature, but it is from a static study without
measured concentrations.
850.4225Seed Germination/Seedling Emergence - Tier II.
Chloropicrin is used in part due to its phytotoxicity at the application site, and a wide range of
open literature and other non-guideline studies indicate the potential for plant damage. This
study will enable the assessment of risk to non-target terrestrial plants off-site.
850.4250Vegetative Vigor - Tier II.
Chloropicrin has at least some phytotoxicity on the treatment site, based on label and open
literature information. This study will enable the assessment of risk to non-target terrestrial
plants off-site.
850.4400Aquatic Plant Growth - Tier II.
87
-------
Chloropicrin has at least some phytotoxicity on the treatment site, based on label and open
literature information. This study will enable the assessment of risk to non-target aquatic plants
off-site.
850.3020Honeybee Acute contact.
This basic study is now being requested for virtually all outdoor uses, and will help determine
the need for, and specifics of, bee hazard labeling.
iii. Other
OPPTS Guideline
Number
Special
Special
Special
Data Requirement
Community Outreach and Education
Programs
Training for Applicators Supervising
Fumigations
Training Materials for Handlers
Study type
Special
Special
Special
Special Study - Community Outreach and Education Programs
The Agency is requiring registrants to develop and implement community outreach and
education programs, including programs for first responders, to address these needs. Community
outreach and education programs must include the following elements, at minimum: (1) what
soil fumigants are and how they work, (2) what buffer zones are, (3) early signs and symptoms
of exposure, (4) appropriate steps to take to mitigate exposures, (5) what to do in case of an
emergency, and (6) how to report an incident. EPA expects registrants' proposals for the first
responder programs described in Section IV will also be designed to integrate with existing local
first-response and emergency preparedness networks.
Special Study - Training for Applicators Supervising Fumigations
EPA has determined that training, developed and implemented by registrants to foster
product stewardship, will help reduce potential risks associated with failure to adequately
manage the complexities of fumigation, and failure to comply with fumigant product labeling.
Additionally, EPA believes that providing safety information to other fumigant handlers will
help them understand and adhere to practices that will help handlers protect themselves from
risks of exposure.
Registrants are required to develop and implement training programs for applicators in
charge of soil fumigations on the proper use of and GAPs for soil fumigants. EPA is requiring
registrants to submit proposals for these programs. The training programs must address, at
minimum, the following elements: how to correctly apply the fumigant; how to protect handlers
and bystanders; how to determine buffer zone distances; how to develop a FMP and complete the
88
-------
post fumigation application summary; how to determine when weather and other site-specific
factors are not favorable for fumigant application; how to comply with required GAPs and
document compliance in the FMP. The training program must be made available to applicators
at least annually. The registrant shall provide documentation, such as a card or certificate, to
each applicator who successfully completes the training. This documentation shall include the
applicator's name, address, license number, and the date of completion. The registrant must be
able to provide to federal, state, or local enforcement personnel, upon request, the names,
addresses, and certified applicator license numbers of persons who successfully completed the
training program, as well as the date of completion. Applicators supervising fumigations must
have successfully completed the program within the preceding 12 months and must document
when and where the training program was completed in the FMP. The registrants will be
required to (1) develop a database to track which certified applicators have successfully
completed the training and (2) make this database available to state and/or federal enforcement
entities upon request. In addition, the applicator must provide to federal, state, or local
enforcement personnel, upon request, documentation that verifies completion of the appropriate
training program(s).
Special Study - Training Materials for Handlers
EPA has determined that registrants must prepare and disseminate training information
and materials for other fumigant handlers, i.e., those working under the supervision of the
certified applicator in charge of fumigations. The training materials must address, at minimum,
the following elements: (1) what fumigants are and how they work, (2) safe application and
handling of soil fumigants, (3) air monitoring and respiratory protection requirements for
handlers, (4) early signs and symptoms of exposure, (5) appropriate steps to take to mitigate
exposures, (6) what to do in case of an emergency, and (7) how to report incidents. Registrants
must provide this training information through channels open to the public (e.g., via a website).
Pesticide labels will require that applicators supervising fumigations provide this training
information to handlers under their supervision before they perform any fumigant handling task,
or they must ensure that handlers have been provided the required information within the
preceding 12 months. The label will also require that the training information be provided in a
manner that the handler can understand. Applicators supervising fumigations must ensure the
FMP includes how and when the required training information was provided to the handlers
under their supervision.
b. Chloropicrin Warning Agent Uses
There are no data requirements.
c. Antimicrobial Uses
There are no data requirements.
2. Labeling for Manufacturing-Use Products
89
-------
To ensure compliance with FIFRA, manufacturing use product (MUP) labeling must be
revised to comply with all current EPA regulations, PR Notices, and applicable policies. The
MUP labeling must bear the labeling contained in Tables 10 and 22.
B. End-Use Products
1. Additional Product-Specific Data Requirements
Section 4(g)(2)(B) of FIFRA calls for the Agency to obtain any needed product-specific
data regarding the pesticide after a determination of eligibility has been made. The Registrant
must review previous data submissions to ensure that they meet current EPA acceptance criteria
and if not, commit to conduct new studies. If a registrant believes that previously submitted data
meet current testing standards, then the study MRID numbers must be cited according to the
instructions in the Requirement Status and Registrants Response Form provided for each
product. The Agency intends to issue a separate product-specific data call-in (PDCI), outlining
specific data requirements.
2. Labeling for End-Use Products
In order to be eligible for reregi strati on, amend all product labels to incorporate the risk
mitigation measures outlined in Section IV. Tables 10 and 22 describe how language on the
labels should be amended.
90
-------
Labeling Changes Summary Table for Chloropicrin
In order to be eligible for reregi strati on, all product labels muse be amended to
incorporate the risk mitigation measures outlined in Section IV. Also, various use and safety
information will be included in the labeling of all end-use products containing chloropicrin. The
following table describes how language on the labels should be amended.
Table 10: Summary of Labeling Changes for All Chloropicrin Uses (except antimicrobial use)
Description
Amended Labeling Language
Placement on
Label
For all
Manufacturing Use
Products
"Only for formulation into a fumigant for the following uses: pre-plant soil fumigant in
agricultural fields and commercial greenhouses, tree replant, warning agent prior to
sulfuryl fluoride residential structure fumigations, and remedial wood treatment."
Structural greenhouse and/or enclosed space fumigation uses have been cancelled and must
be deleted from end-use product labels. On end-use product labels, the directions for use
and mitigation use of chloropicrin as a warning agent before sulfuryl fluoride residential
structure fumigations must be kept separate from pre-plant soil use.
Unless emission data become available to allow EPA to calculate buffer zones for the
untarped (buried minimum of 5 inches) drip application method, then untarped drip
applications of chloropicrin must be prohibited on end-use product labels.
"Chloropicrin cannot be formulated into end-use products labeled for pre-plant or pre-
transplant uses unless the registrant makes available to certified applicators who purchase
or apply the end-use product a training program approved by EPA that provides
information on how to correctly apply the fumigant including how to protect themselves,
other handlers and bystanders, how to determine buffer zone distances, how to develop a
Fumigant Management Plan, and how to determine when weather and other site-specific
factors are not favorable for fumigant application. The training program must be made
available to the certified applicators at least annually and the registrant must be able to
provide, upon request, the names, addresses, and certified applicator license number of
persons who successfully complete the training program."
"Chloropicrin cannot be formulated into end-use products labeled for pre-plant or
pre-transplant uses unless the registrant assures warning signs suitable for posting
buffer zones are available to end-use product users at the point of sale.
The buffer zone sign must meet the following standards:
o Signs must remain legible during entire posting period.
o The size and type of the buffer zone signs must follow the requirements
in the Worker Protection Standard for Agricultural Pesticides for treated
area posting.
Contents of Sign
Directions for Use
- "DO NOT ENTER/NO ENTRE,"
91
-------
~ " [Name offumiganf] Fumigant
BUFFER ZONE,"
~ a space for the date and time of
fumigation,
~ a space for the date and time
buffer zone restrictions are lifted
(i.e., buffer zone period expires)
~ brand name of this product, and
~ a space for the name, address, and
telephone number of the certified
applicator in charge of the
fumigation
One of these
statements may be
added to a label to
allow reformulation
of the product for a
specific use or all
additional uses
supported by a
formulator or user
"This product may be used to formulate products for specific use(s) not listed on the MP
label if the formulator, user group, or grower has complied with U.S. EPA submission
requirements regarding support of such use(s)."
"This product may be used to formulate products for any additional use(s) not listed on the
MP label if the formulator, user group, or grower has complied with U.S. EPA submission
requirements regarding support of such use(s)."
Directions for Use
Environmental
Hazards Statements
Required by the RED
and Agency Label
Policies
"This pesticide is toxic to mammals, birds, fish, and aquatic invertebrates. Do not
discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or
other waters unless in accordance with the requirements of a National Pollutant Discharge
Elimination System (NPDES) permit and the permitting authority has been notified in
writing prior to discharge. Do not discharge effluent containing this product to sewer
systems without previously notifying the local sewage treatment plant authority. For
guidance, contact your State Water Board or Regional Office of the EPA."
Precautionary
Statements
End Use Products
Restricted Use
Requirement for all
products that contain
soil use
"Restricted Use Pesticide due to acute inhalation toxicity to humans. For retail sale to and
use by certified applicators or persons under their direct supervision and only for those
uses covered by the certified applicator's certification."
Top of the front
panel
For pre-plant soil
use.
Certified applicator
must complete
annual training
program.
"The certified applicator supervising that application must successfully complete a
chloropicrin training program made available by the registrant within the last 12 months.
The Fumigant Management Plan (see details elsewhere on this label) must document when
and where the training program was completed."
Directions for Use
For pre-plant soil
use.
Fumigation Handlers
"Persons engaged in any of the following activities are defined as fumigant handlers:
Persons participating in the application as supervisors, loaders, drivers, co-pilots,
shovelers, or as other direct application participants (application starts when the
fumigant is first introduced into the soil and ends after the fumigant has stopped
being delivered/dispensed to the soil);
Persons taking air samples to monitor fumigant air concentrations;
Persons cleaning up fumigant spills;
Persons handling or disposing of fumigant containers;
Persons cleaning, handling, adjusting, or repairing the parts of fumigation
equipment that may contain fumigant residues;
In the
Precautionary Use
Section
92
-------
Persons installing, repairing, operating irrigation equipment in the fumigant
application block or surrounding buffer zone during the buffer zone period;
Persons entering the application site or surrounding buffer zone during the buffer
zone period to perform scouting or crop advising tasks;
Persons installing, perforating (cutting, punching, slicing, poking), removing,
repairing, or monitoring tarps:
> until 14 days after application is complete if tarps are not perforated and
removed during those 14 days, or
> until tarp removal is complete if tarps are both perforated and removed less
than 14 days after application; or
> until 48 hours after tarps perforation is complete if they will not be
removed within 14 days after application
NOTE: see Tarp Perforation and Removal section on this labeling for
requirements about when tarps are allowed to be perforated."
When chloropicrin is
used as a warning
prior to sulfuryl
fluoride residential
structure
fumigations.
Fumigation Handlers
"All persons participating in the application of chloropicrin when it is used as a warning
agent prior to sulfuryl fluoride residential structure fumigations are pesticide handlers."
In the
Precautionary Use
Section
For pre-plant soil
use.
Supervision of
Handlers
"The certified applicator supervising the application must be at the fumigant application
site and able to maintain visual contact with every handler participating in the application
starting when the fumigant is first introduced into the soil and ending after the fumigant
has stopped being delivered/dispensed to the soil and the soil is sealed.
