1. California Department of Pesticide Regulation 1001 I Street, Sacramento CA 95814 October 2015 1 Application Phase Module 1.4: Interior Walkthrough Structural Fumigation Use Monitoring Inspection Training Module

2. Structural Fumigation: Interior Walkthrough WHO SHOULD TAKE THIS TRAINING? 2 This series of training modules is intended for County Agricultural Commissioner (CAC) staff who perform structural fumigation inspections. The procedures described in this presentation are intended solely for the guidance of employees of DPR and CACs. They do not constitute rulemaking by DPR. DPR and CACs may deviate from the procedures and guidance contained in the modules provided deviations do not conflict with law, regulation or policy. This guidance was developed in May 2015 after consultation with the Structural Pest Control Board. If you have any questions, please contact the Department of Pesticide Regulation, Enforcement Branch Liaison serving your county. The procedures described in this presentation are intended solely for the guidance of employees of DPR and CACs. They do not constitute rulemaking by DPR. DPR and CACs may deviate from the procedures and guidance contained in the modules provided deviations do not conflict with law, regulation or policy. This guidance was developed in May 2015 after consultation with the Structural Pest Control Board. If you have any questions, please contact the Department of Pesticide Regulation, Enforcement Branch Liaison serving your county.

3. Structural Fumigation: Interior Walkthrough Inspection Procedures Manual (Vol. 4 of DPR’s “PUE Program Standards Compendium”) http://www.cdpr.ca.gov/docs/enforce/compend/vol_4/inspect_procedures.ht m 3 Before starting this module, have these three manuals available to consult: Before starting this module, have these three manuals available to consult: Laws and Regulations Relating to the Practice of Structural Pest Control (including Business and Professions Code; a convenient booklet format published by Structural Pest Control Board) http://www.pestboard.ca.gov/pestlaw/act.shtml Laws and Regulations (Vol. 2 of DPR’s “PUE Program Standards Compendium”) http://www.cdpr.ca.gov/docs/enforce/compend/vol_2/lawsregs.htm GUIDANCE AND REFERNCES

4. Structural Fumigation: Interior Walkthrough 4 You will also need: Inspection form PR-ENF-107 (revised 1/2010) http://www.cdpr.ca.gov/docs/enforce/prenffrm/prenf107.pdf GUIDANCE AND REFERNCES

5. Structural Fumigation: Interior Walkthrough 5 The three phases of a structural fumigation include: PHASES OF A STRUCTURAL FUMIGATION Structural Fumigation: Observing the Application Application Phase Aeration Phase Certification Phase

6. Structural Fumigation: Interior Walkthrough 6 The five main tasks the CAC inspector has when inspecting the application phase of a structural fumigation: APPLICATION PHASE Document review Truck contents Exterior of structure walk-around Interior of structure walkthrough Observing the actual application

7. Structural Fumigation: Interior Walkthrough 7 * In total, there are 40 inspection requirements on the Structural Fumigation Use Monitoring Inspection Report form (PR-ENF-107, revised 01/2010) * In total, there are 40 inspection requirements on the Structural Fumigation Use Monitoring Inspection Report form (PR-ENF-107, revised 01/2010) This Interior Walkthrough module covers 6* inspection requirements from the application phase on the Structural Fumigation Form: INTERIOR OF STRUCTURE WALK- THROUGH #REQUIERMENT 6Labeling – Site/Rate/Concentration/Other 8Labeling – Food Bagging, Pets Removed, Etc. 15SCBA Worn / Continuous Monitoring / CAP Used 22Protection of Persons/Animals/Property 23Structure vacated / secured against reentry 24Equipment in Good Repair and Safe

8. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/Other SF labeling, particularly the associated structural fumigation manual, has many pages of detailed information covering many items. The next series of 11 slides cover some important miscellaneous compliance items for this criteria item. 8

9. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/Other What and how to inspect: Verifying sulfuryl fluoride (SF) labeling compliance for various items and equipment inside the structure. 9 For more information: FAC § 12973 Sulfuryl product labeling Inspection Procedures Manual For more information: FAC § 12973 Sulfuryl product labeling Inspection Procedures Manual

10. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/Other Electric fans are used for rapid dispersion of gas and to facilitate in the aeration process. Labeling requires a larger fan be used for the shooting fan with “pic pan” in its air stream for proper dispersal. 10 Fans used elsewhere for air circulation are not required to be any particular size. Click for more info SF labeling requirements can vary for this equipment. Fans are used in B1 structural fumigation for 1 of 4 possible purposes: 1. Dispersal of the fumigant and warning agent throughout the structure (“Shooting” fan w/hose & pic pan) 2. To ensure adequate air movement during application phase to achieve equilibrium 3. During the aeration phase to ensure efficient movement of the fumigant and warning agent throughout the structure (b & c are sometimes called “air circulation fans”) 4.Fan(s) attached to CAP aeration ducting as the actual evacuation conduit(s) that “exhaust” SF and pic outside the fumigated space. (click to close)

11. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/Other Heat Source and Electricity Concerns “Extinguish all flames, [heat sources], including pilot lights…unplug/turn off all automatic lighting and appliance controls…” “Turn off burglar alarm” -because they are triggered by air motion of fans “Turn off all central heat/air conditioning systems…” 11 Click for more info SF labeling may vary in the details for these requirements, but structural fumigation requires all pilot lights from water heaters, natural gas line, and other flame or heat sources be shut off or disconnected. The same is true for automatic lighting switches and other electrical sources (such as sound system equipment, computers, dryers, microwave oven) that could cause a spark and create a potential for fire and/or explosion. SF calculators are designed to specify the amount of fumigant to be used partly based on average temperature. Automatic heat or air conditioning modes must be turned off during the fumigation, although depending upon the type of system the fumigator will run the “fan only” mode during the fume or just prior to clearing the structure to ensure no SF or pic remains in the air ducts. See slide 39 (criteria item #23, BPC 8505.7) for more information and definitions of primary door locks versus “secondary door locks”. (click to close) Note: Primary Door Lock(s) not being locked is a label violation!

12. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/Other Use of circulation fans to establish air flow 12 Click for more info NOTE: SF Labeling requires the fumigator to establish air flow throughout the structure. There is NO requirement that each and every room, pantry, closet, etc. must have a fan inside them. “Air Circulation Fans”: photos show examples of possible areas they might be placed, depending upon the layout of the fumigated space. During application phase, circulation fans in B1 structural fumigation ensure adequate air/SF/pic movement to achieve equilibrium. During the aeration phase circulation fans ensure efficient movement of the fumigant and warning agent out of the fumigated space while assisting fresh air from outside that’s being simultaneously pulled inside. You will know it’s functioning as an air circulation fan and not a “shooting fan” or “CAP” aeration fan because there is no ducting or application hose attached, and no pic pan next to these air circulation fans. (click to close)

13. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/Other Setup & use of chloropicrin warning agent 13 Labeling requires the pic pan be positioned next to the shooting fan so that the warning agent is more quickly distributed throughout the structure along with the fumigant. Labeling may state either place in airstream of a fan only, or may state whether a pic pan must be in front of, or behind, the fan. Hose attached to fan Pic Pan in Airstream of fan of fan Click for more info RED ARROW: Open end of SF application hose must be securely attached in a manner that allows the liquid SF pushed up into the fan’s air stream as SF converts to a gaseous state. If hose is improperly placed or becomes detached, the SF liquid would potentially damage most surfaces on contact (sometimes called “etching”). If the SF labeling has a generic statement such as placing the pic pan “in the airstream of a fan” then it’s fumigator’s choice whether to place the pan behind or in front of the shooting fan. Although the best placement is behind the fan, some fumigators choose to place the pic pan in front of the fan when labeling allows that option because concentrated chloropicrin has corrosive properties and long term use might shorten the “life expectancy” of a fan. (click to close)

14. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/Other Cabinets, Drawers, & Appliance Doors Opened 14 To ensure adequate circulation of SF and warning agent, all operable drawers, cabinet doors, and appliance doors other than refrigerators and freezers must remain open. Click for more info *Exception to appliance doors propped open: Refrigerators & freezers- Leaving refrigerators/freezers open for several days would at the minimum would spoil the food and there is the risk of the motor overheating causing a fire. So DPR allows fumigators to briefly open the fridge/freezer doors during the certification process to expedite aeration/dissipation any remaining SF & Pic.( see Branch 1 certification phase submodule 3) When larger cabinets have a single “open space” inside, the fumigator needs only to open one of the doors. Drawers must be at least partially open for adequate air flow, but do NOT have to be fully opened. (click to close)

15. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/Other Operable Internal Doors Opened 15 To ensure adequate circulation of SF and warning agent, all operable internal doors must also remain open. B1 use various methods to keep them open Click for more info Ensuring adequate air flow throughout the entire fumigated space is important for the adequate distribution of the warning agent and reaching equilibrium for maximum efficacy of the SF fumigant. This INCLUDES attics and basements with operable doors/access. During the aeration period the adequate air flow means more efficient movement of SF/pic OUT of the fumigated space to be replaced by incoming fresh air. Fumigator’s choice on how to ensure internal doors stay open. You may see chains, bricks, rope, tape, carpet clips, small items, or property owner’s own “door stops” utilized to keep the internal doors open. Ensuring internal doors are propped or kept open some other way is necessary because when CAP is initiated the first few minutes of the aeration causes a huge amount of air pressure. The initial air pressure force has been known to push internal doors shut, if they were not somehow propped/secured open before the fumigation began. (click to close)

16. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/ Other 16 No for left photo. Yes for right photo. Follow-up with your supervisor: What additional action (if any) should you take in response to this violation? Follow-up with your supervisor: What additional action (if any) should you take in response to this violation? Are these in compliance (yes or no) ? Click for more info Left photo is NO for 12973 because all appliances other than refrigerator/freezers must have operable doors left open. Appliance doors are closed. Right photo is YES for 12973 because cabinet doors are open. (click to close)

17. Structural Fumigation: Interior Walkthrough For security reasons, B1 will utilize existing window locking devices to ensure windows can’t fully open. If none present or they are broken, B1 may install a temporary window lock or barricading device. Requirement #6: Labeling – Site/Rate/Other Operable windows opened (at least 3 inches) 17 Click for more info Exterior walls with operable windows; at least 1 window per room must be opened at least 3 inches. But if windows nailed/painted shut or no access because of storage etc. they are not required to be opened. SF labels refer to opening “operable” internal doors and windows because U.S.EPA and California DPR recognize that there are structures with so much storage “load” that all doors and windows cannot reasonably be accessed or opened by the fumigator, or structures may have all windows deliberately nailed or painted shut. Some government buildings are constructed so that no windows can be opened. Multi-story structures: Upper floor windows may be opened wider than 3 inches. Fumigator has the option to leave ground floor level windows closed for security reasons IF air flow can be established between floors. This is normally accomplished by extra strategically positioned “air circulation fans” on stair landing and/or at the base of stairs, in hallways or corridors, etc. Fumigators are allowed the multi-story window option because they have to comply with regulations, but also want to reduce the risk of break-ins. Since chloropicrin and SF fumigant are normally applied inside structures with walls, the partly open windows help the pic and fumigant to circulate more efficiently to all areas under the tarp. (click to close)

18. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/ Other 18 Answer: Yes for both. Room with multiple windows, but only 1 is open because the others are painted shut. Room windows closed; inside there are boxes stacked in front of windows up to the ceiling. Are these in compliance (yes or no) ? Click for more info Left photo is YES, because labeling only specifies operable windows and internal doors to be opened. If fumigation company cannot access or open windows and/or internal doors because they are blocked, such as from stacked boxes, tall heavy furniture, excess storage “load” (can’t get into the room to access windows); or windows painted, nailed shut, and can’t be opened without damaging them, the fumigator must use fan placement to create air flow but is NOT required to move furniture, heavy boxes, or “force” the windows or doors open. Right photo is YES for 12973 because there’s only 1 operable window, and it is open at least 3 inches. (click to close)

19. Structural Fumigation: Interior Walkthrough Requirement #6: Labeling – Site/Rate/ Other 19 Answer: Yes for both. Inside the sliding door track, This lock is what you see. Sliding door open 3 inches; inside there Is a temporary lock inside the door track. Are these in compliance (yes or no) ? Click for more info Answer is YES,because SF labeling and BPC 8505.7 (secondary lock) allow fumigators choices such as temporary lock, dowel, rod, or other type of barricade to use with sliding doors as long as the door cannot be opened far enough for a child or other person to enter during the fumigation. The temporary lock in the right photo is engaged in the “locked” position, and you can see the upper edge is in contact with the slider. (click to close)

20. Structural Fumigation: Interior Walkthrough Requirement #8: Labeling - Bagging, Pets Removed, etc. SF labeling, particularly the associated structural fumigation manual, has many pages of detailed information covering many items. The next series of 10 slides cover some important miscellaneous compliance items for this criteria item. 20

