Office of Pesticide Programs (7506P) March 2012 EPA 735-F-12-004
£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. The new Emergency Preparedness and Response 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.
New Requirements
for Emergency
Preparedness and
Response
When are Emergency
Preparedness and
Response Measures
Needed?
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.
When are Emergency Preparedness and Response Measures
Needed?
Site-Specific Proximity Triggers for Buffer Zones Greater than 25 Feet
If the buffer zone is:
> 25 feet and < 100 feet
> 1 00 feet and < 200 feet
> 200 feet and < 300 feet
> 300 feet
AND there are residences and
businesses:
50 feet
from the edge of the buffer zone
1 00 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)
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 of the fumigated field, then Emergency
Preparedness and Response measures are not required regardless of the
size of the buffer zone.
Soil Fumigant Mitigation: Emergency Preparedness and Response Requirements
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Fumigant Site
Monitoring
Response Information
for Neighbors
Fumigation Site Monitoring
If emergency response measures are required based on the triggers above
and the applicator chooses to monitor the buffer perimeter rather than to
provide information directly to the neighbors, here is what the applicator
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.
• 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 Fumigant
Management Plan (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 application would need to ensure that residences and businesses that
trigger the requirement have been provided the information below at least
one week before the application starts. The information provided may
include application dates that range for no more than 4 weeks.
Soil Fumigant Mitigation: Emergency Preparedness and Response Requirements
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Response Information
for Neighbors,
continued
Example Site Map
If an application is not made when specified, the information must be
delivered again.
Information that must be provided includes:
The 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 used to share the response information for neighbors can 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.
Example Site Map
Below is an example to clarify this requirement:
• IF the buffer zone is 125 feet, then these requirements apply to resi-
dences within 100 feet of the buffer zone. Either the applicator 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.
100 ft
BufTerHone I 125ft
238ft
For additional information, please see EPA's Soil Fumigant Toolbox, www.epa.gov/oppsrrd1/reregistration/soiMlimigants/.
Soil Fumigant Mitigation: Emergency Preparedness and Response Requirements
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