The certified applicator must provide fumigant safe handling information to each handler
involved in the application or confirm that each handler participating in the application has
received fumigant safe handling information in the past 12 months.
For all other fumigant handling tasks (as defined on this label), at least two WPS-trained
handlers must be present to monitor one another."
Directions for Use
Under the section
"protection for
handlers"
For pre-plant soil
use.
Exclusion of Non
Handlers from
Application Block
and Buffer Zone
"The certified applicator supervising the application and the owner/operator of the
establishment where the fumigation is taking place must make sure that all persons who
are not trained and PPE-equipped and who are not performing one of the handling tasks
defined in this labeling are:
excluded from application block during the entry prohibition period, and
excluded from the buffer zone during the buffer zone period."
Directions for Use
Under the section
"protection for
handlers"
For pre-plant soil use
Providing, cleaning,
and maintaining PPE
"The employer of any fumigant handler (as defined in this label) must make sure that all
handlers are provided and correctly wear the required PPE. The PPE must be cleaned and
maintained as required by the Worker Protection Standard for Agricultural Pesticides."
Directions for Use
Under the section
"protection for
handlers"
When chloropicrin is
used as a warning
prior to sulfuryl
fluoride residential
structure fumigations
"The employer of any handler participating in chloropicrin application prior to sulfuryl
fluoride residential structure fumigation must make sure that all handlers are provided and
correctly wear the required PPE. The PPE must be cleaned and maintained as required by
the Worker Protection Standard for Agricultural Pesticides."
Directions for Use
Under the section
"protection for
handlers"
Respirator
Availability for pre-
plant soil uses and
when chloropicrin is
"In case of emergency or the need for immediate respiratory protection, the fumigation
handler employer must make sure that the following PPE are immediately available to all
persons performing fumigant handling activities:
at least one air rescue device (e.g., SCBA) must be on-site in case of an
Directions for Use
Under the section
"protection for
handlers"
93
-------
used as a warning
prior to sulfuryl
fluoride residential
structure fumigations
emergency, and
unless an air-purifying respirator is being worn by each person performing a
handling task at the site, enough air-purifying respirators and face-sealing goggles
(if the respirator is a half-face style) of the type specified in the PPE section of
this labeling must be immediately available at the site for each handler."
PPE Requirements
Established by the
RED for all
Chloropicrin
formulations except
those formulated
with methyl bromide
or methyl iodide and
except when
chloropicrin is used
as a warning prior to
sulfuryl fluoride
residential structure
fumigations
(for formulations that
contain methyl
bromide see methyl
bromide RED and for
methyl iodide see
approved labels)
"Some materials that are chemical-resistant to this product are [registrant inserts correct
material(s)]." For more options, follow the instructions for category [insert A, B, C, D, E,
F, G or H] on the chemical-resistance category selection chart.
All fumigant handlers must wear:
Long-sleeved shirt and long pants,
Chemical-resistant footwear and socks,
Chemical-resistant gloves, such as barrier laminate or viton when handling liquid,
Chemical-resistant apron when handling liquid, and
Protective eyewear when handling liquid.
In addition, when air monitoring indicates a respirator is required, OR when repairing an
unperforated tarp within 14 days after the end of application, fumigant handlers must wear
either:
a respirator with an organic-vapor-removing cartridge with a prefilter approved
for pesticides (MSHA/NIOSH approval number prefix TC-23C), or
a respirator with a canister approved for pesticides (MSHA/NIOSH approval
number prefix TC-14G).
IMPORTANT; an air-supplying respirator [i.e., a respirator connected directly to a clean
air source or a self-contained breathing apparatus (SCBA)] is not permitted for routine
fumigant handler tasks. Such respirators are only permitted in emergencies such as a spill
or leak or when corrective action is needed to reduce air levels to acceptable levels."
Immediately
following/below
Precautionary
Statements:
Hazards to
Humans and
Domestic Animals
PPE Requirements
Established by the
RED when
chloropicrin is used
as a warning prior to
sulfuryl fluoride
residential structure
fumigations
"Some materials that are chemical-resistant to this product are [registrant inserts correct
material(s)]." For more options, follow the instructions for category [insert A, B, C, D, E,
F, G or H] on the chemical-resistance category selection chart.
All fumigant handlers must wear:
Long-sleeved shirt and long pants,
Chemical-resistant footwear and socks,
Chemical-resistant gloves, such as barrier laminate or viton when handling liquid,
Chemical-resistant apron when handling liquid, and
Protective eyewear when handling liquid.
A half-face, full-face, or helmet/hood style respirator with
o an organic-vapor-removing cartridge with a prefilter approved for
pesticides (MSHA/NIOSH approval number prefix TC-23C), or
o a canister approved for pesticides (MSHA/NIOSH approval number
prefix TC-14G).
IMPORTANT; an air-supplying respirator [i.e., a respirator connected directly to a clean
air source or a self-contained breathing apparatus (SCBA)] is not permitted for routine
fumigant handler tasks. Such respirators are only permitted in emergencies such as a spill
or leak or when corrective action is needed to reduce air levels to acceptable levels."
Immediately
following/below
Precautionary
Statements:
Hazards to
Humans and
Domestic Animals
For pre-plant soil
use.
Fumigant Air
"Fumigant Air Monitoring: The following air monitoring procedures must be followed
to determine whether respiratory protection is required for any person performing a
fumigant handling task as defined in this labeling.
* Air monitoring samples for chloropicrin must be collected in the breathing zone of a
Directions for Use
94
-------
Monitoring for all
Chloropicrin
Formulations except
methyl bromide or
methyl idodide (for
formulations with
methyl bromide see
the RED, or methyl
iodide see approved
labels.
handler performing a representative handling task starting approximately 30 minutes
from the handler's initial exposure and at least once every 2 hours thereafter.
To monitor air concentration levels, a direct reading detection device, such as a
Matheson-Kitagawa, Draeger, or Sensidyne device must be used. The devices must
have sensitivity of at least 0.15 ppm for chloropicrin.
If at any time (1) chloropicrin concentrations are greater than or equal to 0.15 ppm, or
(2) any handler experiences sensory irritation, then an air-purifying respirator as
specified in the PPE section of this label must be worn by all handlers.
If two consecutive breathing zone samples taken at least 30 minutes apart, show levels
have decreased to less than 0.15 ppm for chloropicrin, then handlers may remove the
respirators.
If at any time (1) a handler experiences any sensory irritation when wearing a
respirator, or (2) any air sample is greater than or equal to 1.5 ppm for chloropicrin,
then all handler activities must cease and handlers must be removed from the
application block and surrounding buffer zone until corrective action has been taken.
During the corrective actions if chloropicrin air concentrations are greater than or
equal to 1.5 ppm, then a self-contained breathing apparatus (SCBA) must be worn.
In order to resume work activities:
> Two consecutive air samples for chloropicrin taken at the handling site at least 30
minutes apart must be less than 1.5 ppm for chloropicrin.
> During the collection of air samples an air purifying respirator must be worn by
the handler taking air samples.
> If chloropicrin concentrations are greater than or equal to 0.15 ppm, then handlers
resuming their handler activities must wear air-purifying respirator of the type
specified in the PPE section of this labeling."
User Safety
Recommendations
"User Safety Recommendations
Users should wash hands before eating, drinking, chewing gum, using tobacco, or using
the toilet.
Users should remove clothing/PPE immediately if pesticide gets inside. Then wash
thoroughly and put on clean clothing.
Users should remove PPE immediately after handling this product. As soon as possible,
wash thoroughly and change into clean clothing."
Precautionary
Statements under:
Hazards to
Humans and
Domestic Animals
immediately
following
Engineering
Controls
(Must be placed in
a box.)
User Safety
Requirements
"Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions
for washables exist, use detergent and hot water. Keep and wash PPE separately from
other laundry."
"Discard clothing and other absorbent materials that have been drenched or heavily
contaminated with this product's concentrate. Do not reuse them."
Precautionary
Statements:
Hazards to
Humans and
Domestic Animals
immediately
following the PPE
requirements
PPE Requirements
Established by the
RED
For all
Formulations
"Respirator fit testing, medical qualification, and training
Employers must ensure that all fumigant handlers are:
Fit-tested and fit-checked using a program that conforms to OSHA's requirements
(see 29CFR Part 1910.134)
Trained using a program that confirms to OSHA's requirements (see 29CFR Part
1910.134)
Examined by a qualified medical practitioner to ensure physical ability to safely
wear the style of respirator to be worn. A qualified medical practitioner is a physician or
Directions for Use
Under the section
"Protection for
Handlers"
95
-------
other licensed health care professional who will evaluate the ability of a worker to wear a
respirator. The initial evaluation consists of a questionnaire that asks about medical
conditions (such as a heart condition) that would be problematic for respirator use. If
concerns are identified, then additional evaluations, such as a physical exam, might be
necessary. The initial evaluation must be done before respirator use begins. Handlers
must be reexamined by a qualified medical practitioner if their health statue or respirator
style or use-conditions change."
For pre-plant soil
use.
Application
Requirements, when
tarps are used: Tarp
Perforation and/or
Removal
"Tarp Perforation and/or Removal
IMPORTANT: Persons perforating, repairing, removing, and/or monitoring tarps are
defined, within certain time limitations, as fumigant handlers (see definition of fumigant
handlers in this labeling) and must be provided the PPE and other protections for handlers
as required on this labeling and in the Worker Protection Standard for Agricultural
Pesticides.
Tarps used for fumigations must be perforated (cut, punched, poked, or sliced) only by
mechanical methods. Perforation by hand or with hand-held tools is prohibited.
Each tarp panel used for broadcast fumigation must be perforated using a lengthwise cut.
Tarps cannot be perforated until a minimum of 5 days (120 hours) have elapsed after the
fumigant injection into the soil is complete (e.g., after injection of the fumigant product
and tarps ~ if used ~ have been laid or after drip lines have been purged), unless an
adverse weather condition exists for broadcast applications. See below.
If tarps will be removed after perforation, tarp removal cannot begin until at least 24 hours
after tarp perforation is complete.
If tarps will NOT be removed after perforation, planting or transplanting cannot begin until
at least 48 hours after the tarp perforation is complete.
If tarps are left intact for a minimum of 14 days after fumigant injection into the soil is
complete, planting or transplanting may take place while the tarps are being perforated.
Adverse Weather Conditions Exception for broadcast applications only:
Tarps may be removed before the required 5 days (120 hours) if adverse conditions will
compromise the integrity of the tarp, provided that:
At least 48 hours have passed after the fumigant injection into the soil is complete,
The buffer zone period is extended until 24 hours after tarp removal is complete,
Subsequent fumigations of untreated areas within the application block do not occur
for at least 24-hours after tarp removal is complete, and
Appropriate PPE, respiratory protection, air monitoring and other requirements for the
protection of handlers are met."
Direction For Use
For pre-plant soil
use.
Monitoring Air
Concentration Levels
"Monitoring Air Concentrations in the Buffer Zone Areas: When air concentration
levels must be monitored (i.e., as specified in the general buffer zone requirements
section), use a direct reading detection device, such as a Matheson-Kitagawa, Draeger, or
Sensidyne device. The devices must have sensitivity of at least 0.15 ppm for
chloropicrin."
Directions for Use
under the heading
"General Buffer
Zone
Requirements"
Agriculture Use
Requirements box
Agricultural Use Requirements
After the standard paragraphs for the Agricultural Use Requirements box, substituted the
following text for the standard restricted-entry interval and double notification
Agricultural Use
Requirements box
96
-------
requirements:
"For entry prohibition and notification requirements, see the "Application Block Entry
Prohibition and Notification" section of this labeling."
For pre-plant soil
use.
