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Implementating New Safety Measures for Soil Fumigant Pesticides

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Soil Fumigant Pesticides

Current as of November 2010

Overview

Soil Fumigant Training Materials including fumigant safe handling information for fumigant handlers are now available.

EPA is requiring important new safety measures for soil fumigant pesyesticides 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:

Soil fumigants are pesticides that, when applied to soil, form a gas to control pests that live in the soil and can disrupt plant growth and crop production.  Soil fumigants are used on many high value crops and provide benefits to growers in controlling a wide range of pests, including nematodes, fungi, bacteria, insects and weeds.  As gases, however, fumigants move from the soil to the air at the application site and may move off site at concentrations that produce adverse health effects in humans from hours to days after application.  These health effects range from mild and reversible eye irritation to more severe and irreversible effects, depending on the fumigant and the level of exposure.

On this page:

Schedule for Implementing New Safety Measures: (Fact Sheet) To achieve new protections, many new safety measures will appear on soil fumigant product labels by late December 2010.  All new safety measures, including buffer zones, will be included on fumigant labels by late 2011. 

Implementation Schedule for Soil Fumigant Risk Mitigation Measures
Risk Mitigation Measure 2010 2011
Restricted Use (metam sodium/potassium and dazomet only: methyl bromide
and chloropicrin were already RUPs)
•
•
New Good Agricultural Practices
•
•
Rate reductions
•
•
Use site limitations
•
•
New handler protections
•
•
Tarp cutting and removal restrictions
•
•
Extended worker reentry restrictions
•
•
Safety information for workers
•
•
Fumigant Management Plans
°
•
First responder and community outreach
°
•
Applicator training
°
•
Compliance assistance and assurance measures
°
•
Restrictions on applications near sensitive areas
•
Buffer zones around all treated fields
•
Buffer credits for best practices
•
Buffer posting
•
Buffer overlap prohibitions
•
Emergency preparedness measures
•
° = under development/partial implementation
• = adopt completely

Risk Mitigation Measures for Soil Fumigants:  EPA is requiring a suite of complementary mitigation measures to protect handlers, reentry workers, and bystanders from risks resulting from exposure to the soil fumigant pesticides. These measures are designed to work together to address all risks, but focus on the acute human inhalation risks that have been identified in the revised risk assessments for these fumigants.

Most of the measures summarized here apply to all of the soil fumigants (for example, fumigant management plans).  See fact sheets explaining implementation of these general risk mitigation measures. However, some measures are specific to individual fumigants (for example, buffer distances). The fumigant-specific measures are explained in detail in chemical-specific Amended REDs.

Measures include:

Buffer Zones: (Fact Sheet) EPA is requiring fumigant users to establish a buffer zone around treated fields to reduce risks to bystanders. A buffer zone provides distance between the application site (i.e., edge of field) and bystanders, allowing airborne residues to disperse before reaching the bystanders. This buffer will reduce the chances that air concentrations where bystanders are located will cause adverse health effects.
EPA has selected buffer distances that will protect bystanders from exposures that could cause adverse effects, but that are not so great as to eliminate benefits of soil fumigant use. The size of the buffer zones is based on the following factors:

Buffer zone distances will be provided in look-up tables on product labels. EPA is also giving "credits" to encourage users to employ practices that reduce emissions (for example, use of high-barrier tarps). Credits will reduce buffer distances. Some credits will also be available for site conditions that reduce emissions (e.g., high organic or clay content of soils).

Posting Requirements: (Fact Sheet) For buffer zones to be effective, bystanders need to be informed about their location to ensure they do not enter areas designated as part of the buffer zone. EPA is requiring that buffer zones be posted at usual points of entry and along likely routes of approach to the buffer unless a physical barrier prevents access to the buffer.  

The signs must include a “do not walk” symbol, fumigant product name, and contact information for the fumigator.

Agricultural Worker Protections: (Fact Sheet) Persons engaged in any of a number of activities that are part of the fumigation process are considered “handlers.”  Handler activities include operating fumigation equipment, assisting in the application of the fumigant, monitoring fumigant air concentrations, and installing, repairing, perforating, and removing tarps.

Respiratory Protection: Many current labels require handlers to use respirators when air concentrations in the area where they are working reach certain action levels, but do not require monitoring to determine if the action levels have been reached. New labels will require handlers to either stop work or put on respirators if they experience sensory irritation.
In most cases inhalation risks can be mitigated with the use of air purifying respirators if they choose to continue working after experiencing sensory irritation. For scenarios involving very high air concentrations where these respirators do not provide adequate protection, EPA is requiring handlers to stop work and leave the area. If there is an emergency involving applications of methyl bromide or chloropicrin, then a self contained breathing apparatus (SCBA) may be required.
Additionally, EPA is requiring that handlers be:

Applicator Training Programs and Safety Information for Handlers: EPA is requiring fumigant registrants to develop and implement training programs for applicators in charge of soil fumigations so these applicators are better prepared to effectively manage fumigant operations. The registrants also must prepare and disseminate safety information and materials for fumigant handlers (those working under the supervision of the certified applicator in charge of fumigations). Providing safety information to other fumigant handlers will help them understand and adhere to practices that will protect them from risks of exposure. The materials must include information on work practices that can reduce exposure to fumigants, and thereby improve safety for workers and bystanders.