21. Structural Fumigation: Interior Walkthrough Requirement #8: Labeling - Bagging, Pets Removed, etc. What and how to inspect: Verifying compliance with labeling for which items have to be bagged or removed, and that domestic/non-target animals and desirable plants are removed. 21 For more information: FAC § 12973 Sulfuryl product labeling Inspection Procedures Manual For more information: FAC § 12973 Sulfuryl product labeling Inspection Procedures Manual Click for more info SF registrants have an informational brochure available online describing what and how to bag items. It may be helpful to have a copy of the most recent version with you during training and reviewing the specific page(s) in their SF labeling. Some fumigation companies have a “homeowner preparation checklist.”, however the homeowner checklist and registrant bagging instructions (when they are in a separate brochure, etc.) are not part of the registered labeling. (click to close)

22. Structural Fumigation: Interior Walkthrough 22 SF labeling from registrant may vary in whether certain food, beverage, and/or medicinal items must be bagged or removed. Certain food and medicinal items are NOT required to be bagged or removed. Examples listed in SF labeling include: Food, feed, drugs, tobacco product, and medicinals (including those in refrigerators and freezers) can remain unbagged in the structure, if they are in unopened plastic, glass or metal bottles, cans or jars with the original manufacturer’s air-tight seal intact. Requirement #8: Labeling - Bagging, Pets Removed, etc. Bag or Remove Designated Food & Medicine Items Click for more info If the labeling does NOT specifically exempt ice, bottled water, dental products, or other ingested items, DPR has determined that non-exempted items ingested or used inside the mouth/body must be bagged or removed prior to the fumigation. (click to close) NOTE:. Cosmetic or topical lotions and others that are not “ingested” are exempt from the bag or remove requirement. NOTE:. Cosmetic or topical lotions and others that are not “ingested” are exempt from the bag or remove requirement.

23. Structural Fumigation: Interior Walkthrough 23 Requirement #8: Labeling - Bagging, Pets Removed, etc. Bag or Remove Designated Food & Medicine Items Click for more info Food/medicine bagging, is one of the most common violations in branch 1 application and certification phase inspections. Often items required to be bagged are either missed when preparing for the fumigation or are improperly bagged. Human food, medicinals, and pet food can be found in ANY area of a structure. Look UP at shelves, on top of fridge, etc. and look DOWN/under shelves, closet floors, children’s beds, etc. Bedside drawers may contain candy, snacks, and medicines. Food items can be stored in the living space or garage. Pet food in bowls may be inside, on the back porch/patio, in bathrooms, or near the table where the occupants eat. If they have big dogs or multiple pets, food may be stored in bulk packages or lidded containers. (click to close)

24. Structural Fumigation: Interior Walkthrough Requirement #8: Labeling - Bagging, Pets Removed, etc Bag or Remove Designated Food & Medicine Items 24 For all items that must be bagged, check labeling to verify which brand of bag(s) can be used with that SF product: Nylofume (Vikane), Fumiguard (Zythor), and/or Master Fume bags. Some SF labels also allow other registrant brand bags to be used. Photo on the right depicts properly double bagged sealed food items. Photo below is a close-up of the Nylofume brand bag, which can be used by all 3 SF products per their registered labeling. Click for more info Although each registrant has their own brand of bags, U.S.EPA requires they meet the same standards as the original data from tested Vikane Nylofume brand bags. The other registrants added “Nylofume” type bags into their labeling along with their own brand of bag allowing fumigators to chose which brand of U.S.EPA approved SF registrant bags to use without being in violation of labeling. Sometimes occupants who do their own bagging will run out of proper fumigation bags and “substitute” other types of bags. Check bagged items from various places (countertops, fridge/freezer, garage etc.) to be sure the occupants didn’t use the wrong type of bags. In addition to not being stamped with a registrant brand name, non-approved bags have distinctly different thickness/texture compared to U.S.EPA/registrant’s approved bags. (click to close)

25. Structural Fumigation: Interior Walkthrough Requirement #8: Labeling - Bagging, Pets Removed, etc. Bag or Remove Designated Food & Medicine Items 25 Click for more info Registrants require double bagging items and sealing each bag. The procedure was originally demonstrated by research from the first SF registrant, DOW (Vikane) to U.S.EPA. U.S.EPA allowed subsequent registrants’ products to use the same bagging procedure. DOW did test the manufacturer’s “air-tight seal” standard against metal cans, glass jars, etc. but did not test every type of packaging. All other packaging such as blister packs, cardboard, miscellaneous plastic bags, bottles, foil wrap, clamshells, and liners (such as used for cereal, produce etc.) were either not tested by the registrant or did not meet the “air-tight” standard, so EPA has required registrants to state that all such “miscellaneous” food and medicinal items must be bagged or removed. (click to close)