Entry Prohibitions
"Entry Prohibitions
Entry (including early entry that would otherwise be permitted under the WPS) by any
person - other than a correctly trained and PPE-equipped handler who is performing a
handling task listed on this labeling - is PROHIBITED - from the start of the application
until:
5 days (120 hours) after application has ended for untarped applications.
5 days (120 hours) after application is complete if tarps are not perforated and
removed for at least 14 days following application, or
48 hours after tarps perforation is complete if they will not be removed for at
least 14 days following application, or
until tarp removal is completed if tarps are both perforated and removed less than
14 days after application.
NOTE: see Tarp Perforation and Removal section on this labeling for requirements about
when tarps are allowed to be perforated."
Directions for Use
under the heading
"heading
"Application
Block Entry
Prohibition and
Notification"
For pre-plant soil
use.
Notification
Requirement for the
treated area
"NOTIFICATION: Notify workers of the application by warning them orally and by
posting fumigant warning signs. The signs must bear the skill and crossbones symbol and
state:
- "DANGER/PELIGRO,"
- "Area under fumigation, DO NOT ENTER/NO ENTRE,"
"[Name of fumigant] Fumigant in USE,"
~ the date and time of fumigation,
~ the date and time entry prohibition period is over,
~ Name of this product, and
~ Name, address, and telephone number of the certified applicator in charge of the
fumigation.
Post the fumigant warning sign instead of the WPS sign for this application but follow all
WPS requirements pertaining to location, legibility, size, and timing of posting and
removal.
Post the fumigant warning signs at all entrances to the application block (i.e., the
greenhouse or field or portion of a field treated with a fumigant in any 24-hour period)"
Direction for Use
under the heading
"Application
Block Entry
Prohibition and
Notification"
For pre-plant soil
use.
Mandatory Good
Agricultural
Practices for all
formulations
"Good Agricultural Practices (GAPs)
The following GAPs must be followed during all fumigant applications. All measurements
and other documentation planned to ensure that the mandatory GAPs are achieved must be
recorded in the FMP and/or the post-application summary report.
Tarps (when tarps are used in chloropicrin applications).
A written tarp plan must be developed that includes:
o schedule and procedures for checking tarps for damage, tears, and other problems
o plans for determining when and how repairs to tarps will be made, and by whom
o minimum time following injection that tarp will be repaired
o minimum size of tarp damage that will be repaired
o other factors used to determine when tarp repair will be conducted:
Directions for Use
under "Mandatory
Good Agricultural
Practices"
97
-------
schedule, equipment, and methods used to perforate tarps
aeration plans and procedures following perforation of tarp, but prior to tarp
removal or planting/transplanting
schedule, equipment, and procedures for tarp removal
The written tarp plan must be included in the site specific fumigant management plan
(FMP) as described in the FMP section below.
Weather Conditions
Prior to fumigation the weather forecast for the day of the application and the 48-hour
period following the fumigant application must be checked.
Do not apply fumigant if ground-level winds are less than 2 mph.
Applications must not occur during a temperature inversion or when temperature
inversions are forecasted to persist for more than 6 consecutive hours for the 36-hour
period after application.
o Visual features that could indicate an inversion is occurring are misty
conditions during day or night, and clear night skies.
Detailed local forecasts for sky conditions, weather conditions, wind speed, and
forecasted temperature inversions may be obtained on-line at
http://www.nws.noaa.gov.
For further guidance, contact the local National Weather Service Forecasting Office.
Soil Temperature
The maximum soil temperature at the depth of injection shall not exceed 90 degrees F
at the beginning of the application.
o If air temperatures have been above 100 degrees F for more than three hours in
any of the three days prior to application, then soil temperature shall be measured
and recorded in the FMP.
Soil Moisture
The soil must be moist two to six inches below the surface. The amount of moisture
needed in this zone will vary according to soil type and shall be determined using
standard feel testing methods (see below). Surface soil generally dries rapidly and
must not be considered in this determination.
If there is insufficient moisture two to six inches below the surface, the soil moisture
must be adjusted. If irrigation is not available and there is adequate soil moisture
below six inches, soil moisture can be brought to the surface by discing or plowing
before injection. To conserve existing soil moisture, pretreatment or treatment tillage
should be done as close to the time of application as possible.
Soil Moisture Determination
The soil shall contain at the time of application enough moisture two to six inches
below the surface to meet the following criteria as appropriate for the soil texture.
For fine textured soils (clay loam, silly clay loam, sandy clay, silty clay, sandy clay
loam and clay) there must be enough moisture so that the soil is pliable, not crumbly,
but does not form a ribbon when squeezed between the thumb and forefinger.
For coarse soils (sand and loamy sand) there must be enough moisture to allow
formation of a weak ball when compressed in the hand. Due to soil texture, this ball is
easily broken with little disturbance.
For medium textured soils (coarse sandy loam, sandy loam, and fine sandy loam)
there must be enough moisture to allow formation of a ball which holds together with
moderate disturbance, but does not stick between the thumb and forefinger.
For fields with more than one soil texture, soil moisture content in the lightest
textured (most sandy) areas must comply with this soil moisture requirement.
Whenever possible, the field should be divided into areas of similar soil texture and
98
-------
the soil moisture of each area should be adjusted as needed. Coarser textured soils can
be fumigated under conditions of higher soil moisture than finer textured soils;
however, if the soil moisture is too high, fumigant movement will be retarded and
effectiveness of the treatment will be reduced. Previous and/or local experience with
the soil to be treated or the crop to be planted can often serve as a guide to conditions
that will be acceptable. If there is uncertainty in determining the soil moisture content
of the area to be treated, local extension service or soil conservation service specialist
or pest control advisor (ag consultant) should be consulted for assistance.
Soil Preparation
Soil shall be properly prepared and at the surface generally be free of clods that are
golf ball size or larger. The area to be fumigated shall be tilled to a depth of 5 to 8
inches.
Field trash must be properly managed. Residue from a previous crop must be worked
into the soil to allow for decomposition prior to fumigation. Little or no crop residue
shall be present on the soil surface. Crop residue that is present must not interfere with
the soil seal.
Soil Sealing
For Broadcast Untarped Applications: Use a disc or similar equipment to uniformly
mix the soil to at least a depth of 3 to 4 inches to eliminate the chisel or plow traces.
Following elimination of the chisel trace, the soil surface must be compacted with a
cultipacker, ring roller, and roller in combination with tillage equipment.
For Bedded Applications'. Performed beds shall be sealed by disruption of the chisel
trace using press sealers, bed shapers, cultipackers, or by re-shaping (relisting, lifting
and replacing, etc.) the beds immediately following injection. Beds formed at the time
of application shall be sealed by disrupting the chisel trace using press sealers, or bed
shapers.
5*0/7 Sealing for Tarped Applications'. The use of a tarp does not eliminate the need to
minimize chisel traces prior to application of the tarp, such as by using a nobel plow or
other injection shank that disrupts the chisel traces.
Chloropicrin Bedded and Broadcast Shank Applications: Additional GAPs
In addition to the GAPs required for all Chloropicrin soil fumigation applications, the
following GAPs apply for injection applications:
Tarps
Tarps must be installed immediately after the fumigant is applied to the soil.
Soil Preparation
Trash pulled by the shanks to the ends of the field must be covered with tarp, or soil,
depending on the application method before making the turn for the next pass.
Application Depth
For Tarped-Broadcast and Tarped-Bedded Applications: The injection point shall be
a minimum of 8 inches from the nearest final soil/air interface.
For Untarped-BeddedApplications'. The injection point shall be a minimum of 12
inches from the nearest final soil/air interface.
For Untarped-Broadcast Applications'. The injection point shall be a minimum of 10
inches from the nearest final soil/air interface.
Prevention of End Row Spillage
Do not apply or allow fumigant to drain onto the soil surface. For each injection line
either have a check valve located as close as possible to the final injection point, or
99
-------
drain/purge the line of any remaining fumigant prior to lifting injection shanks from
the ground.
Do not lift injection shanks from the soil until the shut-off valve has been closed and
the fumigant has been depressurized (passively drained) or purged (actively forced out
via air compressor) from the system.
Calibration, Set-up, Repair, and Maintenance for Application Rigs
Brass, carbon steel or stainless steel fittings must be used throughout.
Polyethylene tubing, polypropylene tubing, Teflonฎ tubing or Teflonฎ -lined
steel braided tubing must be used for all low pressure lines, drain lines, and
compressed gas or air pressure lines. All other tubing must be Teflonฎ -lined
steel braided.
Galvanized, PVC, nylon or aluminum pipe fittings must not be used.
All rigs must include a filter to remove any particulates from the fumigant, and a
check valve to prevent backflow of the fumigant into the pressurizing cylinder or
the compressed air system.
Rigs must include a flowmeter or a constant pressure system with orifice plates to
insure the proper amount of fumigant is applied.
To prevent the backflow of fumigant into the compressed gas cylinder (e.g.
nitrogen, other inert gas or compressed air), if used, applicators must:
o Ensure that positive pressure is maintained in the cylinder at not less than
200 psi during the entire time it is connected to the application rig, if a
compressed gas cylinder is used. (This is not required for a compressed
air system that is part of the application rig because if the compressor
system fails the application rig will not be operable)
o Ensure that application rigs are equipped with properly functioning
check valves between the compressed gas cylinder or compressed air
system and the fumigant cylinder. The check valve is best placed on the
outlet side of the pressure regulator, and is oriented to only allow
compressed gas to flow out of the cylinder or compressed air out of the
compressed air system.
o Always pressurize the system with compressed gas or by use of a
compressed air system before opening the fumigant cylinder valve.
Before using a fumigation rig for the first time, or when preparing it for use after
storage, the operator must check the following items carefully:
o Check the filter, and clean or replace the filter element as required.
o Check all tubes and chisels to make sure they are free of debris and
obstructions.
o Check and clean the orifice plates and screen checks, if installed.
o Pressurize the system with compressed gas or compressed air, and check
all fittings, valves, and connections for leaks using soap solution.
Install the fumigant cylinder, and connect and secure all tubing. Slowly open the
compressed gas or compressed air valve, and increase the pressure to the desired
level. Slowly open the fumigant cylinder valve, always watching for leaks.
When the application is complete, close the fumigant cylinder valve and blow
residual fumigant out of the fumigant lines into the soil using compressed gas or
compressed air. At the end of the application, disconnect all fumigant cylinders
from the application rig. At the end of the season, seal all tubing openings with
tape to prevent the entry of insects and dirt.
Application equipment must be calibrated and all control systems must be working
properly. Proper calibration is essential for application equipment to deliver the correct
amount of fumigant uniformly to the soil. Refer to the manufacturer's instructions on how
to calibrate your equipment, usually the equipment manufacturer, fumigant dealer, or
Cooperative Extension Service can provide assistance.
100
-------
Chloropicrin Drip Applications: Additional GAPs
In addition to the GAPs required for all chloropicrin soil fumigation applications, the
following GAPs apply for drip applications:
Soil Preparation
Till fields with known plowpans because they can lead to puddling of the fumigant
due to inadequate soil drainage.
Product and Dosage
Plan the application by calculating the amount of fumigant required at the
appropriate rate for the crop, acreage and target pest. Fumigant must be metered
into the water supply line and then passed through a mixing device, such as a
centrifugal pump or static mixer, to assure proper agitation.
System Controls and Integrity
The irrigation system (main lines, headers, drip tape) must be thoroughly checked
for leaks before the start of application. Leak detection requires that the irrigation
system be at full operating pressure. The amount of time needed at full operating
pressure will vary by irrigation system design. Look for puddling along major
pipes (holes in pipes or leaky joints), at the top and ends of rows (leaky
connection, open drip tape), and on the bed surface (damaged drip tape,
malfunctioning emitters). Any leaks discovered during the pre-application check
must be repaired prior to fumigant application.
