1. California Department of Pesticide Regulation 1001 I Street, Sacramento CA 95814 October 2015 1 Aeration Phase Module 2.2: Sulfuryl Fluoride Labeling Structural Fumigation Use Monitoring Inspection Training Module

2. WHO SHOULD TAKE THIS TRAINING? 2 This series of training modules is intended for County Agricultural Commissioner (CAC) staff who perform structural fumigation inspections. Note: 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. Note: 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. Structural Fumigation: Aeration via sulfuryl fluoride labeling

3. 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 Structural Fumigation: Aeration via sulfuryl fluoride labeling

4. 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 Structural Fumigation: Aeration via sulfuryl fluoride labeling

5. 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. 6 Aeration via CAP SCBA not required (unless structure is entered before CAP aeration period ends, such as for emergencies) Structural Fumigation: Aeration Phase The Aeration Phase has two modules: Aeration via sulfuryl fluoride Product labeling procedures SCBA is required for entry Structural Fumigation: Aeration via sulfuryl fluoride labeling

7. Non-CAP aeration Tape & Seal Preparing for “Active” Aeration Aeration Timeline SF Labeling: “Aeration Procedure 1” 7 Structural Fumigation: Aeration via sulfuryl fluoride labeling

8. Atypical structural fumes: non-CAP aeration 8 Tape & Seal Food Trucks Structural Fumigation: Aeration via sulfuryl fluoride labeling Click for more info Tape & Seal – Review SF Label & Applicator’s Manual Food Trucks - less common sight than residential structures Some types of construction, such as stucco, brick, masonry block, concrete, and metal, may be adequately sealed by using sealing materials, such as polyethylene sheeting, laminated paper, nonporous panels, fumigation tape, spray adhesives, foams and insulation materials. These materials are used to seal gaps in doors, windows, roof eaves, loading docks, pipes, vents, and other openings. When properly used, these materials can adequately confine the fumigant within the structure. (click to close)

9. “Preparing for Active Aeration” 9 FAN DIRECTED INTO ATTIC OPERABLE WINDOW OPENED CENTRAL AIR ACTIVATED Structural Fumigation: Aeration via sulfuryl fluoride labeling Click for more info Breaking of seal, removal of clips/snakes, and removal of tarps are not referenced under “Aeration & Reentry” in any SF labeling, but have to occur before entry into structure. On SF labels, the paragraph under Aeration & Reentry addresses directing fan into attic, and activating fan of central air handling system or placing fan in front of furnace inlet All SF labeling has in bold- “During the initial one hour aeration procedure, approved respiratory protection must be worn until the concentration of {product name} is confirmed not to exceed 1 ppm with an approved detection device” Aeration Procedure 1 / Step 1: Addresses fan capacity, opening of operable windows and doors, and minimum 1 hr. active aeration (click to close)

10. SF Labeling Aeration Time: 10 COMMENCEMENT OF AERATION Breaking the Seal Removing of snakes, clips, & some tarps Opening of operable windows & external doors (SCBA WORN) Enough tarps have been removed to facilitate active aeration Removal of all tarps from structure Fume crew finishes 1 hour aeration Secures structure PASSIVE AERATION COMMENCEMENT OF AERATION Begins Aeration Procedure 1 COMMENCEMENT OF AERATION Ends Structure can be cleared by a licensee Total aeration time Begins ~15 minutes ~10 minutes~20 minutes6 hours up BEGIN: 1 HOUR ACTIVE AERATION END: 1 HOUR ACTIVE AERATION END: 6 HOUR AERATION Time: 12:00 pm12:15 pm12:35 pm12:50 pm1:35 pm6:00 pm Licensee must be present on-site Licensee does not have to be on-site For more information: 16CCR 1970.5 SF Labeling For more information: 16CCR 1970.5 SF Labeling Structural Fumigation: Aeration via sulfuryl fluoride labeling Click for more info THE TIME NOTED ABOVE “BEGIN OF ACTIVE AERATION” TO THE TIME ABOVE “END OF ACTIVE AERATION” – DOES NOT = 60 MINS! (not meant to) Times of 15, 20 mins, etc. reflect typical time fume crews spend doing various activities on a single family residence. 16 CCR§1970.5. Commencing Aeration. “The time ventilation is commenced” as used in section 8505.3 of the Code means the period of time beginning when the seal is broken and ending when all seals/tarps are removed. A licensed Branch 1 operator or field representative is required to be present during this entire period of time.” (click to close)