26. Structural Fumigation: Interior Walkthrough Requirement #8: Labeling - Bagging, Pets Removed, etc. Bag or Remove Designated Food & Medicine Items 26 Answer: No for both. Follow-up with your supervisor: What additional action (if any) should you take in response to this violation? Follow-up with your supervisor: What additional action (if any) should you take in response to this violation? Left photo: Cat food dish found in bathroom. Right photo: Dog biscuit box that’s been opened on pantry shelf next to canned pet food. Are these in compliance (yes or no) ? Click for more info No for both: Left photo (dish with dry cat food): cat food is domestic animal feed and B1 SF labeling does not allow it to be exposed to fumigant. Right photo (box of dog biscuits, unopened can of pet food): The unopened canned food is ok because the manufacturer’s seal is intact. This one is a violation because of the dog biscuits. The cardboard box would need to be bagged or removed per SF labeling whether it was open or not, because it is not considered by U.S.EPA to be “airtight”. (click to close)

27. Structural Fumigation: Interior Walkthrough Requirement #8: Labeling - Bagging, Pets Removed, etc. Removing Pets 27 SF labeling may vary in how they describe requirements or options for large fish tanks. Otherwise all people and non-target/domestic animals must be removed. Click for more info Usually the Branch 3 primary contractor (industry term is the “prime”) works with the occupants to make arrangements for pets on their property and to do their due diligence (prior to fume day) to notify neighbors to keep their own neighborhood pets indoors while the fume crew is preparing the structure for fumigation. But the Branch1 licensee is still responsible for a final walk-through to inspect all reasonable access areas for hiding domestic animals (particularly cats). (click to close)

28. Structural Fumigation: Interior Walkthrough 28 SF labeling states fish should be removed, or in some cases where large tanks with “sensitive” fish the label may allow providing outside fresh air line into the tank and “seal” off the tank from the rest of the fumigated space. Requirement #8: Labeling - Bagging, Pets Removed, etc. Removing Fish Click for more info Check SF labeling since they may differ in language regarding “options” for large aquariums or fish tanks because some species of pet fish may die from stress if they are removed from their tanks. (click to close)

29. Structural Fumigation: Interior Walkthrough 29 When you are doing the walk-through, prior to licensee introducing the chloropicrin warning agent and the fumigant, look around every room to see that no small potted plants were left inside…unless of course they are plastic (“fake”) plants! Requirement #8: Labeling - Bagging, Pets Removed, etc. Remove plants Click for more info If occupants do not remove potted indoor plants the fumigator will often move them to the yard away from the tarped area. NOTE: Fumigators are NOT required by labeling or code to water or otherwise maintain the “health” of potted plants removed from the structure. B1 is only required to make sure desirable plants are located somewhere outside the tarps prior to introduction of the fumigant. (click to close)

30. Structural Fumigation: Interior Walkthrough Requirement #8: Labeling - Bagging, Pets Removed, etc. 30 Answer: No for both. Follow-up with your supervisor: What additional action (if any) should you take in response to this violation? Follow-up with your supervisor: What additional action (if any) should you take in response to this violation? Are these in compliance (yes or no) ? Click for more info Answer is NO to both photos because: it’s a single bag and neither is properly double bagged and “sealed” per SF labeling. Right side photo - it also does not appear to be in a label-approved bag. Sometimes occupants who do their own bagging run out of proper fumigation bags and “substitute” other types of bags. Check bagged items in various places (countertops, fridge/freezer, garage etc.) to be sure the occupants didn’t use the wrong bags. In addition to not being stamped with a registrant brand name, non- approved bags have a distinctly different thickness/texture compared to USEPA/registrant’s approved bags. (click to close)

