^QJV                        Office of Pesticide Programs (7506P)     November 2012     EPA735-F-12-012
    'ClJT*              Soil Fumigant Mitigation Factsheet:
    United States
    Environmental Protection     __   .   .           , _        ^  ,.       f     r*    <    i
    Agency                  Training  and Exam Options for  Pesticide
                            Applicators of Soil Fumigant Products
                            Information for Pesticide State Lead Agencies and Applicators
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 applicators, other fumigant handlers and
bystanders from fumigant exposures. The new Applicator Training requirement is 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 this new requirement.
   Training and Exam
 Options for Pesticide
   Applicators of Soil
   Fumigant Products
The Phase 2 soil fumigant product labels will include the following label
statement which requires certified applicators to successfully complete
training specific to soil fumigation:
"Any certified applicator supervising a soil fumigant application must have
successfully completed one of the soil fumigant training programs listed on the
following EPA Web page (http://www.epa.gov/fumiganttraining) for the active
ingredient(s) in this product. The training must be completed in the time frames
listed on the Web page. The FMP must document the date and location where
the soil fumigant training program was completed. "

Registrants of soil fumigant products offer EPA-approved on-line
training (and possibilities for in-person training) with exams. Although
not required, pesticide State Lead Agencies (SLAs) may also provide
applicators EPA-approved alternatives to registrant-sponsored training.

Note that compliance with the label-required training is a condition of
product use. Because soil fumigants are Restricted Use Products, only
certified applicators may purchase them. Contact the registrant about
additional requirements they may have for persons purchasing their
products.

EPA's Soil Fumigant Toolbox includes registrant-developed training
programs and identifies states with certified applicator training options
and requirements in addition to registrants' programs. State options may
include:
    1)  certification in a recently updated soil fumigation category or
       sub-category
    2)  training, independent of certification, administered by  the state or
    3)  a "challenge exam" administered by the state, independent of
       state certification or training.

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                                 More information on these state options is provided below. All programs
                                 must include an exam or other means to determine whether participants
                                 successfully completed the program.

                                 Additionally, before EPA will add programs to the website, EPA must
                                 review them and determine that they meet the criteria outlined below.

       Criteria for Soil          Criteria for Soil Fumigant Training Programs
     Fumigant Training               t        ...
                                       Approved training programs
             9                        v'  Provide applicators with documentation of successful
                                           completion
                                       S  Include a database of all applicators who have successfully
                                           completed the program so pesticide enforcement officials can
                                           verify applicators' compliance
                                       S  Have a process to evaluate the quality of training and
                                           incorporate improvements as necessary
                                       S  Cover the general topics listed below under "Content Check
                                           List for Soil Fumigant Training Programs"

  Content Check List for        Content Check List for Soil Fumigant Training Programs
  Soil Fumiqant Traininq           A-  Correct application of fumigants and compliance with new
          Proarams                       label recluirements
                                           Information on the following soil fumigants:
                                           o  	Methyl bromide
                                           o  	Chloropicrin
                                           o  	1, 3-Dichloropropene
                                           o  	Dimethyl disulfide (DMDS)
                                           o  	Metam sodium and metam potassium
                                           o  	Dazomet
                                       B.  Protecting handlers and bystanders
                                           o  Safety  information to handlers involved in the application
                                           o  Posting and where to place signs
                                           o  Respiratory protection requirements, and conditions for
                                              using a respirator
                                           o  Entry restricted period - when entry into a treated area is
                                              permitted, and who may enter during the entry restricted
                                              period
                                           o  Tarp perforation and removal restrictions
                                           o  Restrictions near Difficult-to-Evacuate Sites
                                           o  Triggers for Emergency Preparedness and Response
                                              Measures and options for complying
                                           o  Emergency response planning
                                       C.  Buffer zone distance calculations
                                       D.  Fumigation Management Plan requirements
                                       E.  Post- application Summary  requirements
                                       F.  Weather and site-specific conditions unfavorable for
                                           fumigant applications
                                       G.  Good Agricultural Practices requirements
                                       H.  Emergency response plan implementation
Soil Fumigant Mitigation: Training and Exam Options for Pesticide Applicators of Soil Fumigant Products

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    (1) State Option -
  Certification in a Soil
 Fumigation Category or
       Subcategory
    (2) State Option -
  Training Independent
    of SLA Applicator
  Certification Program
    (3) State Option -
     Challenge Exam
   Independent of SLA
 Applicator Certification
         Program
(1) State Option - Certification in a Soil Fumigation Category or
Subcategory