11. SF Labeling: Aeration Procedure 1 11 “Breathing Zone” – areas within the structure where individuals typically stand, sit, or lie down Structural Fumigation: Aeration via sulfuryl fluoride labeling

12. 12 Aeration via SF Labeling #REQUIERMENT# 1Registered in county19Proper management of treated area 2County notified 24 hours prior20Connecting structures 7Labeling – aeration/ certification23Structure vacated/ secured against re-entry 12Handler(s) trained252 SCBA/ CPR chart/ mfg. instructions 13Emergency medical care, posting28Direct supervision 15SCBA worn/ cont. monitoring / CAP29Warning signs on all sides of structure 172 trained employees30Required information on warning signs 18Fume of enclosed spaces /proper entry * In total, there are 40 inspection requirements on the Structural Fumigation Use Monitoring Inspection Report form (PR-ENF-107, revised 01/2010) Structural Fumigation: Aeration via sulfuryl fluoride labeling This Aeration via sulfuryl fluoride labeling training module covers 15* requirements on the Structural Fumigation Inspection Form:

13. Criterion #1: Registered in county 13 For more information: FAC § 15204.5 Enforcement letter ENF 07-31 & Addendum For more information: FAC § 15204.5 Enforcement letter ENF 07-31 & Addendum What and how to inspect: Check SPCB website; Review files at CAC office Has SPCB issued a company registration? Was structural pest control company registered with CAC prior to performing structural pest control for hire within the county? Are Field Reps, & Operators licensed by SPCB? Were licensees registered with CAC prior to working? Structural Fumigation: Aeration via sulfuryl fluoride labeling Click for more info FAC 15204.5 (a) lists structural pest control applicators as having to register under Branch 1 requirements. BPC 8505.2 only allows structural pest control operators and field representatives to perform structural fumigations. BPC 8507.1(a) defines the scope of a structural pest control applicator license FAC 15204.5 (c ) requires “in person” registration. ENF 07-31 (pg. 3), and ENF 07-31 Addendum address “in person” registration (click to close)

14. Kilzall Brothers Pest Control SPCB Reg # PR-7777 879 Bug St., Ento City, CA 92234 (999) 222-0000 Qualifying Manager: Joe Kilzall, Address above SPCB License # OPR-9999 Issued: 7/1/2012 Requirement #1: Registered in county CAC Registration: Company CAC Registration: Licensees Jim Kilzall OPR-9998 Jerry Kilzall FR-2345 Jonnie Kilzall FR-1357 Kilzall Brothers Pest Control 879 Bug St., Ento City, CA 92234 (999) 222-0000 Answer: Yes, this registration is in compliance For required info on registration form – FAC §15204.5(b) Is this registration in compliance (yes or no) ? 14 Structural Fumigation: Aeration via sulfuryl fluoride labeling

15. What and how to inspect: Review Notices of Intent (NOIs) at CAC office. Did the structural pest control company submit its NOI at least 24 hours prior to commencing fumigation? 15 Requirement #2: County notified 24 hours prior For more information: FAC § 15204.5(d) Check with your supervisor - - your CAC might have chosen to waive this requirement (“or as approved on a case-by-case basis by the commissioner”) For more information: FAC § 15204.5(d) Check with your supervisor - - your CAC might have chosen to waive this requirement (“or as approved on a case-by-case basis by the commissioner”) Structural Fumigation: Aeration via sulfuryl fluoride labeling