31. Structural Fumigation: Interior Walkthrough Requirement #15: CAP Equipment / Placement* What and how to inspect: Verifying compliance for California Aeration Plan (CAP) equipment located inside the tarps. SCBA worn/continuous monitoring are normally N/A for application phase inspections; see speaker notes for additional scenario examples. 31 For more information: California Aeration Plan (CAP) & 3CCR § 6780(c) Inspection Procedures Manual For more information: California Aeration Plan (CAP) & 3CCR § 6780(c) Inspection Procedures Manual Click for more info SCBA Worn/Continuous Monitoring: If a licensee or other employee is applying the warning agent to more than 2 pic pan sites per structure, they are required to do so wearing SCBA. Labeling does not allow “substituting” continuous monitoring for this activity. The only other occasional reason for entry to structure once the fumigant introduction has commenced is when the shooting hose detaches from the fan causing a distinctive “whipping” sound as the liquid SF is sprayed into the airspace. Licensee must close the SF cylinder valve, don SCBA, and enter to fix the problem before continuing to apply the SF into the structure. 3CCR 6780 discusses when employers need to either provide appropriate respiratory protection or provide continuous monitoring when employees may be exposed above the PEL = permissible exposure limit (labeling and/or regulatory) to fumigants. This 6780 requirement supplements fumigant labeling instructions regarding worker exposure. If exposure level is unknown or determined to be above the PEL, the employer must provide, and employees must use, air-supplied respiratory protection. Subsection 6780(c) allows industry developed and DPR approved alternatives to these employer options. CAP is an alternative method that is approved under 6780(c) for Branch 1 fumigation in California only. (click to close)

32. Structural Fumigation: Interior Walkthrough 32 Most of the CAP equipment inspection compliance is determined from the outside of the structure. During an application phase inspection it is still important to see how the Ducted Aeration Fan is placed inside. Verify ducting is securely attached to fan and it is clipped into and threaded through the tarp so there is no bunching or blockage on the inside that would inhibit Aeration phase use of this equipment to exhaust the fumigant and warning agent Requirement #15: CAP Equipment / Placement* Interior view of CAP ducted Aeration Fan Click for more info This Ducted Aeration Fan (DAF) is placed at the top of stairs just outside the back door of this apartment unit. There is a sand snake at the base to ensure when the fan is activated, the vibration will not cause the fan to move and detach from the ducting or fall down the stairs. (click to close)

33. Structural Fumigation: Interior Walkthrough CAP ducting needs to be attached (securely) to the fan, as well as fitting snugly to function properly, or else the initial force of fan activation could cause ducting to partially or completely detach from the fan. 33 Answer: Yes. Is this in compliance (yes or no) ? Requirement #15: CAP Equipment / Placement Interior view of CAP ducted Aeration Fan Click for more info Fumigator’s choice whether to clip/tie etc. Photo Details: Ducting is not only pulled tightly around the aeration fan, you can see the white cord is also tied to the fan itself. This fan is positioned on the flat patio surface inside the tarps, so the fumigator determined no anchoring of the fan’s base was necessary. (Upper end of ducting was inserted higher up into the tarp.) (click to close)

34. Structural Fumigation: Interior Walkthrough Requirement #22: Protection of Persons/Animals/Property What and how to inspect: Verifying compliance for miscellaneous items that ensure people, non-target animals, and the property under fumigation are protected from damage or other harm related to exposure. This requires your judgment - not limited only to the exact wording of labeling or CAP 34 For more information: FAC § 12973, and sulfuryl product labeling 3CCR § 6614 Inspection Procedures Manual For more information: FAC § 12973, and sulfuryl product labeling 3CCR § 6614 Inspection Procedures Manual Click for more info For the interior walk-through part of your inspection, compliance with labeling usually ensures no violation of section 6614 as well. Check with your supervisor when you find label or other violations that may appear to also indicate a violation of 6614. See “application” submodule 1.5 for other compliance items which impact compliance with 3CCR 6614. (click to close)

35. Structural Fumigation: Interior Walkthrough Requirement #22: Protection of Persons/Animals/Property 35 Answer: No. Follow-up with your supervisor: What additional action (if any) should you take in response to this violation? Follow-up with your supervisor: What additional action (if any) should you take in response to this violation? Is this in compliance (yes or no) ? Click for more info “Pet Doors” do not require “secondary locks.” Because they are large enough for a dog or cat to climb through they should be latched or barricaded. Larger “doggie doors” can be big enough for a child to crawl through, even though they are not considered by USEPA as a human “entrance”. Fumigator can push a box or place other item against it from the inside, if the pet door doesn’t have its own internal latch or another way to secure it closed. Check with your supervisor to see whether a particular situation like the photo above would be in compliance or in violation of 6614 and/or 3CCR 6600, general standards of care. (click to close)

