Soil Fumigant Overview il i i 15 February 2011 The Pesticide Stewardship Alliance 11 th Annual Conference San Antonio, TX 1
Outline Outline • The Reregistration Process Th R i t ti P • Implementation & Mitigation Measures • Incidents • Enforcement and Compliance Guidance Enforcement and Compliance Guidance • EPA Outreach Materials 2
Reregistration Eligibility Decisions (REDs) • Re ‐ licensing decisions for chemicals used as soil fumigants – Methyl Bromide – Chloropicrin – Metam Sodium/Metam Potassium – Dazomet • First comprehensive re ‐ evaluation since products first registered 3
Overview ‐ Goals • Protect workers and bystanders while y maintaining key benefits of use • Ensure a level playing field across all soil Ensure a level playing field across all soil fumigants • Make risk management decisions that are • Make risk management decisions that are protective and that take into account likely real ‐ world outcomes 4
Regulatory Process Timeline 2004: 2004 2006: 2006 2008: Late 2010: Public Public REDs issued, Phase 1 label participation comment on include new label changes p process begins g risk statements in effect assessments 2009: RED Late 2011: 2005: 2007: Amendments All mitigation Draft risk Public comment issued, include measures assessments on mitigation updated labeling updated labeling on labels on labels and public d bli proposals, public l bli briefing meetings 5
Mitigation Implementation Schedule Risk Mitigation Measure Risk Mitigation Measure Phase Phase Phase Phase 1 2 Rate reductions and use site limitations ● ● Restricted use (new measure for metam sodium/ ( ● ● potassium & dazomet only) Good Agricultural Practices (GAPs) ● ● ◙ under development New handler protections including changes to New handler protections including changes to ● ● ● ● respiratory protection, tarp cutting/removal and ● adopt fully worker reentry restrictions ● ● Safe handling information Fumigant management plans and post ● / ◙ ● application summaries ● Buffer zone distances, credits, and posting Emergency preparedness measures ● Difficult to evacuate sites ● Notice to state lead agencies Notice to state lead agencies ● Certified applicator training, first responder, ◙ ● community outreach
Data on Acute Illnesses • Data obtained from Sentinel Event Notification System for Occupational Risks (SENSOR) ‐ Pesticides Program and the CDPR (1998–2006) • Cases ‐ 11 states 11 states ‐ 2.945 illnesses ‐ 643 “drift” events (including volatilization) • Fumigants • Fumigants ‐ Small percent of events (8%) ‐ Largest proportion (44%) of illness cases g p p ‐ Common factors: weather issues, improper measures to prevent fumigant from escaping, and applicator carelessness 7
2008 Washington Incident g • In 2008; 35 gallons/A of Metam 42% CLR product applied to 150 acres field using center pivot after harvest acres field using center pivot after harvest • Family of 17 lived 380 ft from field • 19 reported symptoms (including sheriff deputy) • 12 sought medical attention (including 2 ‐ week old infant) • WA Dept of Health ‐ contributing factors were: • WA. Dept. of Health ‐ contributing factors were: ‐ Inversion conditions ‐ Low wind speed (< 2 mph) ‐ Home down gradient (150 ft drop down slope) of field H d di (150 f d d l ) f fi ld ‐ Inadequate field preparation (crop residues in field) ‐ Residents unaware of application pp ‐ Improper emergency response 8
2008 Washington Incident Relevant Mitigation • Home located with 380 ft would be in the buffer zone Home located with 380 ft would be in the buffer zone and application scenario from incident would be prohibited unless occupants provided written agreement to voluntarily vacate home during buffer zone period voluntarily vacate home during buffer zone period • New labels have specific requirements related to wind speed, weather, and indentifying unfavorable weather p , , y g conditions • Depending on size of buffer and proximity to homes, applicator is required to either monitor the air between the buffer zone and homes or provide response information to the neighbors 9
2010 Idaho Incident • 99% chloropicrin product applied to 2 fields (25 acres and 75 acres) application method was shank bed and 75 acres), application method was shank bed untarped • People at a drive ‐ in theater (surrounded on 3 sides by p ( y the fumigated fields) complained of burning eyes and trouble breathing • Once the fire department arrived, people were NOT permitted to leave the theater • Reported contributing factor, end ‐ of ‐ row soil sealing d b f d f l l 10
2010 Idaho Incident Relevant Mitigation • New labels have Good Agricultural Practices (GAPs) • New labels have Good Agricultural Practices (GAPs) that address soil sealing and prevention of end row spillage • Registrants will be required to provide emergency responders, in high fumigant use areas, information and training materials necessary to respond to d i i i l d fumigant incidents • Emergency Response Plans must be included in the • Emergency Response Plans must be included in the Fumigant Management Plan (FMP) which identifies emergency procedures and responsibilities 11
Enforcement & Compliance Guidance • Compliance assistance in 2011 ‐ 2012 C li i t i 2011 2012 ‐ Work with users to help understand labeling and how to comply • Compliance monitoring in 2012 ‐ 2013 ‐ Ensure compliance with labeling • Response to complaints ‐ Label violations? Egregious? ‐ Judgment needed J d d d 12
EPA’s Outreach Materials EPA s Outreach Materials Fact Sheets Presentations Tools and Templates l d l Visit Visit… http://www.epa.gov/pesticides/reregistration/soil_fumigants/index.htm O i Or internet search for . . . h f “ soil fumigant implementation ” 13
EPA Contact Information G General Contact: l C t t • John Leahy (703) 305 ‐ 6703 Team Leaders: Team Leaders: • Steven Weiss (703) 308 ‐ 8293 • Cathryn O’Connell (703) 308 ‐ 0136 • Eric Olson (703) 308 ‐ 8067 Chemical Review Managers: • Methyl bromide: Susan Bartow (703) 603 ‐ 0065 Methyl bromide: Susan Bartow (703) 603 ‐ 0065 • Metam sodium/potassium: José Gayoso (703) 347 ‐ 8652 • D Dazomet: Dana Friedman (703) 347 ‐ 8827 t D F i d (703) 347 8827 • 1,3 ‐ D & Chloropicrin: Andrea Mojica (703) 308 ‐ 0122 E ‐ mail: lastname.firstname@epa.gov @ p g 14
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