16. NOI faxed to CAC: Date: June13,13 Time: 4:30 pm Answer: No This NOI is missing the address of the structural pest control operator or company. The address is required by FAC §15204.5(d) Follow up with your supervisor: Based on the criteria in 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) what action (if any) should you take in response to this violation? Follow up with your supervisor: Based on the criteria in 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) what action (if any) should you take in response to this violation? Notice of Structural Fumigation To: Bestest County Ag. From: Kilzall Brothers P.C. Phone: 999-222-0000 Date: June 13, 2013 Fumigant: Vikane Site: 847 Pope St., Bestest City Fume date: June 15, 2013 Requirement #2: County notified 24 hours prior Is this in compliance (yes or no) ? 16 Structural Fumigation: Aeration via sulfuryl fluoride labeling Click for more info Only a single NOI is required, 24 hours prior to the start of operations. There is no requirement for additional NOIs for aeration or clearance phases. (click to close)

17. What and how to inspect: Check SF Labeling under Aeration and Reentry Amount of SF shot (oz./MCF)? Number of fans? Displace total of 5,000cfm? Licensee present? Time of first opening of seal? SCBA worn during initial 1 hour aeration? Minimum required aeration time? Actual time? SF continuous monitoring device used? Reading? 17 Requirement #7: Labeling - Aeration For more information: Check Inspection Procedures Manual For more information: Check Inspection Procedures Manual Structural Fumigation: Aeration via sulfuryl fluoride labeling

18. 18 Requirement #7: Labeling - Aeration Answer: Maybe, for both, based on stage in aeration process Aeration has commenced For more information: Check Inspection Procedures Manual For more information: Check Inspection Procedures Manual Structural Fumigation: Aeration via sulfuryl fluoride labeling Are these licensees in compliance (yes or no) ? Click for more info These pictures portray stage 2 of the Aeration Process Timeline. Clips and snakes have been removed, some tarps have been removed in preparation for 1 hour active aeration. Aeration has commenced (see Aeration Timeline), licensee in opened garage is wearing an SCBA as this is the initiation of aeration in preparation of the 1 hour active aeration. SCBA complies with 6780. Fan in foreground to be placed in garage and turned on. Unknown if operable windows are open. Licensee on roof is wearing SCBA as required by label during initiation of aeration in preparation for the 1 hour active aeration procedure. Wearing of SCBA complies with 6780 What does the Inspection Procedures Manual for criterion 7 say about licensee on roof while wearing SCBA? Issue of no warning signs on either side of garage –relevant for a different criterion (click to close)

19. Requirement #12: Handler(s) Trained What and how to inspect: Ask each handler to see their license. A person holding a pest control operator or field representative license are certified commercial applicators. Certified applicators are considered trained. Ask questions and observe work practiced to determine if handlers have been trained 19 For more information: 3 CCR § 6724(d) 3 CCR § 6000, definitions of “certified commercial applicator” and “handle” For more information: 3 CCR § 6724(d) 3 CCR § 6000, definitions of “certified commercial applicator” and “handle” Structural Fumigation: Aeration via sulfuryl fluoride labeling

20. Two employees of Kilzall Brothers Pest Control are working as handlers during the aeration: Jim Kilzall, SPCB license: OPR-9998 Jerry Kilzall, SPCB license: FR-2345 20 Requirement #12: Handler(s) Trained Answer: Yes Jim and Jerry Kilzall both meet the definition of “certified commercial applicator” and therefore are considered trained Are handlers in compliance (yes or no) ? Structural Fumigation: Aeration via sulfuryl fluoride labeling

21. Requirement #13: Emergency Medical Care What and how to inspect: Is information about emergency medical facility posted in a prominent place (work site / truck)? 21 For more information: 3CCR § 6726 – particularly re: working in multi-city, or multi-county areas Check Inspection Procedures Manual For more information: 3CCR § 6726 – particularly re: working in multi-city, or multi-county areas Check Inspection Procedures Manual Must include name, address, and phone number “Call 911” or wallet card are not sufficient Structural Fumigation: Aeration via sulfuryl fluoride labeling