If a state has a certification category or Subcategory in soil fumigation
that has been updated to cover the content listed above, applicators in
that state will not need to complete the training offered by registrants
IF:
       S  The SLA requests that EPA review the program and list it on
          the EPA website
       S  EPA verifies that the content is at least equal to the content
          required for other programs, and
       -S  EPA lists the program on the website
          (http ://www. epa. gov/fumiganttraining)

(2) State Option - Training Independent of SLA Applicator
Certification Program

States may also choose to provide training to certified applicators in their
states independent of certifying applicators in a soil fumigation category.
      This is optional and would serve to provide additional
       opportunities for applicators to meet the label requirement to
       successfully complete training offered by registrants.
       Such training must meet the same criteria outlined above for
       approved programs, including a means,  such as an exam, to
       determine whether participants have successfully completed the
       training.
      States interested in offering this option must provide to EPA a
       description of their plans  to meet the criteria above as well as a
       copy of the proposed program materials that cover the content
       listed above.
      EPA will review the training materials and exam and upon
       approval, list them on the website
       (http://www.epa.gov/fumiganttraining)

(3) State Option - Challenge Exam Independent of SLA Applicator
Certification Program

A third option available to states is to offer a "challenge exam" to
determine whether applicators have acquired competency in soil
fumigation, including the content outlined above, independent of
certification  in soil fumigation or other training offered by the state.
If a state chooses to offer this option, the exam must:
       S  Assess knowledge and understanding of soil fumigation
          principles, protection of workers and bystanders, and labeling
          requirements outlined above under "Content Check List for
          Soil Fumigant Training Programs"
       S  Be administered by SLA or by a party approved by SLA (e.g.,
          Cooperative Extension Service or independent third party
          under contract with the state)
       -S  Be reviewed by EPA  and listed on the website
          (http ://www. epa. gov/fumiganttraining)
Soil Fumigant Mitigation: Training and Exam Options for Pesticide Applicators of Soil Fumigant Products

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      New Resource
States interested in offering the challenge exam option must provide to
EPA a description of their plans to meet the criteria above, as well as a
copy of the proposed exam and a description of how it will be
administered. Applicators must retest (or take training if the option is
available) every 36 months. This is generally expected to be a temporary
offering until an SLA is able to adopt a soil fumigation category.

New Resource
                                 The NASDA Research Foundation (NASDARF) under a cooperative
                                 agreement with the EPA has developed a manual, exam blueprint and
                                 item bank to incorporate the new requirements for soil fumigant
                                 applications. All three products include the content described above and
                                 are EPA-approved. SLA programs will meet EPA content requirements
                                 (described above) by adopting the three products as is. The manual is
                                 available on-line. For information, contact Carol (Ramsay) Black, EPA
                                 Project Director for the NASDA Research Foundation, at telephone
                                 (208) 301-3654 Pacific Time or carol@nasda.org. For information on the
                                 exam blueprint and item bank, contact Jeanne Kasai,
                                 kasai.ieanne@epa.gov.
   Certified Applicator
 Options for Complying
 with the Soil  Fumigant
 Training Requirement
Certified Applicator Options for Complying with the Soil Fumigant
Training Requirement

Certified Private or Commercial Applicators can purchase but not legally
use soil fumigants until at least one of the following options is taken.
                1) Soil fumigant training offered by
                          Registrant

                  Web-based or in-person training
                   course
                  Exam
                  Receive documentation of
                   completion
                  Applicators must retrain every 36
                   months
                    2) Certification in a Soil Fumigation
                        Category or Subcategory

                      Established or revised in 2012 or
                       after
                      Certification exam
                      Receive state certification
                      Applicator retraining falls within
                       SLA's recertification program and
                       cycle
                3) Soil fumigant training offered by
                             SLA
                  Web-based or in-person training
                   course
                  Exam or other means to determine
                   successful completion
                  Receive documentation of
                   completion
                  Applicators must retrain every 36
                   months
                   4) SLA Challenge Exam

                      Web-based or in-person exam
                      Receive documentation of
                       completion
                      Applicators must retest or retrain
                       every 36 months
For additional information, please see EPA's Soil Fumigant Toolbox, www.epa.gov/oppsrrd1/reregistration/soil_fumigants/.

Soil Fumigant Mitigation: Training and Exam Options for Pesticide Applicators of Soil Fumigant Products                                4

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