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Site-Specific Emergency Preparedness and Response Fact Sheet
Soil Fumigant Mitigation Measures
Current as of May 27, 2009
EPA is requiring important new safety measures for soil fumigant pesticides. This fact sheet summarizes new emergency preparedness and response requirements for fumigant applications. These requirements address potential risks to people who live or work near areas where soil fumigants are applied, in case the fumigant moves outside the buffer zone at concentrations of concern. New fumigant labels that appear in the marketplace in 2011 will require fumigators to adopt these measures.
Due to their volatile nature, soil fumigants have the potential to pose risk concerns to people involved in the application (handlers), workers who re-enter fumigated fields (workers), and people who may be near the treated area (bystanders). EPA’s Amended Reregistration Eligibility Decisions (REDs) for the fumigants chloropicrin, dazomet, metam sodium/potassium, and methyl bromide include a suite of measures designed to work together to reduce exposures, enhance safety, and facilitate compliance and enforcement. These measures include:
- worker protections
- fumigant management plans
- stewardship and training programs
- good agricultural practices
- buffer zones
- posting requirements
- emergency preparedness and response measures
The Amended REDs are based on public comments and new scientific data and information submitted in response to EPA’s July 2008 Soil Fumigant REDs. For additional information, please see the Agency’s Web page on risk mitigation measures for the soil fumigants.
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?
| If the buffer zone is Less than or equal to | AND | There is land (e.g., residential properties and businesses) NOT in the control of the property operator within this distance from the edge of the buffer zone: |
| 26 feet to 100 feet | 50 feet | |
| 101 feet to 200 feet | 100 feet | |
| 201 feet to 300 feet | 200 feet | |
| Greater than 300 feet or buffer zones overlap | 300 feet | |
| Then either monitoring of the buffer zone perimeter or providing emergency response information to neighbors is required. | ||
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/operator of the fumigated field, then Emergency Preparedness and Response measures are not required regardless of the size of the buffer zone.
Because site monitoring may be burdensome for users fumigating in areas with few residences or businesses, EPA is allowing fumigant users the option of providing emergency response information directly to neighbors instead of monitoring.
Example Site Map for Informing Neighbors
Below is an example to clarify this requirement:
- IF the buffer zone is 125 feet, then these requirements apply to residences 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.
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Fumigation Site Monitoring
If emergency response measures are required based on the criteria described above, and the fumigator chooses to monitor the buffer perimeter rather than to provide information directly to the neighbors, here is what the fumigator 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.
- Air concentrations are determined for metam sodium/potassium, dazomet, chloropicrin, and methyl bromide products that include least 20% chloropicrin concentrations by sensory irritation.
- 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 FMP must be immediately implemented.
- If other problems occur, such as a tarp coming loose, then the appropriate control plan must be activated.
- The location and results of the air monitoring must be recorded in the FMP.
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 fumigation (or someone under his/her direct supervision) would need to ensure that residences and businesses that meet the criteria outlined above have been provided the information below at least one week before fumigant application in a specified field. The dates that fumigation is planned to take place may be stated as a range of dates, up to four weeks long. If an application is not made during the four-week window indicated, the information must be delivered again.
Information that must be provided includes:
- The general 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 for distributing informations to neighbors must be described in the FMP and may 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.