Office of Pesticide Programs (7506P) October 2010 EPA 738-F-10-002
£EPA
Soil Fumigant Mitigation Factsheet:
United States "
Environmental Protection
Agency
Emergency Preparedness and
:ion
Response Requirements
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 Emergency Preparedness and Response,
however, will not appear on fumigant labels until late 2011.
New Requirements
for Emergency
Preparedness and
Response
Fumigant Site
Monitoring
New Requirements for Emergency Preparedness and Response
To reduce risks to people who may be near a buffer zone (e.g., at their
home or working in a nearby field), EPA is requiring applicators to
either provide on-site monitoring of the buffer zone perimeter in areas
where residences and other occupied structures are within a specific
distance, or, as an alternative to on-site monitoring, provide emergency
response information directly to neighbors. Whether measures are
required depends on the size of the buffer zone and how close people
may be to the buffer zone. An example of each element is discussed in
more detail below.
Fumigation Site Monitoring
If emergency response measures are required based on the criteria
described below, and the fumigator chooses to monitor the buffer
perimeter rather than to provide information directly to the neighbors,
here is what the fumigator must do:
• Monitoring must begin on the day the application begins and
continue until the buffer zone period expires.
• Monitoring must take place approximately 1 hour before sunset
on the day the application begins and continue once during the
night, once at 1 hour after sunrise, and once during the day until
the end of the buffer zone period.
• Monitor for sensory irritation for metam sodium/potassium,
dazomet, chloropicrin, and methyl bromide products that include
at least 20% chloropicrin.
• Air concentrations of methyl bromide must be measured using
a direct-read instrument if the methyl bromide product applied
contains less than 20% chloropicrin.
• Monitoring must be conducted by a certified applicator or
someone under his/her supervision.
• Monitoring must take place in areas between the buffer zone
perimeter and residences or other occupied areas that trigger this
requirement.
Soil Fumigant Mitigation: Emergency Preparedness and Response Requirements
-------
Fumigant Site
Monitoring, continued
Response Information
for Neighbors
• If at any time the person monitoring the air concentrations
experiences sensory irritation consistent with fumigant exposure,
then the emergency response plan stated in the FMP must be
immediately implemented.
• If other problems occur, such as a tarp coming loose, then the
appropriate control plan must be activated.
• For formulations with less than 20% chloropicrin, the location
and results of the air monitoring must be recorded in the post-
application summary.
• For formulations with 20% or greater chloropicrin, the location
where any sensory irritation occurred must be recorded in the
post-application summary.
EPA believes this will help ensure that if a problem occurs during or
after the fumigation, the appropriate steps can be taken to reduce the
risk of exposure. While protective, site monitoring may be burdensome
for users fumigating in areas with few people. Therefore, users have
the option of providing emergency response information directly to
neighbors rather than monitoring.
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 one week before fumigant application in a specified field. The
dates that fumigation is planned to take place may be stated as a range
of dates, up to four weeks long. If an application is not made during the
four-week window indicated, the information must be delivered again.
Information that must be provided includes:
The general location of the application block,
• Fumigant(s) applied including the active ingredient, name of the
fumigant products(s), and the EPA Registration number,
Contact information for the applicator and property owner/
operator,
Time period in which the fumigation is planned to take place
(must not range more than 4 weeks),
• Early signs and symptoms of exposure to the fumigant(s)
applied, what to do, and emergency responder phone number to
call (911 in most cases), and
• How to find additional information about fumigants.
The method for distributing informations 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.
Soil Fumigant Mitigation: Emergency Preparedness and Response Requirements
-------
When are Emergency
Preparedness and
Response Measures
Needed?
When are Emergency Preparedness and Response Measures
Needed?
Site-Specific Proximity Triggers for Buffer Zones Greater than 25 Feet
If the buffer zone is: AND there are residences and
businesses:
50 feet
from the edge of the buffer zone
> 25 feet and < 100 feet
> 100 feet and < 200 feet
> 200 feet and < 300 feet
> 300 feet
100 feet
from the edge of the buffer zone
200 feet
from the edge of the buffer zone
300 feet
from the edge of the buffer zone
Applicator must either:
Monitor the air (Option 1)
or
Provide information to neighbors (Option 2)
Example Site Map for
Informing Neighbors
Exception: If the buffer zone is 25 feet, the minimum buffer zone size,
then Emergency Preparedness and Response measures are not required.
Also, if all of the land within 300 feet of the edge of the buffer zone
is under the control of the owner/operator of the fumigated field, then
Emergency Preparedness and Response measures are not required
regardless of the size of the buffer zone.
Because site monitoring may be burdensome for users fumigating in
areas with few residences or businesses, EPA is allowing fumigant users
the option of providing emergency response information directly to
neighbors instead of monitoring.
Example Site Map for Informing Neighbors
Below is an example to clarify this requirement:
• IF the buffer zone is 125 feet, then these requirements apply to
residences within 100 feet of the buffer zone. Either the appli-
cator must monitor the area between the dotted house and the
buffer zone or residents of the dotted house must be provided
emergency response information.
The location of the cross-hatched house would not prompt any
action since it is outside the specified distance.
For additional information, see EPA's Web page on
risk mitigation measures for the soil fumigants,
www.epa.gov/oppsrrd1/reregistration/soil_fumigants/.
100ft
I
125ft
238ft
Soil Fumigant Mitigation: Emergency Preparedness and Response Requirements
------- |