To inject fumigant, use a metering system (such as a positive pressure system,
positive displacement injection pump, diaphragm pump, or a Venturi system)
effectively designed and constructed of materials that are compatible with the
fumigant and capable of being fitted with system interlocking controls. Do not
use containers pumps or other equipment made of aluminum, magnesium or their
alloys as chloropicrin can be corrosive to such metals.
The system must contain:
o A functional check valve and low-pressure drain appropriately located
on the irrigation pipeline to prevent water source contamination and
backflow;
o A functional, automatic, quick-closing check valve to prevent the flow of
fluids back toward the fumigant container;
o A functional, normally closed valve located on the intake side of the
injection point and connected to the system interlock to prevent the
fumigant from being withdrawn from the supply tank when the irrigation
system is either automatically or manually shut down;
o Functional interlocking controls to automatically shut off the fumigant
injection when the irrigation water flow stops or decreases to the point
where fumigant distribution is adversely affected.
Site of Injection and Irrigation System Layout
Site of injection must be as close as practical to the area being treated (such as
direct injection of fumigant into the header pipe/manifold or into an aboveground
delivery pipe attached to the header). If the fumigant is injected into a main line,
make sure the irrigation pipe is able to be cleared of all fumigant as the fumigant
may pool in low sections of the pipe. Also make sure that valves on lateral lines
of the main line are closed, if these lateral lines lead to areas not being fumigation
at the time of the application.
System Flush
101
-------
After application of the fumigant, continue to drip-irrigate the area with water to
flush the irrigation system. Do not allow the fumigant to remain in the irrigation
system after the application is complete. The total volume of water, including the
amount used for flushing the irrigation system, must be adequate to completely
remove the fumigant from the lines, but should be less than the amount that could
over-saturate the beds (bed collapse can occur from over-saturation). If common
lines are used for both the fumigant application and water seal (if a water seal is
applied) these lines must be adequately flushed before starting the water seal
and/or normal irrigation practices.
Soil Sealing
Tarps must be put in place before the fumigation begins.
Tarps must be used for drip applications.
o Based on the Agency's review of the recently submitted data for
untarped drip applications, this GAP may change.
Tarp edges must be buried along the furrow and at the ends of rows.
Chloropicrin Tree Replant Application: GAPs
This application method is used when chloropicrin is applied to individual tree sites in an
existing orchard where shank or drip application are not possible.
In addition to the GAPs required for all chloropicrin soil fumigation applications, the
following GAPs apply for chloropicrin tree replant applications:
Site Preparation
Each individual tree-site must remove the tree stump and primary root system
with a back-hoe or other similar equipment, for example an auger.
The hole must be backfilled with soil before application.
Application Depth
The fumigant must be injected at least 18 inches into the soil.
System Flush
Before removing the application wand from the soil the wand must be cleared
using nitrogen or compressed air.
Soil Sealing
After the wand is cleared and removed from the soil, the injection hole must be
either covered with soil and tamp or the soil must be compacted over the injection
hole."
For pre-plant soil
use.
Site-Specific
Fumigation
Management Plans
for all chloropicrin
end-use products.
"Site-Specific Fumigation Management Plan (FMP)
Prior to the start of fumigation, the certified applicator supervising the application must
verify that a site-specific fumigation management plan (FMP) exists for each application
block (i.e., a greenhouse or field or portion of a field treated with a fumigant in any 24-
hour period). The FMP may be prepared by the certified applicator, the site
owner/operator, registrant, or other party. The certified applicator must verify in writing
the site-specific FMPs reflects current site conditions before the start of fumigation.
General site information
o Site address or description of location
o Site operator/owner's name, address, and, phone number
o Map, aerial photo, or detailed sketch showing field location, dimensions,
buffer zones, property lines, public roads, bus stops, water bodies, wells,
rights-of-ways inside buffers, nearby application blocks, surrounding
In the Directions
for Use for Pre-
plant soil
fumigation under
the heading, "Site-
Specific
Fumigation
Management Plan
(FMP)"
102
-------
structures (occupied and non-occupied), locations of posted signs for
buffers, and sites requiring YA mile buffer zones (e.g., prisons, schools,
hospitals, state licensed day care centers) with distances from the
application site labeled
Applicator information (license number, address, phone number, contact
information for person supervising the fumigation with location and date for
completing the registrant's chloropicrin training program)
Authorized on-site personnel (Names of all handlers and the tasks they are
authorized and trained to perform)
Application procedures
o Fumigation window (target application date, earliest and latest possible
date of fumigation)
o Product information (brand name, registration number)
o Type of fumigation (e.g., shank, broadcast, drip, raised bed, strip, etc.)
o Target application rate and application block size
Good Agricultural Practices (GAPs)
o Description of applicable mandatory GAPs (registrants may also include
optional GAPs)
o Measurements and other documentation planned to ensure GAPs are
achieved (e.g. measurement of soil and other site conditions, tarp
repair/perforation/removal plans, etc.)
Buffer zones
o Calculations and rationale for buffer zones distances (e.g. specify table
from label that distances are based on, rate and block size, applicable
credits applied)
o Start and stop times for buffer zones
Respirators and other personal protective equipment (PPE) for handlers
(respirator type, respirator cartridge, and other PPE selection; verification that
respirator training/fit-testing/medical exams is current; and maintenance/storage
procedures)
Air monitoring
o Type of samples that will be collected (e.g., occupational, in occupied
structures, outside buffer zone area if site monitoring is conducted, etc.)
o When and where samples will be collected
o Duration of samples
o Sampling methods and equipment
o Name, address, and, phone number of person taking samples
Posting (names of persons who will post signs, location of posting signs,
procedures for posting and sign removal)
Site-Specific response and management
o Fumigant site monitoring
Description of who, when, where, and procedures for
monitoring buffer zone perimeter
o Response information for neighbors
List of residences and businesses informed (neighboring
property owners)
Method of sharing information
State and tribal lead agency notification
o Include the information that is sent to the lead agency
Plan describing how communication will take place between applicator, land
owner/operator, and other on-site handlers (tarp cutters/removers, irrigators, etc.)
Record keeping procedures
Emergency procedures (evacuation routes, locations of telephones, contact
information for first responders, local/state/federal contacts, key personnel and
emergency procedures/responsibilities in case of an incident, equipment/tarp/seal
103
-------
failure, odor complaints or elevated air concentration levels outside buffer zone
suggesting potential problems, or other emergencies).
Hazard communication (product labels, material safety data sheets, etc.)
For situations where an initial FMP is developed and certain elements do not change for
multiple fumigation sites (e.g. applicator information, authorized on-site personnel, record
keeping procedures, emergency procedures, etc.) only elements that have changed need to
be updated in the site-specific FMP provided the following:
> The certified applicator supervising the application has verified that those
elements are current and applicable to the application block before it is fumigated
and has documented the verification in the site-specific FMP; and
> Recordkeeping requirements are followed for the entire FMP (including elements
that do not change)
The employer of fumigant handlers must make the FMP available to each of their handler
employees involved in the fumigation.
The certified applicator and owner/operator of the application block must provide a copy
of the FMP to handlers who are involved in the fumigation, workers in adjacent areas to
the application block, and federal/state/local enforcement personnel, upon request.
Within 30 days of completing the application portion of the fumigation process, the
certified applicator supervising the application must complete a post-fumigation
application summary that describes any deviations from FMP that have occurred,
measurements taken to comply with GAPs as well as any complaints and/or incidents that
have been reported to him/her. The summary must include the actual date of the
application, application rate, and size of application block fumigated."
The certified applicator who supervised the fumigation and the owner/operator of the
agricultural establishment where the fumigation took place must keep a signed copy of the
site-specific FMPs and the post-application summary record for at least 2 years following
the application and must make them available, upon request, to Federal, state, tribal, and/or
local enforcement personnel.
For pre-plant soil
use.
Information
Exchange
"When the certified applicator supervising the application leaves the application site after
the application portion of the fumigation process is complete and other persons will be
performing handler tasks (see the handling activities listed elsewhere in this labeling), the
certified applicator must communicate in writing all of the requirements on this labeling
with respect to the fumigation process and protection of handlers to the owner/operator of
the agricultural establishment where the fumigation is taking place.
IMPORTANT: this requirement does not override the requirements in the Worker
Protection Standard for Agricultural Pesticides for information exchange between
owners/operators of agricultural establishments and commercial pesticide applicators."
For pre-plant soil
use.
General Buffer
Zones requirements
for all formulations
"General Buffer Zone Requirements
A "buffer zone" must be established for every fumigant application The following
describes the general buffer zone requirements:
"Buffer zone" is an area established around the perimeter of each application block or
greenhouse where a soil fumigant is applied. The buffer zone must extend from the
edge of the application block perimeter equally in all directions.
All non-handlers including field workers, nearby residents, pedestrians, and other
bystanders, must be excluded from the buffer zone during the buffer zone period
except for certain persons in transit (see exemptions section).
In the Directions
for Use for Pre-
plant soil
fumigation under
the heading
"General Buffer
Zone
Requirements"
104
-------
An "application block" is a greenhouse or field or portion of a field treated with a
fumigant in any 24-hour period (see Figures 1 and 2 above for further explanation).
The "buffer zone period" starts at the moment when any fumigant is
delivered/dispensed to the soil within the application block and lasts for a minimum of
48 hours after the fumigant has stopped being delivered/dispensed to the soil.
Buffer zone distances
Buffer zone distances must be based on look-up tables on product labels (25 feet is the
smallest distance regardless of site-specific application parameters).
For selective replant fumigation in an orchard using hand held application methods
(e.g., deep injection auger probes), the minimum buffer zone will be 25 feet measured
from the center of each injection site (i.e., tree hole).
Authorized entry to buffer zones
Only authorized handlers who have been properly trained and equipped according to
EPA's Worker Protection Standard (WPS) and label requirements may be in the buffer
zone during the buffer zone period.
Buffer zone proximity
To reduce the potential for off-site movement from multiple fumigated fields, buffer
zones for products containing chloropicrin from multiple application blocks may not
overlap (including blocks fumigated by adjacent property owners; see below for
exemptions for areas not under the control of owner/operator of application block).
No fumigant applications will be permitted within 0.25 miles of schools, state licensed
day care centers, nursing homes, assisted living facilities, elder care facilities,
hospitals, in-patient clinics and prisons if occupied during the buffer zone period.
Exemptions for transit through buffer zones
Vehicular and bicycle traffic on public and private roadways through the buffer zone
is permitted. "Roadway" means that portion of a street or highway improved, designed
or ordinarily used for vehicular travel, exclusive of the sidewalk or shoulder even
though such sidewalk or shoulder is used by persons riding bicycles. In the event a
highway includes two or more separated roadways, the term "roadway" shall refer to
any such roadway separately.
Bus stops or other locations where persons wait for public transit are not permitted
within the buffer zone.
See posting section for additional requirements that may apply.
Structures under the control of owner/operator of the application block
Buffer zones may not include buildings used for storage such as sheds, barns, garages,
etc., UNLESS,
1. The storage buildings are not occupied during the buffer zone period, and
2. The storage buildings do not share a common wall with an occupied structure.
See posting section for additional requirements that may apply.