Good Agricultural Practices: Current fumigant labels recommend practices that help reduce off-gassing and improve the safety and effectiveness of applications.  The Agency has determined that including certain practices on labels as requirements rather than recommendations will minimize inhalation and other risks from fumigant applications.  Several fumigant products already incorporate some of these measures on their labels.  Examples of good agricultural practices include proper soil preparation/tilling, ensuring optimal soil moisture and temperature, appropriate use of sealing techniques, equipment calibration, and weather criteria.

Application Method, Practice, and Rate Restrictions: The Agency is restricting certain fumigant application methods that lead to risks that are difficult to address. These include certain untarped applications for some fumigants. EPA is also lowering maximum application rates to reflect those rates needed for effective use, thereby reducing the potential for inhalation exposure and risk.

Restricted Use Pesticide Classification: All soil fumigant products containing methyl bromide, 1,3-dichloropropene, iodomethane, and chloropicrin are currently restricted use pesticides, but many soil fumigant products containing metam sodium/potassium and dazomet were not restricted use pesticides.  The Agency has determined that all of the soil fumigants undergoing reregistration meet the criteria for restricted use.  Therefore, EPA has reclassified metam sodium/potassium and dazomet as restricted use pesticides.

Site-Specific Fumigant Management Plans (FMPs): (Fact Sheet; Templates)  Soil fumigations are complex processes that require specialized equipment and practices to properly apply volatile and toxic pesticides. EPA's risk mitigation allows for site-specific decisions to address the conditions where the fumigant is applied. To address this complexity and flexibility, EPA is requiring that fumigant users prepare a written, site-specific fumigant management plan before fumigations begin. Written plans and procedures for safe and effective applications will help prevent accidents and misuse and will capture emergency response plans and steps to take in case an accident occurs.

Fumigators will capture in the FMP how they are complying with label requirements. FMPs will help ensure fumigators successfully plan all aspects of a safe fumigation, and will be an important tool for federal, state, tribal, and local officials to verify compliance with labeling.

The certified applicator supervising the fumigation must verify in writing that the FMP is current and accurate before beginning the fumigation. A post-application summary describing any deviations that may have occurred from the FMP will also be required within 30 days of the end of the application.

The fumigator and the owner/operator of the fumigated field must keep the FMP and post-application summary for two years and make them available upon request to federal, state, tribal, and local enforcement officials.

Emergency Preparedness and Response Requirements: (Fact Sheet) Although buffers and other mitigation will prevent many future incidents, it is likely that some incidents will still occur due to accidents, errors, and/or unforeseen weather conditions. Early detection and appropriate response to accidental chemical releases is an effective means of reducing risk. Preparedness for these types of situations is an important part of the suite of measures necessary to avoid risks posed by fumigants.

First Responder Education: EPA is requiring registrants to provide information to first responders in high fumigant use areas. This will help to ensure that emergency responders are prepared to effectively identify and respond to fumigant exposure incidents.

Site-Specific Response and Management Activities: EPA is requiring site-specific measures in areas where bystanders may be close to fumigant buffer zones. Fumigators may choose either to monitor the buffer perimeter or to provide emergency response information directly to neighbors. If site specific measures are required, and the fumigator chooses to monitor, the emergency response plan stated in the Fumigant Management Plan must be implemented if the persons monitoring detect fumigants moving outside the buffer zone toward places where people are. This monitoring must be done during the full buffer zone time period at times when the greatest potential exists for fumigants to move off-site.



If the fumigator chooses instead to provide emergency response information directly to neighbors, the certified applicator supervising the fumigation, or someone under his/her direct supervision, must ensure that nearby residents and business owners/operators have been provided the response information at least one week prior to fumigant application. The method for distributing information to neighbors must be described in the Fumigant Management Plan.

Compliance Assistance and Assurance Measures: Assuring compliance with new label requirements is an important part of the package of mitigation measures. Some but not all states have mechanisms in place to obtain information needed to assist and assure compliance with new fumigant requirements. Therefore, in states that wish to receive more information, fumigators must notify State and Tribal Lead Agencies for pesticide enforcement about applications they plan to conduct. This information will aid those states in planning compliance assurance activities.

Community Outreach and Education Programs: EPA is requiring fumigant registrants to develop and implement community outreach programs to ensure that information about fumigants and safety is available within communities where soil fumigation occurs. Outreach programs will address the risk of bystander exposure by educating community members about fumigants, buffer zones, how to recognize early signs of fumigant exposure, and how to respond appropriately in case of an incident.

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