March 2012
                                                                                            EPA 735-F-12-003
     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.  Some fumigant products have additional buffer zone requirements beyond
       those described in this factsheet (e.g., methyl bromide products applied with certain high barrier
       tarps). See the buffer zone section of individual labels for these requirements. The new Buffer Zone
       requirements are being implemented during the second of two phases. When new Phase 2 fumigant labels
       appear in the market place in late 2012, fumigant users will need to comply with these new requirements.
  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.

                Buffer 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).

                See www.epa.gov/pesticides/tarpcredits for a list of tarps that have been tested
                and determined to qualify for buffer zone reduction credits.
  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 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 people in transit (see exemptions section
                                          below).
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 of the
     Application Block
    •   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.
Buffer zone distances
    •   Buffer zone distances must be based on look-up tables on product
       labels unless otherwise specified on the product label (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 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
               period, and
           •    The storage buildings do not share a common wall with
               occupied structure.
    •   See the Posting Fact Sheet for additional requirements that may apply.
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   Areas Not Under the
  Control of Owner of the
     Application Block
Areas not under the control of owner 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,
           •   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 of the application block, UNLESS,
           •   The owner 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.
For additional information, please see EPA's Soil Fumigant Toolbox, www.epa.gov/oppsrrd1/reregistration/soil_fumigants/.
Soil Fumigant Mitigation: Buffer Zones

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