Areas not under the control of owner/operator of the application block
Buffer zones may not include residential areas (including employee housing, private
property, buildings, commercial, industrial, and other areas that people may occupy or
outdoor residential areas, such as lawns, gardens, or play areas, UNLESS,
1. The occupants provide written agreement that they will voluntarily vacate the
buffer zone during the entire buffer zone period, and
2. Reentry by occupants and other non-handlers must not occur until,
0 The buffer zone period has ended, and
0 Two consecutive air samples for chloropicrin taken in the structure at least 1 hour
apart indicate less than less than 0.15 ppm chloropicrin is present.
105
-------
Buffer zones may not include agricultural areas owned/operated by persons other than
the owner/operator of the application block, UNLESS,
1. The owner/operator of the application block can ensure that the buffer zone will
not overlap with a buffer zone from any adjacent property owner, and
2. The owner/operator of the areas that are not under the control of the application
provides written agreement to the certified applicator supervising the fumigant
application that they, their employees, and other persons will stay out of the buffer
zone during the entire buffer zone period.
Buffer zones may not include publicly owned and/or operated areas (e.g., parks, rights
of way, side walks, walking paths, playgrounds, athletic fields, etc), UNLESS,
1. The area is not occupied during the buffer zone period,
2. Entry by non-handlers is prohibited during the buffer zone period, and
Written permission to include the public area in the buffer zone is granted by the
appropriate state and/or local authorities responsible for management and operation of the
area."
For pre-plant soil
use.
Buffer Zone
Distances for
chloropicrin only
formulations,
chloropicrin and
methyl bromide
formulations,
chloropicrin and
methyl iodide
formulations, and
chloropicrin and 1,3-
D formulations.
"Buffer Zone Distances
Buffer zone distances must be calculated using the application rate and the size of the
application block.
In the Directions
for Use for Pre-
plant soil
fumigation under
the heading "
Buffer Zone
Distances"
Figure 1. Broadcast Application
Figure 2. Bedded Application
In Figures 1 and 2, the dashed line represents the perimeter of the field, the shaded area is
the portion of the field that is treated, and the un-shaded area is the area of the field that is
untreated. Assuming both fields are 10 acres, and only 50% of field in figure 2 is
fumigated, the rate per treated acre is 400 Ibs ai/A for both Figure 1 and 2. The broadcast
rate for figure 1 is 400 Ib ai/A but the effective broadcast equivalent rate for Figure 2 is
200 Ibs ai/A. The buffer zone distances must be based on the broadcast or effective
broadcast equivalent rates."
Note to registrant: Labels may express rates as Ibs per treated acre under the application
instructions but they must identify buffer zone distances based on the broadcast or
effective broadcast equivalent rates.
"For selective replant fumigation in an orchard using hand-held application methods (e.g.,
deep injection auger probes), the minimum buffer zone will be 25 feet measured from the
center of each injection site.
106
-------
For all other applications, the following tables must be used to determine the buffer
distances. Round-up to the nearest rate and block size, where applicable.
Buffer Zone Look-up Table for Shank Bedded with Tarps
[For chloropicrin only see Table 15 below.
See driver table below for formulations of chloropicrin and methyl bromide. If methyl
bromide is the driver insert Table 2 from MeBr RED. If chloropicrin is the driver insert
Table 15 below.
When chloropicrin is used in combination with methyl iodide, please refer to the Agency
for appropriate buffer table.
When chloropicrin is used in combination with 1,3-dichloropropene, the buffer zone must
meet all of the generic requirements for chloropicrin. Also to clarify which buffer must be
used, 1,3-D labels that contain chloropicrin must delete the current buffer zone language,
and replace it with, "The buffer zone for 1,3-D is 100 feet. This buffer zone does not apply
to soils that have not been treated with 1,3-D in the previous 3 years." If the chloropicrin
buffer as listed in Table 15 is greater than 100 feet, the chloropicrin buffer must be used. If
the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the
previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the
previous 3 years, the buffer is determined by Table 15 below.]
Buffer Zone Look-up Table for Shank Bedded with Tarps if the application occurs 1
hour before sunset and 1 hour after sunrise
[For chloropicrin only see Table 16 below.
See driver table below for formulations of chloropicrin and methyl bromide. If methyl
bromide is the driver insert Table 2 from MeBr RED. If chloropicrin is the driver insert
Table 16 below.
When chloropicrin is used in combination with methyl iodide, please refer to the Agency
for appropriate buffer table.
When chloropicrin is used in combination with 1,3-dichloropropene, the buffer zone must
meet all of the generic requirements for chloropicrin. Also to clarify which buffer must be
used, 1,3-D labels that contain chloropicrin must delete the current buffer zone language,
and replace it with, "The buffer zone for 1,3-D is 100 feet. This buffer zone does not apply
to soils that have not been treated with 1,3-D in the previous 3 years." If the chloropicrin
buffer as listed in Table 16 is greater than 100 feet, the chloropicrin buffer must be used. If
the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the
previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the
previous 3 years, the buffer is determined by Table 16 below.]
Buffer Zone Look-up Table for Shank Broadcast with Tarps
[For chloropicrin only see Table 15 below.
See driver table below for formulations of chloropicrin and methyl bromide. If methyl
bromide is the driver insert Table 3 from MeBr RED. If chloropicrin is the driver insert
Table 15 below.
When chloropicrin is used in combination with methyl iodide, please refer to the Agency
for appropriate buffer table.
When chloropicrin is used in combination with 1,3-dichloropropene, the buffer zone must
107
-------
meet all of the generic requirements for chloropicrin. Also to clarify which buffer must be
used, 1,3-D labels that contain chloropicrin must delete the current buffer zone language,
and replace it with, "The buffer zone for 1,3-D is 100 feet. This buffer zone does not apply
to soils that have not been treated with 1,3-D in the previous 3 years." If the chloropicrin
buffer as listed in Table 15 is greater than 100 feet, the chloropicrin buffer must be used. If
the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the
previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the
previous 3 years, the buffer is determined by Table 15 below.]
Buffer Zone Look-up Table for Shank Bedded without Tarps
[For chloropicrin only see Table 17 below.
When chloropicrin is used in combination with 1,3-dichloropropene, the buffer zone must
meet all of the generic requirements for chloropicrin. Also to clarify which buffer must be
used, 1,3-D labels that contain chloropicrin must delete the current buffer zone language,
and replace it with, "The buffer zone for 1,3-D is 100 feet. This buffer zone does not apply
to soils that have not been treated with 1,3-D in the previous 3 years." If the chloropicrin
buffer as listed in Table 17 is greater than 100 feet, the chloropicrin buffer must be used. If
the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the
previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the
previous 3 years, the buffer is determined by Table 17 below.]
Buffer Zone Look-up Table for Shank Broadcast without Tarps
[For chloropicrin only see Table 18 below.
When chloropicrin is used in combination with 1,3-dichloropropene, the buffer zone must
meet all of the generic requirements for chloropicrin. Also to clarify which buffer must be
used, 1,3-D labels that contain chloropicrin must delete the current buffer zone language,
and replace it with, "The buffer zone for 1,3-D is 100 feet. This buffer zone does not apply
to soils that have not been treated with 1,3-D in the previous 3 years." If the chloropicrin
buffer as listed in Table 18 is greater than 100 feet, the chloropicrin buffer must be used. If
the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the
previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the
previous 3 years, the buffer is determined by Table 18 below.]
Buffer Zone Look-up Table for Shank Deep Broadcast without Tarps
[For chloropicrin only see Table 19 below.
See driver table below for formulations of chloropicrin and methyl bromide. If methyl
bromide is the driver insert Table 4 from MeBr RED. If chloropicrin is the driver insert
Table 19 below.
When chloropicrin is used in combination with 1,3-dichloropropene, the buffer zone must
meet all of the generic requirements for chloropicrin. Also to clarify which buffer must be
used, 1,3-D labels that contain chloropicrin must delete the current buffer zone language,
and replace it with, "The buffer zone for 1,3-D is 100 feet. This buffer zone does not apply
to soils that have not been treated with 1,3-D in the previous 3 years." If the chloropicrin
buffer as listed in Table 19 is greater than 100 feet, the chloropicrin buffer must be used. If
the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the
previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the
previous 3 years, the buffer is determined by Table 19 below.]
Buffer Zone Look-up Table for Drip Irrigation with Tarps
[For chloropicrin only see Table 20 in the chloropicrin RED.
When chloropicrin is used in combination with 1,3-dichloropropene, the buffer zone must
108
-------
meet all of the generic requirements for chloropicrin. Also to clarify which buffer must be
used, 1,3-D labels that contain chloropicrin must delete the current buffer zone language,
and replace it with, "The buffer zone for 1,3-D is 100 feet. This buffer zone does not apply
to soils that have not been treated with 1,3-D in the previous 3 years." If the chloropicrin
buffer as listed in Table 20 is greater than 100 feet, the chloropicrin buffer must be used. If
the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the
previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the
previous 3 years, the buffer is determined by Table 20 below.]
Buffer Zone Look-up Table for Pre-Plant Greenhouse Applications with Tarps
[For chloropicrin only see Table 21 below.
When chloropicrin is used in combination with 1,3-dichloropropene, the buffer zone must
meet all of the generic requirements for chloropicrin. Also to clarify which buffer must be
used, 1,3-D labels that contain chloropicrin must delete the current buffer zone language,
and replace it with, "The buffer zone for 1,3-D is 100 feet. This buffer zone does not apply
to soils that have not been treated with 1,3-D in the previous 3 years." If the chloropicrin
buffer as listed in Table 21 is greater than 100 feet, the chloropicrin buffer must be used. If
the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the
previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the
previous 3 years, the buffer is determined by Table 21 below.]"
For pre-plant soil
use.
Buffer Zone Credits
"Buffer Zone Credits
The buffer zone distances for chloropicrin applications may be reduced by the percentages
listed below. Credits may be added, but credits cannot exceed 50%. Also the minimum
buffer zone distance is 25 feet regardless of buffer zone credits available. The maximum
buffer zone is 0.5 mile (2,640 feet), with or without credits.
40% reduction in buffer zone distance, IF using Bromostopฎ (1.38 mil), IPM Clear
VIF (1.38 mil), Eval/Mitsui (1.38 mil) tarps, Hytiblock 7 Black (0.00125"), XL Black
Blockade (0.00125"), and Hytibar (1.5 mil). The tarp brand name, manufacturer, lot
number, batch number, part number, and thickness must be recorded in the FMP.
50% reduction in buffer zone distance, IF the Symmetry application system is used
with one of the approved high barrier tarps AND the application rate is less than 100
Ibs ai/A.
5% reduction in buffer zone distance if potassium thiosulfate (KTS) is applied on top
of a tarped chloropicrin application. Apply KTS by sprinkler, and apply 25 gallons of
KTS per acre with enough water to wet the soil to a depth of 10 mm.
10% reduction in buffer zone distance, IF the organic content of soil in the application
block is greater than 3%. Record the measurements taken to verify the organic content
in the FMP.
10% reduction in buffer zone distance, IF the clay content of the soil in the application
block is greater than 27%. Record the measurements taken to verify the clay content
in the FMP.
Example of Buffer Calculation if a Credit is Applicable
Application Method: Shank, Tarp, Bed
Application Block size: 20 acres
Application Rate: 122.5 Ibs ai/A
Required Buffer Zone from Table 1: 350 feet
Use IPM Clear VIF (1.38 mil) tarp: 40% credit.
New Buffer Zone = required distance from appropriate table * (1-credit)
New Buffer Zone = 350 * (1-0.40)
In the Directions
for Use for Pre-
plant soil
fumigation under
the heading
"Buffer Zone
Credits"
109
-------
For pre-plant soil
use.
Posting
New Buffer Zone = 210 feet"
"Posting Fumigant Buffer Zones
Posting all entrances to the application block (i.e., the greenhouse or field or portion of
a field treated with a fumigant in any 24-hour period) is required for all soil fumigants
and use sites. The posting requirements for the application block are listed elsewhere
in this labeling.