22. 22 Answer: Yes (if visor is down). Information is complete, and posted in a prominent place (a bystander could see it if needed in case of emergency). Sticker posted onto sun visor inside the cab of the truck If this sticker was stored inside the glove box rather than posted, that would not be in compliance. “Emergency Medical Care Posting” was one of the most common violation categories in structural inspections (2009- 11). “Emergency Medical Care Posting” was one of the most common violation categories in structural inspections (2009- 11). Requirement # 13 Emergency Medical Care Is this posting in compliance (yes or no) ? Structural Fumigation: Aeration via sulfuryl fluoride labeling Click for more info The employer must have CONTACTED the medical facility and assured that it is capable of handling illnesses and injuries caused by pesticide exposure - see 3CCR § 6726(a). For employees that work in a wide geographic area, the employer must post procedures for obtaining emergency medical care when the listed facility is too far away to be reasonably available. To check this ask the crew how many minutes would it take to drive from the work site to the medical facility listed on the posting? (click to close)

23. 23 For more information: 3CCR § 6780 Check Inspection Procedures Manual / SF Labeling For more information: 3CCR § 6780 Check Inspection Procedures Manual / SF Labeling What and how to inspect: Precautions taken to prevent exposure? Verify aeration procedures are followed correctly. Licensee present? Steps taken to prevent tarp crew from overexposure? Is a certified SF continuous monitoring device on site? Being used in breathing zones? PPM level for entry known? Ask how else to prevent exposure. Requirement #15: SCBA/ Continuous Monitoring Structural Fumigation: Aeration via sulfuryl fluoride labeling Click for more info The employer must ensure that employees who handle fumigants during introduction, aeration, and certification are not exposed above the Permissible Exposure Level (PEL) for airborne contaminants listed in 8CCR § 5155. During tear down and aeration operations, following fumigation of a typical residential structure, an overexposure situation to employees may exist. SCBA may not always be practical due to conditions at the work site (such as use on ladders, on rooftops pulling tarps, etc.). For this reason, the employer is given alternative methods of providing for exposure mitigation. One alternative is to employ continuous monitoring to warn employees before the PEL is reached. Ask the licensees how they measure fumigant levels at the work site. If you suspect levels are not being controlled and employees may not be fully protected, ask the licensee to test for fumigant levels or test the working atmosphere yourself to establish exposure in excess of the PEL. (click to close)

24. What and how to inspect: 24 Requirement #17: 2 Trained Employees For more information: 3 CCR § 6782(a) Check Inspection Procedures Manual re: when 2 trained employees do not have to be present For more information: 3 CCR § 6782(a) Check Inspection Procedures Manual re: when 2 trained employees do not have to be present Ask employees to demonstrate use of SCBA How many SCBAs should be available? How full should each SCBA be? What does ringing mean? Employees trained in artificial resuscitation? Proof of CPR training available? or Instruction chart of artificial resuscitation available? Structural Fumigation: Aeration via sulfuryl fluoride labeling

25. 25 1) Yes, employees providing info re: SCBA & CPR training 2) No, employee entering post fume, prior to clearance without using SCBA or continuous monitoring device Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for this violation? Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for this violation? Requirement #17: 2 Trained Employees Are these employees in compliance (yes or no) ? Structural Fumigation: Aeration via sulfuryl fluoride labeling CAC Inspector Tarps dropped; unknown PEL Employee entering; Signs up 1 2

26. What and how to inspect: Unprotected employees are prohibited from entering a fumigated enclosed space unless SF is <1ppm Is approved SF detection device on site? Does licensee know how to use it? Is device calibration current? Is device listed on SF labeling? Is respiratory equipment listed on SF labeling? What is purpose for entering enclosed space? 26 Requirement #18: Enclosed Space / Entry For more information: 3CCR § 6782(d) / SF Labeling re: aeration & reentry Check Inspection Procedures Manual For more information: 3CCR § 6782(d) / SF Labeling re: aeration & reentry Check Inspection Procedures Manual Structural Fumigation: Aeration via sulfuryl fluoride labeling

