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Fumigant Management Plans and Postapplication Summary Reports Fact Sheet
Current as of January 2010
Soil Fumigant Mitigation Measures
EPA is requiring important new safety measures for soil fumigant pesticides. This fact sheet summarizes new requirements for fumigant management plans (FMPs) and postapplication summary reports. When new fumigant labels appear in the marketplace around 2010, fumigators will need to ensure that a site-specific FMP is in place before beginning a fumigant application. They will also need to prepare a postapplication summary report to document any deviations from the FMP that may have been necessary, as well as results of air monitoring done during and after the application. For assistance in preparing these documents, please see:
- 2010 template for methyl bromide (10 pp, 217 KB, About PDF) for FMPs and post-application summaries
- 2011 template for methyl bromide (14 pp, 270 KB, About PDF) for FMPs and post-application summaries
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 mitigation 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 FMPs
To address the risk to bystanders, handlers and re-entry workers the Agency is requiring site-specific fumigant management plans (FMPs) and post application summary reports. Each site-specific FMP must contain the following elements:
- Applicator information (name, phone number, license number, employer name, employer address, date of completing registrant fumigant training program)
- General site information
- Application block location (e.g., address or global positioning system (GPS) coordinates)
- Name, address, and phone number of owner/operator of the application block
- Map, aerial photo, or detailed sketch showing field location, dimensions, buffer zones, property lines, roads, rights-of-ways, sidewalks, permanent walking paths, bus stops, water bodies, wells, nearby application blocks, surrounding structures (occupied and non-occupied), locations of posted signs for buffers, and sites requiring ¼ or 1/8 mile restriction (e.g., schools, state licensed day care centers, nursing homes, assisted living facilities, hospitals, in-patient clinics, and prisons) with distances from the application site labeled
- General application information (target application date/window, brand name of fumigant, EPA registration number)
- Tarp information and procedures for repair, perforation and removal (if tarp is used)
- Brand name, lot number, thickness
- Name and phone number of person responsible for repairing tarps
- Schedule for checking tarps for damage, tears, and other problems
- Maximum time following notification of damage that the person(s) responsible for tarp repair will respond
- Minimum time following application that tarp will be repaired
- Minimum size of damage that will be repaired
- Other factors used to determine when tarp repair will be conducted
- Name and phone number of person responsible for cutting and/or removing tarps (if other that certified applicator)
- Equipment/methods used to cut tarps
- Schedule and target dates for cutting tarps
- Schedule and target dates for removing tarps
- Soil conditions (description of soil texture in application block, method used to determine soil moisture)
- Weather conditions (summary of forecasted conditions for the day of the application and the 48-hour period following the fumigant application)
- Wind speed
- Inversion conditions (e.g., shallow, compressed (low-level) temperature inversion)
- Air stagnation advisory
- Buffer zones
- Application method
- Application rate from lookup table on the label (lb ai/A)
- Application block size from lookup table on the label (acres)
- Credits applied
- Buffer zone distance
- Description of areas in the buffer zone that are not under the control of the owner/operator of the application block
- Respirators and other personal protective equipment (PPE) for handlers (handler task, protective clothing, respirator type, respirator cartridge type, respirator cartridge replacement schedule, eye protection, gloves, other PPE)
- Emergency procedures (evacuation routes, locations of telephones, contact information for first responders, local/state/federal contacts, key personnel and emergency procedures/responsibilities in case of an incident, equipment/tarp/seal failure, odor complaints or elevated air concentration levels outside buffer zone suggesting potential problems, or other emergencies).
- Posting procedures (person(s) who will post signs, location of posting signs, procedures for sign removal)
- Site-specific response and management (if applicable)
- Fumigant site monitoring
- Description of who, when, where, and procedures for monitoring buffer zone perimeter
- Response information for neighbors
- List of residences, businesses, and neighboring property owners informed
- Name and phone number of person doing notification
- Method of providing the information
- State and tribal lead agency notification (If state and/or tribal lead agency requires notice, provide a list of contacts that were notified and date notified.)
- Plan describing how communication will take place between applicator, land owner/operator, and other on-site handlers (e.g., tarp cutters/removers, irrigators) for complying with label requirements (e.g., buffer zone location, buffer zone start/stop times, timing of tarp cutting and removal, PPE).
- Name and phone number of persons contacted
- Date contacted
- Authorized on-site personnel
- Names, addresses and phone numbers of all handlers
- Employer name, addresses, and phone numbers for all handlers
- Tasks that each handler is authorized and trained to perform
- Date of PPE training for each handler
- For handlers designated to wear respirators respiratory protection is required (minimum of 2 handlers), date of medical qualification to wear a respirator and date of fit testing for respirator.