Posting of the fumigation buffer zone is required, except when one of the following
conditions exist:
(1) if there is a physical barrier that prevents access into the buffer zone, such as a
fence or wall, that separates the edge of the buffer zone from workers or
bystanders, or
(2) if the area within 300 feet of the edge of the buffer zone is entirely controlled by
owner/operator of the application block (i.e. , the greenhouse or field or portion of
a field treated with a fumigant in any 24-hour period); however this exception
does not apply to any area under the control of the owner/operator that may be
used as housing for workers or other employees. IMPORTANT: if there is public
land or any land under someone else's control within 300 feet from the edge of
the buffer zone, the buffer zone must be posted.
If the buffer zone must be posted, signs must be placed at all usual points of entry and
along likely routes of approach from areas where people not under the control of the
application block's owner/operator may approach the buffer zone.
o Some examples of points of entry include, but are not limited to, roadways,
sidewalks, paths, and bike trails.
o When there are no usual points of entry, signs must be posted in the corners
of the buffer zone, between the corners of the buffer zone, and along sides so
that one sign can be viewed (not read) from the previous one.
o The buffer zone posting signs must remain posted at least until the end of the
buffer zone period and must be removed within 3 days after the end of the
buffer zone period.
Contiguous Application Blocks Exception: If multiple contiguous application blocks
are fumigated within a 14-day period, a buffer zone may be established starting from
the outer edge of the contiguous application blocks. This buffer zone is in effect from
the beginning of the first application until the buffer zone period for the last
application block has expired. The periphery of the buffer zone must be posted during
this entire period. Signs may remain posted until 3days after the buffer zone period
for the last application block has expired.
The buffer zone posting should meet the following standards:
o The printed side of the sign must face away from the buffer zone.
o Signs must remain legible during entire posting period.
o The signs at entrances to buffer zones must be removed by the certified
applicator in charge of the fumigation (or someone under his/her
supervision).
o The general standards for size and type of signs for the buffer zone signs
must follow the requirements in the Worker Protection Standard for
Agricultural Pesticides for treated area posting.
o The signs must remain visible and legible during the time they are posted."
Contents of Signs
The treated area sign must state the The buffer zone sign must state the
following: following:
~ Skull and crossbones symbol ~ Do not walk sign
In the Directions
for Use for Pre-
plant soil
fumigation under
the heading
"Posting"
110
-------
- "DANGER/PELIGRO,"
- "Area under fumigation, DO NOT
ENTER/NO ENTRE,"
"[Name offumigant] Fumigant in USE,"
- the date and time of fumigation,
- the date and time entry prohibition is
lifted
- brand name of this product, and
- name, address, and telephone number of
the certified applicator in charge of the
fumigation.
- "DO NOT ENTER/NO ENTRE,"
~ "[Name offumigant] Fumigant
BUFFER ZONE,"
~ the date and time of fumigation,
~ the date and time buffer zone
restrictions are lifted (i.e., buffer zone
period expires)
~ brand name of this product, and
~ name, address, and telephone number of
the certified applicator in charge of the
fumigation"
For pre-plant soil
use.
Site specific response
and management
"Site Specific Response and Management
The certified applicator must either follow the directions under the "fumigant site
monitoring" section or follow the directions under the "response information for
neighbors" section.
Fumigation Site Monitoring
From the beginning of the fumigant application until the buffer zone period expires, a
certified applicator or someone under his/her supervision must monitor the air
concentration levels of the fumigant in the area between the buffer zone and any residences
or businesses that trigger the 'response information for neighbors' requirement.
The person monitoring the air concentration levels must take readings starting
approximately 30 minutes from the start of application and at least once each hour
during the entire application and buffer zone period.
A direct reading detection device, such as a Draeger device with a sensitivity of at
least 0.15 ppm for chloropicrin must be used to monitor the air concentration levels of
chloropicrin.
If at any time (1) chloropicrin concentrations are greater than or equal to 0.15 ppm OR
(2) the person monitoring the air concentrations experiences sensory irritation, then
the emergency response plan stated in the FMP must be immediately implemented by
the person monitoring the air concentrations
If other problems occur, such as a tarp coming loose, then the appropriate control plan
must be activated.
The results of the air concentration monitoring must be recorded in the FMP.
Informing the appropriate federal, state or tribal lead agencies is still required.
Response Information for Neighbors
The certified applicator (or someone under his/her supervision) supervising the fumigation
must ensure that residences and owners/operators of businesses that meet the criteria below
have been provided the emergency response information at least 48 hours before
fumigation occurs. The information provided may include application dates that range for
no more than 2 weeks. After 2 weeks, the information must be delivered again.
Criteria for providing response information for neighbors:
In the Directions
for Use for Pre-
plant soil
fumigation under
the heading "Site
specific response
and management"
111
-------
If the buffer zone is less than or equal to 100 feet, then residences and businesses
within 50 feet from the edge of the buffer zone must be informed.
If the buffer zone is greater than 100 feet but less than or equal to 200 feet, then
residences and businesses within 100 feet from the edge of the buffer zone must be
informed.
If the buffer zone is greater than 200 feet but less than or equal to 300 feet, then
residences and businesses within 200 feet from the edge of the buffer zone must be
informed.
If the buffer zone is greater than 300 feet, then residences and businesses within 300
feet from the edge of the buffer zone must be informed.
Information that must be included:
Location of the application block and surrounding buffer zone
Fumigant(s) applied including EPA Registration #
Applicator and property owner/operator contact information
Time period that fumigation may occur (must not range more than 2 weeks)
Duration of buffer zone
The information must also include:
o information on what is being applied,
o signs and symptoms of exposure to the fumigant,
o what to do and who to call if you believe you are being exposed (911 in most
cases).
The method used to share the response information for neighbors must be described in
the FMP and may be accomplished through mail, door hangers, or through other
methods that will effectively inform people in residences and businesses within the
required distance from the edge of the buffer zone."
Notice to State and
Tribal Lead Agencies
"Notice to State and Tribal Lead Agencies
The state and tribal lead agency information must be provided to the appropriate state or
tribal lead agency in a written format prior to the application.
The information that must be provided to state and tribal lead agencies includes the
following:
o Location of the application block and surrounding buffer zone,
o Fumigant(s) applied including EPA Registration #,
o Applicator and property owner/operator contact information,
o Time period that fumigation may occur (must not range more than 2
weeks),
o Duration of buffer zone."
Directions for Use
under "Notice to
State and Tribal
Lead Agencies"
For pre-plant soil
use.
Application
Restrictions
"Maximum Application Rates for Pre-Plant Soil Uses
350 Ibs a.i. per treated acre for tarped, shank injection applications;
175 Ibs a.i. per treated acre for untarped, shank injection applications;
300 Ibs a.i. per treated acres for drip irrigation applications (including
greenhouses);
500 Ibs a.i. per treated acre, this is equivalent to 1 Ib per 100 square feet,
for tree hole replant applications (small area)."
In the Directions
for Use for Pre-
plant soil
fumigation under
the heading
"Maximum
Application Rates
for Pre-Plant Soil
Fumigation"
within its own box
For pre-plant soil
use.
"The maximum area that can be treated is 50,000 square feet.
In the Directions
for Use for Pre-
112
-------
Requirements for
greenhouses.
All greenhouse pre-plant soil fumigations must be tarped.'
plant soil
fumigation under
the heading
"Requirements for
Pre-Plant
Greenhouse Soil
Fumigations"
Environmental
Hazards
"This pesticide is toxic to mammals and birds. Do not apply directly to water, or to areas
where surface water is present or to intertidal areas below the mean high water mark. Do
not contaminate water when disposing of equipment washwaters or rinsate."
Precautionary
Statements
immediately
following the User
Safety
Recommendations
General Application
Restrictions
"Do not apply this product in a way that will contact workers or other persons, either
directly or through drift. Only protected handlers may be in the area during application.
While chloropicrin has certain properties and characteristics in common with chemicals
that have been detected in groundwater (chloropicrin is highly soluble in water and has low
adsorption to soil), volatilization is this chemical's most important route of dissipation.
To reduce the potential for leaching to groundwater, especially in soils with shallow
groundwater, for broadcast, tarped applications, the tarps must be perforated (cut,
punched, etc.) before noon and only when rainfall is not expected within 12 hours. For
raised-bed, tarped applications rainfall is not a factor since planting occurs with the tarp in
place.
For untarped applications of chloropicrin, potential leaching into groundwater and runoff
into surface water can be reduced by avoiding applications when heavy rainfall is
forecasted to occur within 24 hours."
Place in the
Direction for Use
directly above the
Agricultural Use
Box.
DRIVER TABLES
Table 11
Standard Tarp (no credits)
Formulation
Application
Method
Broadcast1
Bedded2
Bedded*3
98:2
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
80:20
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
75:25
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
67:33
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
57:43
Chloropicrin
Methyl
Bromide
Methyl
Bromide
50:50
Chloropicrin
Chloropicrin
Chloropicrin
45:55
Chloropicrin
Chloropicrin
Chloropicrin
33:67
Chloropicrin
Chloropicrin
Chloropicrin
113
-------
Table 12
High Barrier Films: Bromostopฎ (1.38 mil), IPM Clear VIF (1.38 mil), and Eval/Mitsui (1.38 mil) with 25% credit for
methyl bromide and 40% credit for chloropicrin
Formulation
Application
Method
Broadcast1
Bedded2
Bedded*3
98:2
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
80:20
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
75:25
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
67:33
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
57:43
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
50:50
Chloropicrin
Methyl
Bromide
Chloropicrin
45:55
Chloropicrin
Chloropicrin
Chloropicrin
33:67
Chloropicrin
Chloropicrin
Chloropicrin
Table 13
High Barrier Films: Hytiblock 7 black (0.00125"), XL Black Blockade (0.00125") and Hytibar (1.5 mil) with a 40%
credit for chloropicrin and no credit for methyl bromide
Formulation
Application
Method
Broadcast1
Bedded2
Bedded*3
98:2
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
80:20
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
75:25
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
67:33
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
57:43
Methyl
Bromide
Methyl
Bromide
Methyl
Bromide
50:50
Chloropicrin
Methyl
Bromide
Methyl
Bromide
45:55
Chloropicrin
Methyl
Bromide
Chloropicrin
33:67
Chloropicrin
Chloropicrin
Chloropicrin
Table 14
Deep (> 18 inches) Untarp
Formulation
Application
Method
Broadcast
98:2
Methyl
Bromide
80:20
Methyl
Bromide
75:25
Chloropicrin
67:33
Chloropicrin
57:43
Chloropicrin
50:50
Chloropicrin
45:55
Chloropicrin
33:67
Chloropicrin
*When applications occur between 1 hour before sunset and 1 hour after sunrise.
Where methyl bromide is listed, for the appropriate buffer zone, see Table 3 in the methyl bromide
RED. Where chloropicrin is listed, see Table 15 below.
Where methyl bromide is listed, for the appropriate buffer zone, see Table 2 in the methyl bromide
RED. Where chloropicrin is listed, see Table 15 below.
Where methyl bromide is listed, for the appropriate buffer zone, see Table 2 in the methyl bromide
RED. Where chloropicrin is listed, see Table 16 below.
4 Where methyl bromide is listed, for the appropriate buffer zone, see Table 4 in the methyl bromide
RED. Where chloropicrin is listed, see Table 19 below.