27. 27 Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take in response to this violation? Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take in response to this violation? 1. Yes, licensee checking concentration using Interscan 2. No, employees are in enclosed space without SCBA or continuous monitoring device Employees Requirement #18: Enclosed Space / Entry Are these employees in compliance (yes or no) ? Structural Fumigation: Aeration via sulfuryl fluoride labeling 2 1

28. What and how to inspect: After completion of the fumigation: How does the licensee prevent employees from entering the structure prior to it being certified safe to reenter? What precautions are taken to protect employees from being exposed to a concentration in excess of the Permissible Exposure Limit (PEL)? 28 For more information: 3CCR § 6782(f) Check Inspection Procedures Manual; SF Labeling For more information: 3CCR § 6782(f) Check Inspection Procedures Manual; SF Labeling Requirement #19: Proper Management of Treated Areas Structural Fumigation: Aeration via sulfuryl fluoride labeling

29. 29 Requirement #19: Proper Management of Treated Area 1. Yes, employee wearing SCBA to repair blowout 2. No, employee entering post fume, prior to clearance Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) What action (if any) should you take for this violation? Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP) What action (if any) should you take for this violation? Employee entering; Signs up 1 2 Are these employees in compliance (yes or no) ? Tarps dropped; unknown PEL Structural Fumigation: Aeration via sulfuryl fluoride labeling

30. What and how to inspect: Check the Fumigation Log (if present) to verify that a thorough search for drains, conduits or vacuum systems etc… was conducted by the licensee and discuss this with them. Verify that any discovered connection has been closed or the structure vacated and managed as a fumigated structure. If there were any conduits, how were they handled and determine if their closure is adequate to keep the fumigant from going past the connection. 30 For more information: FAC § 12973 and 16CCR 1970.6 Inspection Procedures Manual entry for this requirement For more information: FAC § 12973 and 16CCR 1970.6 Inspection Procedures Manual entry for this requirement Requirement #20: Connecting Structures Structural Fumigation: Aeration via sulfuryl fluoride labeling Click for more info Evaluate subflooring or basements to determine if connecting structures have been identified and whether conduits run between the connecting structures. Good communication between the Branch 3 inspector and the Branch 1 fumigator is essential. (click to close)

31. 31 Requirement # 20: Connecting Structures Structural Fumigation: Aeration via sulfuryl fluoride labeling Click for more info Conduits The fumigated structure should be inspected for pipes, conduits, ducts, or others features which would result in fumigant loss outside of the fumigated space. If possible, these features should be sealed to stop excessive gas loss. (click to close)

32. 32 Requirement # 20: Connecting Structures Structural Fumigation: Aeration via sulfuryl fluoride labeling

33. 33 1. Has the garage unit adjacent to the house in photo 1 (left) been documented in the fumigation log (conduits identified etc.…)? Follow up with your supervisor: What should you do in response to this violation? Follow up with your supervisor: What should you do in response to this violation? Requirement #20: Connecting Structures Are these in compliance (yes or no) ? Structural Fumigation: Aeration via sulfuryl fluoride labeling 2. Has it been determined in photo 2 (right) that the drain at the gutter is not connected to the fumigated home? Click for more info 1 2 How do you know what might be connected to an adjacent structure? Have you gone into both structures to determine if the buildings contain connected electrical conduits, drains, vacuum systems etc.… Many homes have downspout systems that are directed to belowground drains that release water to the front curb or front yard somewhere. How can you tell which drain system belongs to the fumigated structure? How do you determine that the fumigator asked the right questions? Does the licensee know about the fumigation log and is it filled out for this fumigation. (click to close)

34. Requirement #20: Connecting Structures 34 Answer: No Conduit carries electrical wires from house to detached garage This house was fumed, & will be aerated via CAP Licensee has no plan to aerate or monitor this detached garage Detached Garage House Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for this violation? Follow up with your supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for this violation? Garage should be considered a connecting structure. Should have been tarped (too late). It should be aerated. Is this in compliance (yes or no) ? Structural Fumigation: Aeration via sulfuryl fluoride labeling