- Air monitoring plan
- For buffer zone monitoring:
- Name, address, and, phone number of handler to perform monitoring activities
- Location and timing of monitoring for the buffer zone
- For handlers without respiratory protection:
- If sensory irritation is experienced, indicate whether operations will be ceased or operations will continue with respiratory protection
- If intend to cease operations when sensory irritation is experienced, provide the name, address, and phone number of the handler that will perform monitoring activities prior to operations resuming
- For handlers with respiratory protection:
- Representative handler tasks to be monitored
- Monitoring equipment to be used and timing of monitoring
- For buffer zone monitoring when using methyl bromide formulations with < 20% chloropicrin:
- Name, address, and phone number of person(s) to perform sampling
- Identify areas or structures to be monitored before reentry is permitted
- Monitoring equipment to be used and timing of the monitoring
- For monitoring the breathing zone when using methyl bromide formulations with < 20% chloropicrin:
- Representative handler tasks to be monitored
- Monitoring equipment to be used and timing of the monitoring
- Good Agricultural Practices (GAPs)
- Description of applicable mandatory GAPs (registrants may also include optional GAPs)
- Measurements and documentation to ensure GAPs are achieved (e.g., measurement of soil and other site conditions)
- Description of hazard communication. (The buffer zone around the application block has been posted in accordance with the label. Pesticide product labels and material safety data sheets are on-site and readily available for employees to review.)
- Record-keeping procedures (the owner/operator of the application block, as well as the certified applicator, must keep a signed copy of the site-specific FMP and the post application summary for 2 years from the date of application).
For situations where an initial FMP is developed and certain elements do not change for multiple fumigation sites (e.g., applicator information, authorized on-site personnel, record keeping procedures, emergency procedures) only elements that have changed need to be updated in the site-specific FMP provided the following:
- The certified applicator supervising the application has verified that those elements are current and applicable to the application block before it is fumigated and has documented the verification in the site-specific FMP.
- Recordkeeping requirements are followed for the entire FMP (including elements that do not change).
Once the application begins, the certified applicator must make a copy of the FMP available for viewing by handlers involved in the fumigation. The certified applicator or the owner/operator of the application block must provide a copy of the FMP to any federal, state, tribal, or local enforcement personnel who request the FMP. In the case of an emergency, the FMP must be made available when requested by federal/state/local emergency response and enforcement personnel.
New Requirements for Postapplication Summary Reports
Within 30 days of completing the application portion of the fumigation process, the certified applicator supervising the application must complete a post fumigation application summary that describes any deviations from the FMP that have occurred, measurements taken to comply with GAPs as well as any complaints and/or incidents that have been reported to him/her.
Specifically the Post-Application Summary must contain the following elements:
- Actual date of the application, application rate, and size of application block fumigated
- Summary of weather conditions on the day of the application and during the 48-hour period following the fumigant application
- Soil temperature measurement (if air temperatures were above 100 degrees F in any of the 3 days prior to the application)
- Tarp damage and repair information (if applicable)
- Location and size of tarp damage
- Description of tarp/tarp seal/tarp equipment failure
- Date and time of tarp repair
- Tarp removal details (if applicable)
- Description of tarp removal (if different than in the FMP)
- Date tarps were cut
- Date tarps were removed
- Complaint details (if applicable)
- Person filing complaint (e.g., on-site handler, person off-site)
- If off-site person, name, address, and phone number of person filing complaint
- Description of control measures or emergency procedures followed after complaint
- Description of incidents, equipment failure, or other emergency and emergency procedures followed (if applicable)
- Details of elevated air concentrations monitored on-site or outside the buffer zone (if applicable)
- Location of elevated air concentration levels
- Description of control measures or emergency procedures followed
- Air monitoring results
- When sensory irritation experienced:
- Date and time of sensory irritation
- Handler task/activity
- Handler location where irritation was observed
- Resulting action (e.g., cease operations, continue operations with respiratory protection)
- When using a direct read instrument
- Type of sample (e.g., area, breathing zone, structure)
- Sample date and time
- Handler task/activity (if applicable)
- Handler location or structure location
- Air concentration
- Sampling method
- Date of sign removal
- Any deviations from the FMP
In addition to recordkeeping requirements from 7 CFR part 110 “Recordkeeping Requirements for Certified Applicators of Federally Restricted Use Pesticides,” this decision requires that both the applicator and owner/operator of the application block keep a signed copy of the site-specific FMP and the post-application summary record for 2 years from the date of application.
Applicators and other stakeholders have the flexibility to use EPA’s template, prepare their own FMP templates, or use other commercially available software with certain elements listed above in check-list and/or fill in the blank format.