Norton, 2010 E. Randall Norton, Ph.D. The University of Arizona Safford Agricultural Center

Norton, 2010 Soil fumigant review Products available/affected Use distribution (crops by locations) Affected by new EPA rulings History of EPA Reregistration Eligibility Decisions (REDs) Timeline for implementation New risk mitigation factors

Norton, 2010 Re-licensing decisions for chemicals used as soil fumigants including: Methyl bromide Chloropicrin Metam Sodium/Potassium Dazomet First comprehensive re-evaluation since products were first registered 1,3-Dichloropropene (Telone EC, Telone II) Not included in this round of REDs

Norton, 2010 Amended REDs issued in June 2009 Include measures to mitigate risks from fumigant pesticides Measures will be implemented through product labels Revised labels with new measures will appear in the field 2010 and 2011

Norton, Public Participation process begins Draft Risk Assessments Published for Comment, Public Meeting Public Comment on Risk Assessments REDs Issued RED Amendments Issued 2010 Label Changes in Effect All Mitigation Measures on Labels Public Comment on Mitigation, Public Meetings Held

Norton, 2010 Soil Fumigant Major Pests Controlled NematodesPlant PathogensWeeds Methyl Bromide  1,3-Dichloropropene  Metam Sodium  Metam Potassium  Dazomet  Chloropicrin 

Norton, 2010

EPA proprietary data, average usage

Norton, 2010 EPA proprietary data, average usage

Norton, 2010 EPA proprietary data, average usage

Norton, 2010 EPA proprietary data, average usage

Norton, 2010 EPA proprietary data, average usage

Norton, 2010 EPA proprietary data, average usage

Norton, 2010 EPA proprietary data, average usage

Norton, 2010

AZDA 1080 Database, average usage

Norton, 2010

Will not impact large acreages Will have significant impact on some growers Not a large number of producers Our goal (UA/Industry/AZDA)… Identify this target audience Provide needed educational programming regarding changes Prepare producers to deal with new regulations

Norton, 2010

Package of measures that work together to: Reduce potential for direct exposure to toxic concentrations Reduce likelihood of accidents and errors Foster planning and compliance Assure appropriate response to exposures that occur

Norton, Implementation Good Agricultural Practices (GAPs) RUP Classification Handler respiratory protection Tarp perforation and removal restrictions Reentry restrictions Fumigant Management Plans (FMPs) Registrant-provided handler information

Norton, Implementation Buffers and buffer posting Emergency preparedness and response Restrictions near difficult to evacuate sites Registrant-provided training and community outreach programs

Norton, 2010 Good Agricultural Practices Developed by registrants – based on input from growers Reviewed by EPA Many of the GAPs are currently on label Recommendations GAPs will be mandatory Compliance will be captured on FMPs

Norton, 2010 GAPs are chemical specific Examples Wind speed restrictions Soil conditions Soil temperature Soil moisture

Norton, 2010 Ground rig with soil incorporation: “At beginning of application, maximum soil temperature at injection depth is 90 o F” Chemigation: “At beginning of application, the maximum soil temperature is 90 o F measured at 3 inches in depth”

Norton, 2010 Restricted Use Product (RUP) All products containing methyl bromide, 1,3- Dichloropropene, and chloropicrin are currently RUP Many soil fumigant products containing metam sodium/potassium and dazomet are not currently RUP EPA has determined all soil fumigants undergoing reregistration meet the criteria for restricted use

Norton, 2010 Defined: A person performing “handler activities” Anybody involved in any activity relating to the application of a restricted soil fumigant Handlers must stop work or use respirators if air concentrations exceed acceptable limits or if they experience sensory irritation Fit-tested Trained Physically fit to wear a respirator

Norton, 2010 Current labels allow reentry after 48 hours Reentry times lengthened Untarped applications 5 days Tarped applications Vary depending on tarp perforation or removal intervals

Norton, 2010 Implemented in 2010 Capture current and 1 st phase label requirements Expansion in 2011 Capture second phase requirements

Norton, 2010 Written, site-specific plan must be completed prior to fumigation Designed to… Ensure fumigators successfully plan all aspects of a safe and effective fumigation Prevent accidents, ensure label compliance, and identify appropriate procedures in case of accidents Demonstrate compliance with label requirements Tool for verifying compliance

Norton, 2010 Information required – 2010 General site and applicator information Application procedures Measurements taken to verify compliance with GAPs Handler protection information Air monitoring and hazard communication procedures Posting and record keeping procedures Emergency plans and procedures Handler training information provided Post-application summary report

Norton, 2010 Must be available… For viewing on-site by handlers To enforcement personnel upon request To emergency response personnel in case of emergency FMP for methyl bromide currently available on EPA website Others to follow soon Web-based system under development

Norton, 2010 Buffer zones Area around the application block where bystanders must be excluded during the buffer zone period (except for people in transit) Buffer zone period starts when the fumigant is first delivered and is in effect for 48 hours after the fumigant has stopped being delivered to the soil Distance is determined by: Treated block size Rate Method Outlined on label

Norton, 2010 Must be posted at usual points of entry and along likely routes of approach unless a physical barrier prevents access Roads, sidwalks, walking paths, bike trails

Norton, 2010 Must include: “Do Not Walk” symbol “Do Not Enter/No Entre” Name of fumigant, name of product Certified applicator contact information DO NOT ENTER/NO ENTRE Metam Sodium Fumigant Buffer Zone Contact: Jon Doe

Norton, 2010 Emergency Preparedness and Response If occupied structures are in close proximity to buffer zone applicator must choose: “Fumigant Site Monitoring” or “Response Information for Neighbors”

Norton, 2010 Buffer zone=125’, any occupied structures within 100’ of buffer zone Residents must be provided with emergency response information or the area between buffer zone and house must be monitored Occupied structure >100’ from buffer zone no action needed

Norton, 2010 Defined: Schools (pre-K through12) State licensed daycare Nursing homes Assisted living facilities Hospitals In-patient clinics Prisons

Norton, 2010 If buffer zone >300 feet Difficult to Evacuate Site must not be within 1/4 mile (1320 ft) of the treated area If buffer zone is <300 feet Difficult to Evacuate Site must not be within 1/8 mile (660 feet) of the treated area

Norton, 2010 UA Cooperative Extension along with industry and AZDA Conduct trainings (6) across Arizona Hands-on instruction Yuma will be first later this fall Remainder in mid-January Need to target audience – identify those needing training