Worker Protection Measures 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 to protect fumigant handlers and workers from fumigant exposures. When new fumigant labels appear in the market place around 2010, fumigant users will need to comply with these new requirements to protect fumigant handlers and other workers.

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 to Protect Handlers and Workers

To address the risk to handlers and workers, the Agency is requiring:

A definition of handler activities on labels. Handlers are defined as persons

participating in the application as supervisors, loaders, drivers, co-pilots, and shovelers;
taking air samples to monitor fumigant air concentrations;
cleaning fumigant spills;
handling or disposing of fumigant containers;
cleaning, handling, adjusting, or repairing fumigation equipment that may contain fumigant residues;
installing, repairing, or operating irrigation equipment in the application block or buffer zone during the buffer zone period;
entering the application block or buffer zone during the buffer zone period to perform scouting or crop advising tasks; and
installing, perforating (cutting, punching, slicing, poking), removing, repairing, or monitoring tarps, until

after tarps are perforated and removed, if removal is done less than 14 days after the application is complete, or
14 days after the application is complete if tarps are not perforated and removed during those 14 days, or
48 hours after tarps are perforated if they will not be removed prior to planting.

Certified applicator supervision during the fumigant application
Certified applicator training (registrant developed)
Registrants provide handlers with training information
Two Worker Protection Standard (WPS)-trained handlers on site during all post-fumigation activities
Air monitoring during all handler activities
Air-purifying respirators must be worn if air monitoring indicates that label-specified air concentration levels are reached or if sensory irritation is felt
Respirators must be worn while tarps are being repaired if the entry prohibition period has not ended
All handlers must be fit-tested, trained, and medically examined
Respirator and cartridges must be made available for each handler
If tarps are used, they cannot be perforated until at least 5 days (120 hours) have elapsed after the fumigant is complete
Tarp removal cannot begin until at least 24 hours after tarp perforation is complete
Planting cannot begin until at least 48 hours after tarp perforation is complete
If tarps are left on for at least 14 days after the fumigation is complete, planting can occur when the tarps are being perforated
Tarps must be perforated using mechanical methods
Each tarp panel used for a broadcast fumigation must be perforated using a lengthwise cut
For broadcast applications only, if adverse weather conditions compromise the integrity of the tarp, the tarp may be perforated and removed before 5 days only if,

At least 48 hours have passed since the completion of the fumigation,
The buffer zone period is extended until 24 hours after tarp removal is complete, and
Subsequent fumigations of untreated areas within the application block do not occur for at least 24 hours after tarp removal is complete.

Entry into the treated area by any person, other than a correctly trained and PPE-equipped handler, is prohibited for a minimum of 5 days after the application is complete or until tarp removal is complete.

Figures 1, 2, 3, 4, and 5 provide illustrations of tarp perforation/removal and entry prohibition mitigation for different application scenarios. The intervals depicted are the minimum that must be followed.