soil fumigation – new risk mitigation measures
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Soil Fumigation – New Risk Mitigation Measures. E. Randall Norton, Ph.D. The University of Arizona Safford Agricultural Center. Outline. Soil fumigant review Products available/affected Use distribution (crops by locations) Affected by new EPA rulings - PowerPoint PPT PresentationTRANSCRIPT
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E. Randall Norton, Ph.D.The University of ArizonaSafford Agricultural Center
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Soil fumigant reviewProducts available/affectedUse distribution (crops by locations)Affected by new EPA rulings
History of EPA Reregistration Eligibility Decisions (REDs)Timeline for implementationNew risk mitigation factors
20102011
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Re-licensing decisions for chemicals used as soil fumigants including:
Methyl bromideChloropicrinMetam Sodium/PotassiumDazomet
First comprehensive re-evaluation since products were first registered1,3-Dichloropropene (Telone EC, Telone II)
Not included in this round of REDs
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Amended REDs issued in June 2009Include measures to mitigate risks from fumigant pesticidesMeasures will be implemented through product labelsRevised labels with new measures will appear in the field 2010 and 2011
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20042005
20062007
20082009
20102011
Public Participation
process begins
Draft Risk Assessments Published for
Comment, Public
Meeting
Public Comment on
Risk Assessments
REDs Issued
RED Amendments
Issued
2010 Label Changes in
Effect
All Mitigation Measures on
Labels
Public Comment on Mitigation,
Public Meetings
Held
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Soil FumigantMajor Pests Controlled
Nematodes Plant Pathogens Weeds
Methyl Bromide 1,3-Dichloropropene Metam Sodium Metam Potassium Dazomet Chloropicrin
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EPA proprietary data, average usage 2006-2008
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EPA proprietary data, average usage 2006-2008
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EPA proprietary data, average usage 2006-2008
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EPA proprietary data, average usage 2006-2008
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EPA proprietary data, average usage 2006-2008
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EPA proprietary data, average usage 2006-2008
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EPA proprietary data, average usage 2006-2008
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AZDA 1080 Database, average usage 2000-2009
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Will not impact large acreagesWill have significant impact on some growers
Not a large number of producersOur goal (UA/Industry/AZDA)…
Identify this target audienceProvide needed educational programming regarding changesPrepare producers to deal with new regulations
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Package of measures that work together to:
Reduce potential for direct exposure to toxic concentrationsReduce likelihood of accidents and errorsFoster planning and complianceAssure appropriate response to exposures that occur
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2010 ImplementationGood Agricultural Practices (GAPs)RUP ClassificationHandler respiratory protectionTarp perforation and removal restrictionsReentry restrictionsFumigant Management Plans (FMPs)Registrant-provided handler information
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2011 ImplementationBuffers and buffer postingEmergency preparedness and responseRestrictions near difficult to evacuate sitesRegistrant-provided training and community outreach programs
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Good Agricultural PracticesDeveloped by registrants – based on input from growersReviewed by EPAMany of the GAPs are currently on label
RecommendationsGAPs will be mandatory
Compliance will be captured on FMPs
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GAPs are chemical specificExamples
Wind speed restrictionsSoil conditionsSoil temperatureSoil moisture
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Ground rig with soil incorporation:“At beginning of application, maximum soil temperature at injection depth is 90oF”
Chemigation:“At beginning of application, the maximum soil temperature is 90oF measured at 3 inches in depth”
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Restricted Use Product (RUP)All products containing methyl bromide, 1,3-Dichloropropene, and chloropicrin are currently RUPMany soil fumigant products containing metam sodium/potassium and dazomet are not currently RUP
EPA has determined all soil fumigants undergoing reregistration meet the criteria for restricted use
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Defined:A person performing “handler activities”
Anybody involved in any activity relating to the application of a restricted soil fumigant
Handlers must stop work or use respirators if air concentrations exceed acceptable limits or if they experience sensory irritation
Fit-testedTrainedPhysically fit to wear a respirator
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Current labels allow reentry after 48 hoursReentry times lengthened
Untarped applications5 days
Tarped applicationsVary depending on tarp perforation or removal intervals
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Implemented in 2010Capture current and 1st phase label requirements
Expansion in 2011Capture second phase requirements
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Written, site-specific plan must be completed prior to fumigationDesigned to…
Ensure fumigators successfully plan all aspects of a safe and effective fumigationPrevent accidents, ensure label compliance, and identify appropriate procedures in case of accidentsDemonstrate compliance with label requirements
Tool for verifying compliance
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Information required – 2010General site and applicator informationApplication proceduresMeasurements taken to verify compliance with GAPsHandler protection informationAir monitoring and hazard communication proceduresPosting and record keeping proceduresEmergency plans and proceduresHandler training information providedPost-application summary report
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Must be available…For viewing on-site by handlersTo enforcement personnel upon requestTo emergency response personnel in case of emergency
FMP for methyl bromide currently available on EPA website
Others to follow soonWeb-based system under development
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Buffer zonesArea around the application block where bystanders must be excluded during the buffer zone period (except for people in transit)Buffer zone period starts when the fumigant is first delivered and is in effect for 48 hours after the fumigant has stopped being delivered to the soilDistance is determined by:
Treated block sizeRate
• Method• Outlined on label
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• Must be posted at usual points of entry and along likely routes of approach unless a physical barrier prevents access– Roads, sidwalks, walking paths, bike trails
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• Must include:– “Do Not Walk” symbol– “Do Not Enter/No
Entre”– Name of fumigant,
name of product– Certified applicator
contact information
DO NOT ENTER/NO ENTREMetam Sodium Fumigant
Buffer ZoneContact: Jon Doe
888.555.1234
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• Emergency Preparedness and Response– If occupied structures are in close
proximity to buffer zone applicator must choose:• “Fumigant Site Monitoring” or• “Response Information for Neighbors”
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• Buffer zone=125’, any occupied structures within 100’ of buffer zone– Residents must be provided with emergency
response information or the area between buffer zone and house must be monitored
– Occupied structure >100’ from buffer zone no action needed
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• Defined:– Schools (pre-K through12)– State licensed daycare– Nursing homes– Assisted living facilities– Hospitals– In-patient clinics– Prisons
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• If buffer zone >300 feet– Difficult to Evacuate Site must not be
within 1/4 mile (1320 ft) of the treated area
• If buffer zone is <300 feet– Difficult to Evacuate Site must not be
within 1/8 mile (660 feet) of the treated area
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• UA Cooperative Extension along with industry and AZDA– Conduct trainings (6) across Arizona
• Hands-on instruction– Yuma will be first later this fall
• Remainder in mid-January– Need to target audience – identify those
needing training