114
-------
Table 15
Tarp Bedded and Broadcast Buffer Zone Distances (feet)
Block
Size
(.acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib ai.'acre)
35
25
25
25
25
25
25
35
50
50
75
52.5
25
25
25
35
35
50
50
75
100
175
70
25
25
50
50
70
100
150
200
275
400
87.5
25
25
75
125
200
275
350
400
500
700
105
25
50
100
250
350
425
500
600
750
1050
122.5
50
75
175
350
475
600
700
800
1000
1375
140
75
125
250
450
600
750
900
1050
1250
1675
157.5
100
175
350
550
750
900
1100
1225
1475
2050
175
125
225
400
650
900
1050
1250
1450
1775
2375
192.5
135
275
450
750
1000
1200
1425
1625
2175
2775
210
150
300
550
850
1100
1400
1575
1825
2325
3150
245
175
375
650
1025
1400
1675
1975
2275
2775
3725
262.5
"?25
450
700
1150
1500
1775
2175
2,375
2950
4000
280
250
475
750
1225
1575
1975
2375
2575
3150
4350
315
275
550
900
1375
1825
2250
2675
2950
3750
P
350
325
625
1000
1575
2075
2500
2950
3350
4150
P
Table 16
Tarp Bedded Buffer Zone Distances (feet) with 25% Increase
Block
Size
(acres)
1
5
10
20
30
40
SO
60
80
120
Broadcast Equivalent Application Rate (Ib ai.'acre)
35
31
31
31
31
31
31
44
63
63
94
52.5
31
31
31
44
44
63
63
94
125
219
70
31
31
63
63
88
125
188
250
344
500
87.5
31
31
94
156
250
344
438
500
625
875
105
31
63
125
313
438
531
625
750
938
1313
122.5
63
94
219
438
594
750
875
1000
1250
1718
140
94
156
313
563
750
938
1125
1313
1563
2094
157.5
125
219
438
688
938
1125
1375
1531
1844
2563
175
157
281
500
813
1125
1313
1563
1813
2219
2968
1.02.5
169
344
563
938
1250
1500
1781
2031
2719
3469
210
188
375
688
1063
1375
1750
1969
2281
2906
3938
245
219
469
813
1281
1750
2094
2469
2844
3469
4656
262.5
281
562.5
875
1438
1375
2219
2719
2969
3688
5000
280
313
594
938
1531
1969
2469
2969
3219
3938
P
315
344
388
1125
1719
2281
2813
3344
3688
4688
P
350
406
781
1250
1969
2594
3125
3688
4188
5188
P
115
-------
Table 17
Untarp Bedded Buffer Zone Distances (feet)
Block
Size
(acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib at'acre)
17.5
25
25
25
25
25
25
25
35
50
50
26.25
25
25
25
35
50
75
125
175
250
350
35
25
25
50
125
200
300
350
400
500
650
43.75
25
50
150
275
350
450
550
650
775
1025
52.5
50
100
200
375
550
650
725
825
1000
1400
61.25
100
175
300
500
675
800
925
1025
1225
1650
70
125
225
375
600
800
975
1100
1250
1475
2000
78.72
150
275
450
725
925
1100
1275
1475
1775
2375
87.5
175
325
550
825
1050
1275
1475
1675
2025
2575
96.25
175
375
600
925
1175
1425
1625
1875
2475
2950
105
200
400
650
1000
1300
1575
1775
2000
2550
3200
122.5
250
500
750
1175
1475
1775
2075
2375
2800
3750
131.3
275
525
825
1225
1625
1975
2225
2575
2900
3975
140
300
575
875
1350
1700
2175
2375
2775
3200
4350
157.5
325
625
1000
1475
1925
2350
2750
3075
3750
4725
175
350
700
1100
1650
2175
2550
3000
3550
4350
P
Table 18
tfntarp Broadcast Buffer Zone Distances (feet)
Block
Size
(acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib ai/acre)
17.5
25
25
25
25
25
35
50
50
75
125
26.25
25
25
25
50
125
250
275
350
450
600
35
25
50
75
250
400
500
600
700
900
1200
43.75
SO
75
250
450
625
800
900
1050
1275
1775
52,5
100
175
350
625
850
1025
1225
1400
1775
2375
61.25
150
275
450
800
1100
1275
1575
1775
2150
2950
70
175
350
600
975
1250
1575
1825
2075
2600
3350
78.75
200
400
700
1125
1475
1775
2100
2375
2950
3950
87.5
225
475
800
1250
1625
1975
2375
2550
3275
4350
96.25
275
550
900
1375
1825
2250
2575
2950
3575
P
105
300
600
950
1500
1975
2400
2850
3200
3950
P
122.5
350
700
1125
1775
2375
2850
3300
3800
P
P
131.3
375
750
1200
1875
2550
3050
3550
4175
P
P
140
400
800
1300
1975
2600
3225
3950
4350
P
P
157.5
450
900
1450
2225
2950
3750
4350
P
P
P
175
500
1000
1575
2575
3400
4325
P
P
P
P
116
-------
Table 19
Untarp Broadcast Deep Buffer Zone Distances (feet)
Block
Size
(acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib ai.'acre)
35
25
50
75
250
400
500
COO
700
ง00
1200
52.5
90
175
350
625
850
1025
1225
1400
1775
2375
70
175
350
600
975
1250
1575
1S25
2075
2600
3350
87.5
225
475
800
1250
1625
1975
2375
2550
3275
4350
105
300
600
950
1500
1975
2400
2850
3200
3950
P
122.5
350
700
1125
1775
2375
2850
3300
3800
P
P
140
400
800
1300
1975
2600
3225
3950
4350
P
P
157.5
450
900
1450
2225
2950
3750
4350
P
P
P
175
500
1000
1575
2575
3400
4325
P
P
P
P
192.5
525
1050
1675
2775
3650
4500
P
P
P
P
210
600
1200
1875
2950
3300
P
P
P
P
P
245
700
1400
2200
3550
4350
P
P
P
P
P
26'2,5
750
1475
2350
3750
4575
P
P
P
P
P
280
800
1575
2550
4000
4725
P
P
P
P
P
315
878
1775
2800
P
P
P
P
P
P
P
350
975
1975
3150
P
P
P
P
P
P
P
Table 20
Drip Irrigation Tarped Buffer Zone Distances (feet)
Block
Size
(acres)
1
5
10
20
30
40
50
60
80
120
Broadcast Equivalent Application Rate (Ib ai. acre)
30
25
25
25
25
25
25
25
25
25
25
45
25
25
25
25
25
25
25
25
25
25
60
25
25
25
25
25
25
25
25
25
25
"75
25
25
25
25
25
25
25
25
25
25
90
25
25
25
25
25
25
2,5
25
25
25
105
25
25
25
25
25
25
25
25
25
25
120
25
25
25
25
25
25
25
25
25
25
135
25
25
25
25
25
25
25
25
50
50
150
25
25
25
25
25
25
35
35
50
75
165
25
25
25
25
25
25
35
50
50
100
180
25
25
25
25
25
35
50
50
50
100
210
25
25
25
35
35
35
50
50
75
175
225
25
25
25
35
50
50
75
100
125
225
240
25
25
25
50
65
75
125
125
150
275
270
25
25
25
65
85
125
145
175
225
325
300
25
25
50
75
125
150
175
225
275
400
Table 21
Greenhouse Tarped Drip Applications
Structure Size
< 25,000 square feet
> 25,000 square feet and < 30,000 square feet
> 30,000 square feet and < 35,000 square feet
> 35,000 square feet and < 40,000 square feet
> 40,000 square feet and < 45,000 square feet
> 45,000 square feet and up to 50,000 square
feet
Buffer Zone
25 feet
50 feet
75 feet
100 feet
115 feet
130 feet
117
-------
Table 22: Summary of Labeling Changes for Chloropicrin Antimicrobial Uses (Remedial Wood
Treatment)
Description
Amended Label Language
Placement
Add language
clarifying
application
methods
"For remedial treatment of wooden poles/timbers:
1. Plug the pre-drilled holes immediately after applications;
2. Do not treat structures/beams indoors;
3. Do not drill an application hole through seasoning checks to apply
product. If the hole intersects a check, plug the hole and drill another. If
more than 2 treatment holes intersect an internal void or rot pocket, re-
drill the holes farther up the pole into relatively solid wood."
Directions for Use
For end-use
products
containing
directions for use
for the pour or
injection method of
application (not
including the vial
application
method)
"Applicators and other handlers must wear a full-face tight-fitting or loose-
fitting helmet or hood style NIOSH/MSHA approved respirator
with an organic-vapor-removing cartridge with a prefilter approved for
pesticides (MSHA/NIOSH approval number prefix TC-23C), or
with a canister approved for pesticides (MSHA/NIOSH approval number
prefix TC-14G)."
All references to wearing goggles or a full face shield for eye protection must
be removed.
Personal Protective
Equipment
For end-use
products
containing
directions for use
for the vial method
of application
"For handling activities in enclosed areas, applicators and other handlers
participating in filling the vials or otherwise exposed to non-encapsulated product
must wear:
a supplied-air respirator with MSHA/NIOSH approval number prefix TC-
19C, or
a self-contained breathing apparatus (SCBA) with MSHA/NIOSH approval
number TC-13F.
For handling activities outdoors, applicators and other handlers participating in
filling the vials or otherwise exposed to non-encapsulated product must wear a
full-face tight-fitting or loose-fitting helmet or hood style NIOSH/MSHA
approved respirator:
with an organic-vapor-removing cartridge with a prefilter approved for
pesticides (MSHA/NIOSH approval number prefix TC-23C), or
with a canister approved for pesticides (MSHA/NIOSH approval number
prefix TC-14G)."
Personal Protective
Equipment
For all
antimicrobial end-
use registrations of
chloropicrin
"Do not permit entry into spill area or clean-up area by unprotected persons until
concentration of chloropicrin is determined to be less than 0.1 ppm."
This language updates some labels which currently state 0.3 ppm.
Storage and
Disposal and
Personal Protective
Equipment
The following
language must
appear on the label
if respirator use is
required (for liquid
pour application
and when filling
vials):
"Employers must also ensure that all handlers are:
Fit-tested and fit-checked using a program that conforms to OSHA's
requirements (see 29CFRPart 1910.134)
Trained using a program that confirms to OSHA's requirements (see
29CFR Part 1910.134)
Examined by a qualified medical practitioner to ensure physical ability to
safely wear the style of respirator to be worn. A qualified medical
practitioner is a physician or other licensed health care professional who
will evaluate the ability of a worker to wear a respirator. The initial
Directions for Use
Under the section
"Protection for
Handlers"
118
-------
evaluation consists of a questionnaire that asks about medical conditions
(such as a heart condition) that would be problematic for respirator use. If
concerns are identified, then additional evaluations, such as a physical
exam, might be necessary. The initial evaluation must be done before
respirator use begins. The initial evaluation must be done before respirator
use begins. Handlers must be reexamined by a qualified medical
practitioner if their health statue or respirator style or use-conditions
change."
The following
language must
appear on the label
if the use of a
respirator is not
required
(application via
vial method) but
needs to be
available in case of
spill or emergency:
"In case of emergency or the need for immediate respiratory protection, the
fumigation handler employer must make sure that the following PPE are
immediately available to all persons performing fumigant handling activities:
at least one air rescue device (e.g., SCBA) must be on-site in case of an
emergency, and
unless an air-purifying respirator is being worn by each person performing
a handling task at the site, enough full-face air-purifying respirators of the
type specified in the PPE section of this labeling must be immediately
available at the site for each handler."
Directions for Use
Under the section
"Protection for
Handlers"
For registration
75340-1, use
directions for the
vial method of
application must be
incorporated into
the main label and
the reference to the
pour method of
chloropicrin
removed (the pour
method is no
longer used for this
registration).
