Soil Fumigation In Idaho

Idaho State Department of Agriculture Division of Agricultural Resources Bob Spencer Deputy Administrator/Bureau Chief (208) 332-8613 bob.spencer@agri.idaho.gov 4/13/2017

Potato Cyst Nematode Control Area

FIELD POSTING

Is Already Required by WPS Field Posting Is Already Required by WPS

Treated Area Posting Signs DANGER/PELIGRO Area under fumigation, DO NOT ENTER/NO ENTRE [Name of fumigant] Fumigant in USE Time of fumigation Time when the entry prohibition is lifted Brand name of the product Name, address, and telephone number of the certified applicator in charge of the fumigation Reminder that treated area signs are already required for fumigant labels. Here is an example of those signs. EPA has not changed any of the requirements for these signs as part of these REDs.

FIELD POSTING Used to be only for the protection of handlers & workers Fields did not need posting if there were no workers within ¼ mile of treated area 2010 – Posting will be required for all fields Helps protects handlers, workers and the public

BUFFER ZONES

HOMES +300 foot notification HOMES

Posting of Buffer Zones Required in 2011 Posting required unless there is a physical barrier preventing bystander access to buffer zone Post signs at usual places of entry and along likely routes of approach where people may enter buffer zone roadways, sidewalks, bike paths, trails

Buffer zone sign must include: This slide shows the information that buffer zone posting must display. It should be noted that content of these signs is different than the signs posted at the field edge. “Do Not Walk” symbol "DO NOT ENTER/NO ENTRE," "[Name of fumigant, name of product] Fumigant BUFFER ZONE” certified applicator contact information 11 11

Posting of Buffer Zones Signs must be posted prior to the application and remain until the Buffer Zone Period Expires Signs must face away from treated area towards area where people will approach Signs must remain legible during the entire posting period Signs must be removed within 3 days after the end of the Buffer Zone Period If multiple contiguous blocks are fumigated, only the periphery of the blocks needs to be posted

Difficult to Evacuate Sites

Difficult To Evacuate Sites (DES) Difficult-to-evacuate sites (DES) are: Schools (preschool-12) State licensed daycare centers Nursing homes Assisted living facilities Hospitals In-patient clinics Prisons DES includes the building and property The goal is to ensure school children, the sick, elderly and others who may be difficult to evacuate have another measure protecting them in addition to the buffer zone in the case of an incident. Certain types of sites are difficult to evacuate should an incident occur. EPA determined that additional measures to reduce the potential need to evacuate these types of sites were necessary to reduce risk of exposure to occupants and address potential challenges associated with an accident. 2011 labels will define difficult to evacuate sites as: (see list on slide) The “site” includes the building that might house children, elderly, sick and/or prisoners and the adjoining property that can be readily accessed such as play areas, fields, common areas, and/or park areas.

Difficult to Evacuate Sites Licensed Day Care Centers

Difficult to Evacuate Sites Schools – Preschool - 12

Difficult to Evacuate Sites Hospitals

Difficult to Evacuate Sites Nursing Homes

Difficult to Evacuate Sites If the buffer zone is 300 feet or less, then no fumigant applications will be permitted within 1/8 mile unless site is unoccupied during the application and 36 hours after the application No fumigant applications with buffer zones greater than 300 feet are permitted within ¼ mile

Difficult To Evacuate Sites The DES must be un-occupied during and for 36-hours after fumigation. Saturday Morning 12 6 Complete Application by 6 PM Saturday Evening 12 6 12 6 Saturday Evening 12 6 Monday Morning In order to allow fumigation around some difficult to evacuate sites, EPA is requiring the sites be unoccupied for the duration of the application and 36 hours following the application. [The buffer zone is in effects for 48 hours.] Example: Application begins on Sat. morning from 6 AM – 6 PM but it could occur earlier. Saturday evening at 6:00 PM to Monday morning at 6:00 AM is 36 hours, in time for students to return to school or day care. Begin Application at 6 AM 6:00 AM Sat. to 6:00 PM Sat. DES unoccupied 6:00 PM Sat. to 6:00 AM Mon. DES unoccupied 36 hrs 24 24

Buffer Zone = 250 ft Distance = 350 ft. Example: RED solid line = school property RED STRIPED line area = 250 ft buffer zone Q: How far does the TREATED AREA need to be from the OCCUPIED SCHOOL SITE? A: 660 feet Q: What can the grower do to make this application? A: The grower notices the land within 660 ft of the field is outdoor areas like a track and tennis courts. If the grower talks to the school and determines there will not be any school events at those locations (those areas will not be occupied by students) during the application and 36 hrs after, the application could go on. Note: Since the goal of this measure is to ensure people who may be difficult to evacuate, like school children, have another measure protecting them, it may be OK for others to be playing on these fields like families, etc. (since they are outside the buffer zone). The concern is children that may be dropped off by a bus for the day may not have an easy way to leave if an incident happens to occur.

Difficult to Evacuate Sites If fumigated area is between 1/8 Mile (660 ft) and ¼ Mile (1320 ft) from a DES: If the DES is occupied during and for 36-hours after the fumigation has ended, the buffer must be less than 300 ft, OR, If the DES is un-occupied during and for 36-hours after the fumigation has ended, the buffer must be less than 600 ft. If fumigated area is between 1/8 Mile (660 ft) and ¼ Mile (1320 ft) from a Difficult To Evacuate Site: The difficult to evacuate site may be occupied during the fumigation and 36 hours afterwards, but the buffer zone must be less than 300 feet. OR If the site is un-occupied during the fumigation and 36-hours after the fumigation has ended, then the buffer zone could be any distance.

>1/8 Mile to <1/4 Mile From Difficult To Evacuate Site Buffer Zone = 250 ft >1/8 Mile to <1/4 Mile From Difficult To Evacuate Site Distance = 700 ft Example: TREATED AREA = Further than 1/8 mile (660 ft) but less than ¼ mile (1320 ft), in this example the treated area is 700 ft from the difficult to evacuate site. RED SOLID LINE = property line around the difficult to evacuate site. RED STRIPED LINES = 250 ft buffer zone. Q: What must the grower do to make this application? A: The fumigated area is further than 1/8 mile (660 ft) but less than ¼ mile (1320 ft) from a difficult to evacuate site, including the track and tennis courts. Since the buffer zone is less than 300 ft, the fumigation can occur at any time. 27

School: ¼ mile buffer X X +300 foot notification X X School X X OK X X

Difficult to Evacuate Sites If fumigated area is greater than ¼ Mile (1320 ft) from a DES: There are no additional restrictions.

Review Question Which location(s) is/are NOT included in the list of Difficult to Evacuate Sites on the label? A) State licensed day care centers B) Non-licensed day care centers C) Dance schools D) Community baseball fields E) Neighborhood playgrounds Only A is included on EPA’s list of difficult to evacuate sites. 30 30

Review Question True or False? The duration of the difficult to evacuate site requirement is the same as the buffer zone duration. False. The difficult to evacuate site restriction is in effect until 36 hours after the fumigation ends. The buffer zone is in effect until 48 hours after the fumigation ends. 31 31

Bob Spencer (208) 332-8613 bob.spencer@agri.idaho.gov Thank you Bob Spencer (208) 332-8613 bob.spencer@agri.idaho.gov