United States Environmental Protection Agency Region 10
                                                            EPA910-F-09-002
                                 February 2009
                     Federal Air Rules for Indian Reservations
                     Fact Sheet:  Mint Slugs
What are Mint Slugs?

Mint slugs are the large quantities of solids gen-
erated after distilling oil from mint leaves. When
stored and composted properly, mint slugs are
an economically valuable source of nitrogen for
agricultural uses. However, when not managed
properly, mint slugs may combust and create an
air quality problem. Mint  slugs are considered an
asset to most growers. Uses include spreading
them on fields and plowing them under to en-
hance soil fertility and spreading them on roads
and by-ways to suppress weeds and dust. Where
facilities are available, mint waste is used as a
primary component of compost as shown  in this
operation at a vegetable production farm on the
Yakama Reservation.
What are the legal consequences for allowing
mint slugs to catch fire and smolder?

Mint Slug fires are not allowed under the Federal
Air Rules for Indian Reservations in Idaho, Or-
egon, and Washington (FARR) which prohibits
smoldering fires. Penalties for mint slug fires
which are allowed to burn and smolder can range
from $200 (for one day or less in violation) to
$10,000 or more, depending on how long the vio-
lation occurs, the potential for adverse health and
environmental impacts, and other factors. See
Additional Information section below for more
info about the FARR.
How can I learn how to prevent mint slug
fires?

The Washington Mint Growers Association
(WMGA) has developed best management prac-
tices for mint slug storage. The WMGA recom-
mend mint slug piles should be stored in a man-
ner that reduces the danger of fire and allows
access to control a fire. Information for how to
contact the WMGA to obtain these materials is
found in the Contacts section of this fact sheet.

Who should I contact if I have a mint slug fire?

First, alert the local fire department that you have
a fire which is potentially a hazard to human
health due to smoke. In coordination with that
authority,  take steps to put out the fire and stop or
prevent smoke. Also inform the US EPA Region
10 FARR Hotline at 1-800-424-4EPA, the Yakama
Nation Air Quality Program at (509) 865-5121 ext:
6078 and the WMGA at (509) 585-5460 as soon
as practicable.

What are the health effects of breathing
smoke from mint slug fires?

                              Burning mint
                             slugs tend to
                             smolder for
                              long periods
                             and create
                             heavy dense
                             smoke.  This
                             smoke can
                             cause health
                             problems when
                             the fine par-
ticles of smoke and soot are inhaled. Smoke has
many tiny particles which can get deep into lungs
and cause disease and respiratory problems.
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                             Who is most
                             affected by this
                             type of air
                             pollution?

                             Elders, children,
                             pregnant women
                             and people with
                             heart or respira-
                             tory diseases (like
                             asthma) are most
                             at risk from breath-
                             ing smoke and
                             particulate matter.
How do I get more information about Best
Management Practices and Mint Slugs?

The WMGA has developed educational materials to
help farmers and other owners of mint slugs learn
best management practices (BMPs) to prevent fires
and protect the public health. The practices also help
farmers get the most value from their commodity.
These BMPs are available by contacting the
association directly at the address below.

Who should I contact if I have further ques-
tions about outdoor burning and Mint Slugs?

US EPA Region 10 Contacts:
FARR Hotline
AWT 107
1200 6th Ave., Suite 900
SeatleWA, 98101
1-800-424-4372

Jerry Craig, US EPA, FARR Compliance & Outreach
15 West Yakima Ave., Suite 200,
Yakima, WA 98902
Craig.Jerry@epa.gov
(509) 952-3057

Washington Mint Growers Association:
Rod Christensen, Executive Director
Washington Mint Growers Association
100N.  Fruitland St., Suite B
Kennewick, WA 98336
rodc@agmgt.com
(509) 585-5460
                                                   Yakama Nation Contacts:
                                                   Greg T Scott, Air Quality Specialist
                                                   604 W 4th Ave. Suite E
                                                   Toppenish, WA
                                                   Greg@yakama.com
                                                   (509)865-5121 ext: 6078
Additional Information
Additional Information about the FARR is avail-
able at the EPA Region 10 FARR website
www.epa.gov/r1 Oearth/FARR. The website pro-
vides additional background information on the
rule and implementation of the FARR. The FARR
Hotline is available at 1-800-424-4EPA to provide
information, permit forms and respond to ques-
tions.
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