Vial method of application language to be provided by registrant when
revised label submitted for review.
Directions for Use
119
-------
Appendix A
Chloropicrin PC Code 081501 Uses Eligible for Reregistration
Use Site
Formulation
Application
Method
Maximum
Application
Rate/Number of
Applications
Use Limitations
Pre-Plant Soil
Agricultural Crops
Berries:
caneberries, blackberries,
boysenberries,
dewberries, loganberries,
raspberries,
youngberries,
blueberries, cranberries,
gooseberries,
huckleberries.
Small fruits:
strawberries, currants,
grapes, kumquat,
bananas, figs,
persimmons, pineapple,
pomegranates,
tree fruits (all), vine
fruits (all).
Citrus fruits: Grapefruit,
lemon, limes, oranges,
tangelos, tangerines.
Nut crops:
almonds, cashews,
chestnuts, filberts,
hickory nuts, pecans,
walnuts, pistachios.
Pome and stone fruits:
apples, pears, quinces,
apricots, cherries,
nectarines, peaches,
plums, prunes, dates.
Cucurbits:
soluble
concentrate/li qui d,
pressurized gas,
pressurized liquid,
emulsifiable
concentrate, and a
ready-to-use
product
1. Shank injection
tarped**
2. Shank injection
untarped
3. Shank injection
deep (at least 18
inches) untarped
4. Drip Irrigation
Tarp
5. Tree hole replant
1.3501bsai/A
2. 175 Ibs ai/A
3.3501bsai/A
4. 300 Ibs ai/A
5. 500 Ibs ai/A (1
lb/100 ft2)
See applicable
GAPS from Table
10 in the RED.
120
-------
Use Site
Formulation
Application
Method
Maximum
Application
Rate/Number of
Applications
Use Limitations
Melons (all),
cantaloupes, casaba
melons, crenshaw
melons, honeydew,
muskmelons, persian
melons, watermelon,
cucumbers, pumpkins,
squash (summer and
winter), mango melons.
Vegetables: asparagus,
eggplant,_peppers,
pimentos, tomatoes,
cole crops, broccoli,
brussels sprouts,
cabbage, cauliflower,
collards, kale,
kohlrabi, endive,
lettuce (all), mustard,
spinach, Swiss chard,
carrots, garlic, leeks,
okra, onions, parsnips,
potatoes, radishes,
rutabagas, salsify,
shallots, sweet potato,
yams, popcorn,
garden beets, celery,
turnips, vegetables (all).
Field crops:
beans (all), peas (all),
kenaf, forage-fodder
grasses (all), pastures,
alfalfa, clover, lespedeza,
vetch,
birdsfoot trefoil, barley,
corn, oats, rye, sorghum,
wheat, sugarcane,
buckwheat, tobacco,
safflower, cotton, flax,
peanuts, soybeans,
millet.
121
-------
Use Site
Ornamentals:
golf course turf,
ornamental turf, forest
trees (all), herbaceous
plants (all), woody plants
(all), flowering plants
(all).
Miscellaneous: hops.
horseradish, mint, olives,
greenhouse soils,
mushroom house soils.
Formulation
Application
Method
Maximum
Application
Rate/Number of
Applications
Use Limitations
Warning Agent Prior to Sulfuryl Fluoride Residential Fumigations
Residential Structures
Ready-to-Use
Chloropicrin is then
placed in the center
of the structure in
either a shallow pan
or onto absorbent
material. A fan is
then placed to
direct the air stream
over the pan or
absorbent material
to accelerate the
chloropicrin's
evaporation.
1 fluid ounce ai of
chloropicrin is used
per 10,000-15,000
cubic feet.
Remedial Wood Treatment
Wood poles, timbers,
pilings, and glue-
laminated beams.
Ready to use
There are two
methods for
application of
chloropicrin for
remedial wood
treatment. One
method involves
using encapsulated
vials. Applicators
pour liquid
chloropicrin into
vials and cap them.
After the applicator
Pole Circumference
in inches and
amount of solution
to be applied :
22-29in, use 1A pint
3 0-3 Sin, use /^ pint
39-56in, use 1.0
pint
57-65in, use 1 1A
pint
Do not treat
structures/beams
indoors.
Do not drill an
application hole
through seasoning
checks to apply
product. If the hole
intersects a check,
plug the hole and
drill another. If
more than 2
122
-------
Use Site
Formulation
Application
Method
has reached the area
to be treated, the
cap is removed and
the vial inserted
into the holes that
have been pre-
drilled into the
timber. The hole is
then capped. The
other method
involves
pouring/injecting
liquid chloropicrin
into holes that have
been pre-drilled.
The hole is then
capped.
Maximum
Application
Rate/Number of
Applications
Use Limitations
treatment holes
intersect an internal
void or rot pocket,
re-drill the holes
farther up the pole
into relatively solid
wood.
**The application method matches up with the same number for the maximum application rate.
For example, the maximum application rate for shank bedded tarped applications is 350 Ibs ai/A.
123
-------
Appendix B
Table of Generic Data Requirements and Studies Used to Make the Reregistration Decision
This section is currently not available.
124
-------
Appendix C.
Technical Support Documents
Additional support of this RED is maintained in the OPP docket EPA-HQ-OPP-2007-0350. This
docket may be accessed in the OPP docket room located at S-4900, One Potomac Yard 2777 S.
Crystal Drive, Arlington, VA. It is open Monday through Friday, excluding federal holidays,
from 8:30-4:00 pm. All documents may be view in the OPP docket room or downloaded or
viewed via the internet at http://www.regulations.gov.
Health Effects Support Documents
Chloropicrin Final Revised FLED Human Health Risk Assessment June 18, 2008. (DP
Barcode 348674)
MO A Mode of Action, Eye Irritation, and the Intra-Species Factor: Comparison of
Chloropicrin and MITC. June 25, 2008. DP Barcode 293356.
RESPONSE TO PUBLIC COMMENTS. The Health Effects Division's Response to
Comments on the Agency's April 12, 2007 document, Chloropicrin: Revised HED
Human Health Risk Assessment for Phase 5 (Docket EPA-HQ-OPP-2007-0350). DP
Barcode 348676.
Environmental Fate and Ecological Effects Support Documents
Revised Screening Ecological Risk Assessment for the Reregi strati on of Chloropicrin.
DP Barcode 348669. April 16, 2008.
Response to Phase 5 Public Comments on the Phase 4 Chloropicrin Reregi strati on Risk
Assessment. April 16, 2008. DP Barcode 348669.
Biological and Economical Analysis Support Documents
Review of Stakeholder Submitted Impact Assessments of Proposed Fumigant
Buffers, Comments on Initial Buffer Zone Proposal, and Case Studies of the Impact
of a Flexible Buffer System for Managing By-Stander Risks of Fumigants. June 25,
2008. DP Barcode 353940.
Response to Phase 5 BEAD Related Public Comments Received on the Reregi strati on
of Chloropicrin, Dazomet, Metam Potassium, Metam Sodium, and Methyl Bromide.
June 25, 2008. DP Barcode 353940.
EPA-HQ-OPP-2007-03 50-0017, Summary of the Benefits of Soil Fumigation with
Chloropicrin in Crop Production.
EPA-HQ-OPP-2007-03 50-0018, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam Sodium in Cucurbit Production.
EPA-HQ-OPP-2007-03 50-0019, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam Sodium in Eggplant Production
EPA-HQ-OPP-2007-03 50-0020, Assessment of the Benefits Soil Fumigants (Methyl
Bromide, Chloropicrin, Metam-Sodium, Dazomet) Used by Forest Tree Seedling
Nurseries.
EPA-HQ-OPP-2007-03 50-0021, Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin, Dazomet, and Metam Sodium for Use in Raspberry
125
-------
Nurseries, Fruit and Nut Deciduous Tree Nurseries, and Rose Bush Nurseries in
California.
EPA-HQ-OPP-2007-03 50-0022, Assessment of the Benefits of Soil Fumigation with
Chloropicrin and Metam-sodium in Onion Production.
EPA-HQ-OPP-2007-0350-0023, Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin, and Metam Sodium in Grape Production.
EPA-HQ-OPP-2007-03 50-0024, Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin and Metam Sodium in Tree Nut Production.
EPA-HQ-OPP-2007-03 50-0025, Assessment of the Benefits of Soil Fumigation with
Chloropicrin and Metam Sodium in Pome Fruits Production.
EPA-HQ-OPP-2007-03 50-0026, Assessment of the Benefits of Soil Fumigation with
Methyl Bromide, Chloropicrin, and Metam Sodium in Stone Fruit Production.
EPA-HQ-OPP-2007-03 50-0027, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam Sodium in Bell Pepper Production.
EPA-HQ-OPP-2007-03 50-0028, Assessment of the Benefits of Soil Fumigation with
Metam Sodium in Potato Production.
EPA-HQ-OPP-2007-0350-0029, Assessment of Soil Fumigation with Chloropicrin,
Methyl Bromide and Metam-sodium in Strawberry Production.
EPA-HQ-OPP-2007-0350-0030, Assessment of the Benefits of Chloropicrin, Methyl
Bromide, Metam-sodium and Dazomet Use In Strawberry Nursery Runner
Production.
EPA-HQ-OPP-2007-03 50-0031, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam-sodium on Sweet Potato Production.
EPA-HQ-OPP-2007-03 50-0032, Assessment of the Benefits of Soil Fumigation with
Chloropicrin in Tobacco Production.
EPA-HQ-OPP-2007-0350-0033, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, and Metam Sodium in Tomato Production.
EPA-HQ-OPP-2007-03 50-0034, Assessment of the Benefits of Soil Fumigation with
Metam-Sodium in Carrot Production.
EPA-HQ-OPP-2007-03 50-003 5, Assessment of the Benefits of Soil Fumigation with
Metam Sodium in Peanut Production.
EPA-HQ-OPP-2007-0350-0036, Assessment of the Benefits of Soil Fumigation with
Chloropicrin, Methyl Bromide, Metam Sodium and Dazomet in Ornamental
Production.
EPA-HQ-OPP-2007-0350-0037, BEAD'S Planned Impact Assessments on
Agricultural Sites with Significant Use of Soil Fumigants (Chloropicrin, Dazomet,
Methyl Bromide, Metam Potassium, and Metam Sodium.
Antimicrobial Assessment Support Documents
Revised Occupation and Residential/Bystander Assessment of the Antimicrobial Use
(Remedial Wood Treatment) of Chloropicrin for the Reregi strati on Eligibility Decision
(RED) Document. (Phase 3 Comment). PC Code 081501, DP Barcode 314399.
Phase 6 Response to Substantive Public Comments on Antimicrobials Division's
Occupational and Residential Assessments for the Reregi strati on Eligibility Decision
126
-------
(RED) Documents for the following chemicals: Methylisothiocyanate (MITC), Metam
Sodium, Dazomet, and Chloropicrin.
Updated Label Language for the Antimicrobial Uses of Chloropicrin (PC Code 081501)
for the Reregi strati on Eligibility Decision Document.
Buffer Zone Credits Support Document
Factors Which Impact Soil Fumigant Emissions - Evaluation for Use in Soil Fumigant
Buffer Zone Credit Factor Approach. Dawson, J. and Smith, C.; D306857; June 9, 2008.
Health Effects Division Recommendations for Fumigant Data Requirements. DP
Barcode 353724.
Risk Management Support Documents
SRRD's Response to Phase 5 Public Comments for the Soil Fumigants. Rice, M. and
McNally, R.; July 2008.
Risk Mitigation Options to Address Bystander and Occupational Exposures from Soil
Fumigant Applications. EPA-HQ-OPP-2007-0350-0003.
127
------- |