36. Structural Fumigation: Interior Walkthrough Requirement #23: Structure Vacated/Secured Against Re-entry SF labeling, particularly the associated structural fumigation manual, has many pages of detailed information covering many items. The next series of 6 slides cover some important compliance items for this requirement item. 36

37. Structural Fumigation: Interior Walkthrough Requirement #23: Structure Vacated/Secured Against Re-entry What and how to inspect: Verifying compliance for occupants all having vacated the structure and that primary and “secondary” locks/barricades (when required) are in place for entrances until fumigation is completed and the structure is certified safe for occupants to re-enter. 37 For more information: FAC § 12973, and sulfuryl product labeling Inspection Procedures Manual BPC § 8505.7 & 16CCR § 1970.3 For more information: FAC § 12973, and sulfuryl product labeling Inspection Procedures Manual BPC § 8505.7 & 16CCR § 1970.3 Click for more info SF labeling requires entrances to have secondary locks or barricades under certain circumstances. Example from the Vikane 2013 labeling: “Existing locking devices, such as pins or bars for sliding glass doors, or interior bolts, can be used to secure entrances without the use of secondary locking devices if the devices cannot be opened or removed from the exterior of the structure.” BPC section 8505.7 states in part “locked, barricaded, or otherwise secured…” 16 CCR section 1970.3 defines this phrase and gives various examples of what doorways/entrances must be barricaded and what type of secondary locks or barricades are acceptable. (click to close)

38. Structural Fumigation: Interior Walkthrough Requirement #23: Structure Vacated/Secured Against Re-entry Primary Door Locks 38 Not engaging the primary lock on a door is a label (FAC 12973) violation, NOT a BPC 8505.7 “Secondary Lock” violation. Click for more info BPC 8505.7 refers to either barricades or “Secondary locks” that are part of the fumigator’s equipment. (Windows are NOT considered “entrances” by U.S.EPA, so they are not required to have secondary locks.) Whereas primary locks (primary door locks) are those that are part of the original construction or condition of the doorway such as deadbolt locks, keyways, sliding door latches, etc. Primary locks are those the occupants could potentially open if they got under the tarps during a fumigation if there were no other fumigator locks or barricading. There have been a few episodes where a resident or someone else got into fumigated structures and either accidentally or intentionally died because a primary lock was not engaged and/or there was no secondary lock or barricade. (click to close)

39. Structural Fumigation: Interior Walkthrough Requirement #23: Structure Vacated/Secured Against Re-entry Secondary Locks 39 J Lock Clamshell Lock Keyway Lock, ½ key inserted Click for more info A keyway secondary lock in place. This half key alone cannot open the door in order to be in compliance as a secondary lock. (click to close) Click for more info J locks are often used for hotels and other commercial buildings that have doors with magnetic “swipe key” entry. (click to close) Click for more info Same site as center photo but fumigator has the other half of the keyway secondary lock in his hand; door lock cannot be turned or opened without both halves of the fumigator’s key inserted and turned simultaneously. (click to close) Some fumigators have this additional half key’s ring mini- sign on their keyway locks. (click to close) “clamshell” secondary lock, used to cover door knobs so they can’t unlock/turn and open the door. (click to close)

40. Structural Fumigation: Interior Walkthrough Requirement #23: Structure Vacated/Secured Against Re-entry Secondary Locks 40 Secondary Lock display provided by Mike Watkins of Cardinal Professional Products Clamshell lock interior & side views Padlock with chain Click for more info A demo station display of how different types of secondary locks can be used. Left to right examples include: Clamshells, ½ keyway, and J locks (click to close) Click for more info 2 views of the “clamshell” secondary lock, one of the most commonly used to cover door knobs or handles so they can’t turn and open the door. Padlock and chain type of secondary lock can be used on certain types of doors not suitable for clamshell or keyway (click to close)

41. Structural Fumigation: Interior Walkthrough Criterion #23: Structure Vacated/Secured Against Re-entry More Scenario Examples 41 Licensee is disconnecting the electrical power cord to disable the automatic garage door opener. Click for more info If there is no way to open this type of door from the outside and the electronic opener is disengaged in this manner prior to beginning the fumigation, then labeling may indicate no secondary barricade or lock is required (click to close) Click for more info For sliding doors, if there is an exterior lock/keyway (top left photo) then the fumigator is required to provide a secondary lock or barricade. For those sliders with no way to open from the outside when the interior primary lock is engaged, a secondary lock is not required. Fumigator may choose to put in either a track lock or dowel type barricade for additional security purposes, even if it’s not required by SF labeling. If there is no primary lock or it is NOT functioning properly (sliding glass, garage doors, detached sheds, etc.) then there must be a secondary barricade or lock to be in compliance with 8505.7. (click to close)

