October 2010
                                                                                            EPA738-F-10-001
     United States
     Environmental Protection
     Agency
Soil Fumigant Mitigation Factsheet:
                              Buffer Zones
              EPA is requiring important new safety measures for soil fumigant pesticides to increase
       protections for agricultural workers and bystanders ~ people who live, work, or otherwise spend time
       near fields that are fumigated. These measures are for the soil fumigants chloropicrin, dazomet, metam
       sodium/potassium, and methyl bromide.
              This fact sheet summarizes new requirements to protect fumigant handlers and other workers
       from fumigant exposures. When new fumigant labels appear in the market place in 2010, fumigant
       users will need to comply with new requirements. Requirements for Buffer Zone Mitigation Measures,
       however, will not appear on fumigant labels until late 2011.
  Buffer Zone Distances
                A buffer zone provides distance between the application site (i.e., edge of field)
                and bystanders, allowing airborne residues to disperse before reaching the
                bystanders. This buffer will reduce the chances that air concentrations where
                bystanders are located will cause acute adverse health effects.

                EPA has selected buffer distances that will protect bystanders from acute
                exposures, but which are not so great as to eliminate benefits of soil fumigant
                use. The size of the buffer zones is based on the following factors:

                       application rate;
                       field size;
                       application equipment and methods; and,
                       credits for use of emission-reduction measures such as high-barrier
                        tarps and site conditions.

                Buffers zone distances are scenario-based using applicable site conditions and
                will be based on look-up tables on product labels. EPA is also giving "credits"
                to encourage users to employ practices which reduce emissions. Credits will
                reduce buffer distances. Some credits will also be available for site conditions
                that reduce emissions (e.g., high organic or clay content of soils).
  New Requirements for
        Buffer Zones
           General
                To address the risk to bystanders who live and work near fumigated fields, the
                Agency is requiring buffer zones. The following summarizes the buffer zone
                requirements:
                General
                                          A "buffer zone" must be 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 people in transit (see exemptions section
                                          below).
                                          The "buffer zone period" starts at the moment when any fumigant
                                          is delivered/ dispensed to the soil within the application block or
                                          greenhouse and lasts for a minimum of 48 hours after the fumigant has
                                          stopped being delivered/dispensed to the soil.
Soil Fumigant Mitigation: Buffer Zones

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  Buffer Zone Distances
    Authorized Entry to
       Buffer Zones
   Buffer Zone Proximity
  Exemptions for Transit
   Through Buffer Zones
   Structures Under the
     Control of Owner/
      Operator of the
     Application Block
   Areas Not Under the
    Control of Owner/
      Operator of the
    Application Block

Soil Fumigant Mitigation: Buffer Zones
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) to treat
       individual tree holes, 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 bystander exposure to peak
       fumigant emissions from multiple fumigated fields, buffer zones from
       multiple application blocks may only overlap under the following
       conditions:
              For continuous-move center-pivot applications (metam
              sodium/potassium products only), buffers may overlap only if
              applications are made using low-drift systems.
              For all other application methods, buffers may overlap only if
              at least 12 hours have elapsed from end of the application for
              which a buffer is already  in place to the start of the subsequent
              application.
              The certified applicators in charge of the fumigations must
              provide information to handlers who may work in the buffers
              about the protective equipment, signs of exposure, and health
              effects associated with each fumigant to  which they may be
              exposed.

Exemptions for transit through buffer zones
       Vehicular and bicycle traffic on public and private roadways through
       the buffer zone is permitted
       Bus stops or other locations where persons wait for public transit are
       not permitted within the buffer zone.
       See the Posting Fact Sheet 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,
              The storage buildings are not occupied during the buffer zone
              period,and
              The storage buildings do  not share a common wall with an
              occupied structure.
       See the Posting Fact Sheet 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,

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   Areas Not Under the
     Control of Owner/
       Operator of the
     Application Block,
          continued
 Fumigation Restrictions
      Near Difficult-to-
       Evacuate Sites
              The occupants provide written agreement that they will
               voluntarily vacate the buffer zone during the entire buffer
               zone period, and
              Reentry by occupants and other non-handlers does not occur
               until the buffer zone period has ended.
              For methyl bromide formulations with less than 20%
               chloropicrin, air monitoring with direct-read instruments
               shows concentrations are below action levels before reentry is
               permitted.

       Buffer zones may not include agricultural areas owned/operated
       by persons other than the owner/operator of the application block.
       UNLESS,
              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, taking into account the amended
               requirements for overlapping buffers, and
              The owner/operator of the areas that  are not under the control
               of the applicator 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, sidewalks, walking paths, playgrounds, athletic fields,
       etc), UNLESS,
              The area is not occupied during the buffer zone period,
              Entry by non-handlers is prohibited during the buffer zone
               period,and
              Written permission is given by the appropriate state and/or
               local authorities to include public areas in the buffer zone.

       Buffer zones may include publicly owned and/or operated roads,
       including rights of ways. As mentioned in the previous bullet, if a
       sidewalk or permanent walking path is associated with it, written
       permission must be given by the appropriate  state and/or local
       authorities.

Fumigation Restrictions Near Difficult-to-Evacuate Sites
       The Agency has defined "difficult-to-evacuate" sites to include
       schools, state-licensed daycare centers, nursing homes, assisted living
       facilities, hospitals, in-patient clinics, and prisons.
       No fumigant applications with buffer zones greater than 300 feet will
       be permitted within % mile of a difficult-to-evacuate site unless the
       site is not occupied during the application and the 36-hour period
       following the application.
       If the fumigation buffer zone is 300 feet or less, then no fumigant
       applications will be permitted within 1/8 mile of a difficult-to-
       evacuate site unless the site is not occupied during the application and
       the 36-hour period following the application.
                 For additional information, please see EPA's Web page on risk mitigation measures
                 for the soil fumigants, http://www.epa.gov/oppsrrd1/reregistration/soil_fumigants/.
Soil Fumigant Mitigation: Buffer Zones

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