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Fumigant Management Plans and Postapplication Summary Reports Fact Sheet
Current as of August 29, 2008
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.
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 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
EPA is accepting public comment until October 30, 2008, on implementation of the risk mitigation measures in the soil fumigant REDs. For additional information, please see the Agency's August 29, 2008, and July 16, 2008, Federal Register notices announcing these decisions, and 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:
- General site information
- Site address or description of location
- Site operator/owner's name, address, and, phone number
- Map, aerial photo, or detailed sketch showing field location, dimensions, buffer zones, property lines, public roads, bus stops, water bodies, wells, rights-of-ways inside buffers, nearby application blocks, surrounding structures (occupied and unoccupied), locations of posted signs for buffers, and sites requiring ¼ mile buffer zones (e.g., prisons, schools, hospitals, state licensed daycare centers) with distances from the application site labeled
- Applicator information (license number, address, phone, contact information for person supervising the fumigation with location and date for completing registrant methyl bromide training program)
- Authorized on-site personnel (names of all handlers and the tasks they are authorized and trained to perform)
- Application procedures
- Fumigation window (target application date, earliest and latest possible date of fumigation)
- Product information (brand name, registration number)
- Type of fumigation (e.g., shank, broadcast, drip, raised bed, strip, etc.)
- Target application rate and application block size
- Good Agricultural Practices (GAPs)
- Description of applicable mandatory GAPs (registrants may also include optional GAPs)
- Measurements and other documentation planned to ensure GAPs are achieved (e.g. measurement of soil and other site conditions; tarp repair/perforating/removal plans; etc.)
- Buffer zones
- Calculations and rationale for buffer zone distances (i.e., specify table from label that distances are based on, rate and block size, applicable credits applied)
- Start and stop times for buffer zones
- Respirators and other personal protective equipment (PPE) for handlers (respirator type, respirator cartridge, and other PPE selection; verification that respirator training/fit-testing/medical exam are current; and maintenance/storage procedures)
- Air monitoring
- Type of samples that will be collected (e.g., occupational, in occupied structures, outside buffer zone area if site monitoring is conducted, etc.)
- When and where samples will be collected
- Duration of samples
- Sampling methods and equipment
- Name, address, and, phone number of person taking samples
- Posting (names of persons who will post signs, location of posting signs, procedures for posting and sign removal)
- Site-specific response and management
- Fumigant site monitoring
- Description of who, when, where, and procedures for monitoring buffer zone perimeter
- Response information for neighbors
- List of residences and businesses informed (neighboring property owners)
- Method of sharing information
- State and tribal lead agency notification
- Include the information that is sent to the lead agency
- Plan describing how communication will take place between applicator, land owner/operator, and other on-site handlers (tarp cutters/removers, irrigators, etc.)
- Record keeping procedures
- 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).
- Hazard communication (product labels, material safety data sheets, etc.)
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, etc.), 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 and owner/operator of the application block must provide a copy of the FMP to handlers involved in the fumigation, workers in adjacent areas to the application block, and federal/state/local enforcement personnel, upon request.
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 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. The summary must include the actual date of the application, application rate, and size of application block fumigated.
The certified applicator and owner/operator of the application block must provide a copy of the FMP and post fumigation application summary to handlers involved in the fumigation, workers in adjacent areas to the application block, and federal/state/local enforcement personnel, upon request.
Both the applicator and owner/operator of the application block must keep a signed copy of the site-specific FMPs and the post-application summary record for two years from the date of application.