Emergency Preparedness and Response Fact Sheet

Current as of August 29, 2008

EPA is requiring important new safety measures for soil fumigant pesticides. This fact sheet summarizes new emergency preparedness and response requirements for fumigant applications. These requirements address potential risks to people who live or work near areas where soil fumigants are applied, in case the fumigant moves outside the buffer zone at concentrations of concern. When new fumigant labels appear in the marketplace in around 2010, fumigators will need to adopt these measures.

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 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 Emergency Preparedness and Response

To reduce risks to people who may be near a buffer zone (e.g., at their home or working in a nearby field), EPA is requiring applicators to either provide on-site monitoring of the buffer zone perimeter in areas where residences and other occupied structures are within a specific distance, or, as an alternative to on-site monitoring, provide emergency response information directly to neighbors. Whether measures are required depends on the size of the buffer zone and how close people may be to the buffer zone. An example of each element is discussed in more detail below.

When are Emergency Preparedness and Response Measures Needed?

If the buffer zone is less than or equal to:	AND	There is land (e.g., residential properties and businesses) NOT in the control of the property operator within this distance from the edge of the buffer zone:
Buffer ≤ 100 feet		50 feet
100 feet < Buffer ≤ 200 feet		100 feet
200 feet < Buffer ≤ 300 feet		200 feet
Buffer > 300 feet		300 feet

Then either monitoring of the buffer zone perimeter or providing emergency response information to neighbors is required.

Since site monitoring may be burdensome for users fumigating in areas with few residences or businesses, EPA is allowing users the option of providing emergency response information directly to neighbors at least 48 hours before fumigation begins.

If all of the land within 300 feet of the edge of the buffer zone is under the control of the property operator, then no site monitoring or informing neighbors would be required regardless of the size of the buffer zone.

Example Site Map for Informing Neighbors

Here is an example to clarify this requirement:

IF the buffer zone is 125 feet, the fumigator either needs to monitor air concentrations on the perimeter of the buffer between the treated field and people within 100 feet of the buffer zone; or the fumigator must provide emergency response information to those people. So the fumigator would need to monitor the buffer along the perimeter of the buffer zone near the houses with the diamond pattern or provide emergency response information to the people in the diamond houses.
This requirement does not affect the roadway, the property operator's residence (striped), or the plain house.
In this example, if all of the land within 100 feet of the edge of the buffer zone were under the control of the property operator, then no site monitoring or informing neighbors would be required.

diagram showing an example buffer zone for emergency prepardness and response for informing neighbors

Fumigation Site Monitoring

If emergency response measures are required based on the criteria described above, and the fumigator selects to monitor the buffer perimeter rather than providing information directly to the neighbors, here is what the fumigator must do:

Monitoring must take place from the beginning of the fumigant application until the buffer zone period expires.
Monitoring must be conducted by a certified applicator or someone under his/her supervision.
Monitoring of air concentration levels of the fumigant must take place in the area between the buffer zone and the residences or other occupied areas that meet the criteria above, which ranges between 50 and 300 feet from the edge of the buffer zone.
The person monitoring the air concentration levels must take air samples starting approximately 30 minutes after the start of application and at least once each hour during the entire application and buffer zone period.
A direct reading detection device, such as a Draeger device, must be used to monitor the air concentration levels of the fumigant being applied.
If at any time (1) the air concentrations are greater than or equal to a level specified on the label, OR (2) the person monitoring the air concentrations experiences eye irritation, an early sign of exposure to concentrations that exceed the action level on the fumigant label, then the emergency response plan detailed in the Fumigant Management Plan (FMP) must be immediately implemented by the person monitoring the air concentrations.
If other problems occur, such as a tarp coming loose, then the appropriate control plan must be activated.
The results of the air concentration monitoring must be recorded in the FMP.

EPA believes this will help ensure that if a problem occurs during or after the fumigation, the appropriate steps can be taken to reduce the risk of exposure. While protective, site monitoring may be burdensome for users fumigating in areas with few people. Therefore, EPA is allowing users the option of providing emergency response information directly to neighbors.

Response Information for Neighbors

As an alternative to on-site monitoring, the certified applicator supervising the fumigation (or someone under his/her direct supervision) would need to ensure that residences and businesses that meet the criteria outlined above have been provided the information below at least 48 hours before fumigant application in a specified field. The dates that fumigation is planned to take place may be stated as a range of dates, up to two weeks long. If an application fails to be made during the two-week window indicated, the information must be delivered again.

Information that must be provided includes:

Location of the application block
Name of fumigant products(s) to be applied, including EPA registration number
Applicator and property owner/operator contact information
Location of buffer zones
Time period in which the fumigation is planned to take place and the duration of buffer zone period
Early signs and symptoms of exposure to the fumigant(s) to be applied, what to do, and who to call if you believe you are being exposed (911 in most cases).

The method for distributing information to neighbors must be described in the FMP and may be accomplished through mail, telephone, door hangers, or through other methods that can be reasonably expected to effectively inform residences and businesses within the required distance from the edge of the buffer zone.

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