42. Structural Fumigation: Interior Walkthrough Criterion #23: Structure Vacated/Secured Against Re-entry 42 Answer: No. Follow-up with your supervisor: What additional action (if any) should you take in response to this violation? Follow-up with your supervisor: What additional action (if any) should you take in response to this violation? PIN Is this in compliance (yes or no) ? Click for more info 16CCR 1970.3 states staples cannot be used as a secondary lock. If “pin” type used is not thick or sturdy enough, or not properly inserted, the pin is not be in compliance. SF labeling and/or regulations may include additional statements about what the registrant considers “inadequate secondary lock devices”. Photo shows an actual site where the property was under SF label aeration method (no crew on site). The county inspector pulled back the tape covering the key hole and this “secondary lock device” fell out. Inspector took several photos including a close-up of the pin lying on the ground where it fell, then picked it up and put it on the tape, to show how small and inadequate it was as a secondary lock device. (click to close)

43. Structural Fumigation: Interior Walkthrough Requirement #24: Equipment in Good Repair/Safe What and how to inspect: Verifying compliance for equipment functioning while applying the fumigant. (Most of this is done while outside the tarps.) 43 For more information: FAC § 12973, 3CCR 6742, and sulfuryl product labeling Inspection Procedures Manual entry for this requirement For more information: FAC § 12973, 3CCR 6742, and sulfuryl product labeling Inspection Procedures Manual entry for this requirement Click for more info When there is a violation of 6742 it is normally found during the application and outside the tarps (see submodule 1.5). Either the SF cylinder valve malfunctions, the SF tube pops off the valve stem, or somewhere in the SF application line there is a pinhole or crack which may be too tiny to see. BUT as soon as the SF is released, a small white cloud could be visible and the sound the hissing of escaping gas could be heard from a pinhole spot. Another interior event is very rare, but happens when the SF application hose disconnects from the shooting fan. Instead of the characteristic slow steady “hissing” SF sound inside, you may hear the “whipping” sound of the open end of tube moving through the air as the liquid SF comes out of it. Licensee must immediately close the cylinder valve, don his SCBA, and enter the structure to reconnect the hose properly before resuming the application. Check with your supervisor if this happens, particularly if you were not on site early enough to be able to walk through and see how the shooting hose(s) were connected to the fan(s). (click to close)

44. Structural Fumigation: Interior Walkthrough Criterion #24: Equipment in Good Repair/Safe 44 Answer: YES. Is this in compliance (yes or no) ? Click for more info YES in real life situations the fan should be running during the setup process, so you could verify it was functioning properly. Pic pan close to fan, shooting hose securely clipped close to the fan’s air flow up and outward, and hose doesn’t appear to have holes etc. Fumigator has also put something under this equipment to protect the carpet. NOTE: Check the labeling to see what types of pic pan containers are allowed. The discoloration of the pad in the pic pan is NOT a violation and does NOT indicate a problem. Fumigators are not required by labeling or regulation to use a brand new pad for each fumigation. The discoloration is a normal result of repeated use. (click to close)

45. Structural Fumigation: Interior Walkthrough You have completed the Interior Walk-Through module, which included six* requirements from the Structural Fumigation Use Monitoring Inspection form: 45 CONGRATULATIONS! * In total, there are 40 requirements on the Structural Fumigation Use Monitoring Inspection Report form (PR-ENF-107, revised 01/2010) * In total, there are 40 requirements on the Structural Fumigation Use Monitoring Inspection Report form (PR-ENF-107, revised 01/2010) #REQUIERMENT 6Labeling – Site/Rate/Concentration/Other 8Labeling – Food Bagging, Pets Removed, Etc. 15SCBA Worn / Continuous Monitoring / CAP Used 22Protection of Persons/Animals/Property 23Structure vacated / secured against reentry 24Equipment in Good Repair and Safe

46. Structural Fumigation: Interior Walkthrough Please complete the remaining modules before conducting an actual inspection of the application phase of a structural fumigation: Document review Truck contents Exterior of structure walk-around Interior of structure walk-through Observing the actual application 46

47. California Department of Pesticide Regulation 1001 I Street, Sacramento CA 95814 October 2015 FOR MORE INFORMATION, CONTACT: 47