&EPA
                                       October 2010
                                                     EPA 738-F-10-005
    United States
    Environmental Protection
                     Soil Fumigant Mitigation Factsheet:
                               Worker Protection  Measures
          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 these new requirements.
      Handler activities on
              labels
    On-site supervision and
             training
To address risks to fumigant handlers and workers, EPA is requiring:

A clear description of handler activities on labels
All persons performing fumigant-handler activities must be trained and
equipped as handlers in accordance with the requirements in the WPS (40 CFR
Part 170). Handler activities include:
   •   Participating in the application as supervisors, loaders, drivers, tractor
       co-pilots,  shovelers, cross ditchers, or as other direct application
       participants (note: the application starts when the fumigant is first
       introduced into the soil and ends after the fumigant has stopped being
       delivered/dispensed to the soil);
   •   Monitoring fumigant air concentrations;
   •   Cleaning up fumigant spills (this does not include emergency
       personnel not associated with the fumigation application);
   •   Handling  or disposing of fumigant containers;
   •   Cleaning, handling, adjusting, or repairing the parts of fumigation
       equipment that may contain fumigant residues;
   •   Installing, repairing, operating, or removing irrigation equipment in
       the application block or surrounding buffer zone during the buffer zone
       period;
   •   Entering the application site or surrounding buffer zone during the
       buffer zone period to perform scouting or crop advising tasks;
   •   Installing, perforating (cutting, punching, slicing, poking), removing,
       repairing, or monitoring tarps:
          o   until 14 days after application is complete if tarps are not
              perforated and removed during those 14 days, or
          o   until tarp removal is complete if tarps are both perforated and
              removed less than 14 days after application; or
          o   until 48 hours after tarp perforation is complete if tarps will be
              perforated but not removed within 14 days after application.

On-site supervision and training
   •   Direct, on-site supervision by certified applicators during most
       fumigant applications
   •   New training provided by registrants for certified applicators who
       supervise  fumigant applications
   •   New training information for other handlers.
   Soil Fumigant Mitigation: Worker Protection Measures

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  Respiratory protection         Respiratory protection requirements
        requirements                  •   Handlers must either stop work and leave the area or use air-purifying
                                            respirators if they experience sensory irritation (this does not apply to
                                            formulations with less than 20% chloropicrin)
                                         •   For methyl bromide formulations with less than 20% chloropicrin.
                                            handlers must wear air-purifying respirators during handling activities
                                         •   Air monitoring while handlers use respirators to ensure concentrations
                                            do not exceed the upper working limit of respirators
                                         •   All handlers who will wear a respirator must be fit-tested, trained, and
                                            medically examined to ensure they do not have health problems such
                                            as a heart condition that could make use of a respirator dangerous
                                         •   An air purifying respirator with the appropriate cartridges must be
                                            available for each handler who will wear a respirator.

     Tarp perforation and         Tarp perforation and removal requirements
    removal requirements            •   If tarps are used, they may not be perforated until at least 5 days (120
                                            hours) have elapsed after the fumigation is complete unless a weather
                                            condition exists that necessitates early removal
                                         •   Tarp removal may not begin until at least 2 hours after tarp perforation
                                            is complete and tarp removers must follow respiratory protection
                                            requirements
                                                o   For methyl bromide, air monitoring  with direct-read
                                                    instruments is required before tarp removal  can begin
                                         •   If tarps are not removed, planting may not begin until at least 48 hours
                                            after tarp perforation is complete
                                         •   If tarps are left on the soil for at least  14 days after the fumigation is
                                            complete, planting may begin when the tarps are being perforated
                                         •   Tarps must be perforated using mechanical methods (e.g., all-terrain
                                            vehicles with cutting implements) except for small areas (less than 1
                                            acre), at the start of a row, and during flood prevention activities.

  Entry-restricted period        Entry-restricted period requirements
        requirements                  •   Entry into treated fields (including early entry that would otherwise
                                            be permitted under the WPS) by any person  other than a trained and
                                            equipped handler is prohibited from the start of the application until
                                                o   5 days (120 hours) after application  has ended for untarped
                                                    applications, or
                                                o   After tarps are perforated and removed if tarp removal is
                                                    completed less than 14 days after application, or
                                                o   48 hours after tarps are perforated if they will not be removed
                                                    at least 14 days after the application, or
                                                o   5 days (120 hours) after application  is complete if tarps are
                                                    not perforated and removed 14 days after the application is
                                                    complete.
Soil Fumigant Mitigation: Worker Protection Measures

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Entry Restricted Period by Scenario
If the application
is[ ]

1.
2.
3.
4.

Untarped
Tarped
Tarped
Tarped
and Tarp is
r i



Perforated and
Removed
Perforated BUT
NOT Removed
Perforated and/or
Removed
T 1 days after
application is
completed


Within 14 days
Within 14 days
More than 14 days
workers may
enter [ 1

5 days after application is
complete
After tarp is removed
48 hours after
perforating tarps
5 days after application is
complete
                  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: Worker Protection Measures

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