35. What and how to inspect: 35 Requirement #23: Structure Vacated/Secured For more information: 16CCR § 8505.7 / CAP Check Inspection Procedures Manual For more information: 16CCR § 8505.7 / CAP Check Inspection Procedures Manual Prior to commencement of a fumigation, structure must be: Vacated by all occupants. Ask how this was verified particularly with multi-unit structures. Secured (all entrances) against entry, including door ways used for air exchange, until structure is cleared for re-occupancy. Ask licensee about secondary locks. Structural Fumigation: Aeration via sulfuryl fluoride labeling

36. 36 Requirement #23: Structure Vacated/Secured Question for supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for this violation? Question for supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for this violation? 1. No, pet door not secured 2. No, opening 3” minimum, but not secured 3. No, secondary lock allows gap; door not used as airway Are structures in compliance (yes or no) ? Structural Fumigation: Aeration via sulfuryl fluoride labeling 1 2 3

37. What and how to inspect: 37 Requirement #25: 2 SCBA / CPR Chart For more information: 16CCR § 1971(a) / CAP / 3CCR § 6739 Check Inspection Procedures Manual re: CAP exemption For more information: 16CCR § 1971(a) / CAP / 3CCR § 6739 Check Inspection Procedures Manual re: CAP exemption Fume crews must have a safety kit on-site Verify presence & completeness of safety kit. Ask crew about purpose, use & care of safety kit. Ask crew if/when it had first aid & CPR training. Two + SCBA units must be readily available Check pressure gauge on air tanks. Enough air to complete job? Extra tanks available? Ask crew what bell ringing on SCBA means. If ringing when in structure? Structural Fumigation: Aeration via sulfuryl fluoride labeling

38. 38 Requirement #25: 2 SCBA / CPR Chart Answers: Yes 1. 3 SCBA in vehicle; sufficient air in tanks 2. Instructions for artificial resuscitation available 1 2 Are these in compliance (yes or no) ? Structural Fumigation: Aeration via sulfuryl fluoride labeling

39. What and how to inspect: 39 Requirement #28: Direct Supervision For more information: B&P Code § 8505.2 / B&P Code § 8505.3 CAP / Check Inspection Procedures Manual For more information: B&P Code § 8505.2 / B&P Code § 8505.3 CAP / Check Inspection Procedures Manual Structural fumes require direct supervision: During fumigant release During active aeration For reentry clearance Identify supervising licensee; ask to see SPCB license Structural Fumigation: Aeration via sulfuryl fluoride labeling

40. 40 Answer: Yes 1 hour active aeration 6-8 hour passive Structural Fumigation: Aeration via sulfuryl fluoride labeling Is Direct Supervision in compliance (yes or no) ? Requirement #28: Direct Supervision Images convey presence of licensee during key elements of aeration process

41. What and how to inspect: 41 Requirement #29: Warning Signs – all sides For more information: 16CCR § 1974 Check Inspection Procedures Manual for posting specifics For more information: 16CCR § 1974 Check Inspection Procedures Manual for posting specifics Prior to commencing fume, post warning signs: On structure On tarps At all joint seams Are warning signs posted at required locations? Are warning signs too weathered to read? Torn? Posted for required duration? Visible? Any missing? Warning signs posted: On structure: under tarps, until structure is posted safe for re-occupancy. On each side of structure; at or near all entrances On tarps: visible from all accessible sides of structure; from any direction site is approached At all joint seams: of tarp at 1 st floor level (click to close) Click for more info Structural Fumigation: Aeration via sulfuryl fluoride labeling

42. 42 Requirement #29: Warning Signs – all sides Question for supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for the violation? Question for supervisor: Based on 3CCR §6128 & §6130 (ACP), or 16CCR §1922 (SCP), what action (if any) should you take for the violation? 1. Warning sign not readable. What about others? 2. Window is not an entrance; placement of other signs? Answer: Depends 1 2 Are these signs in compliance (yes or no) ? Structural Fumigation: Aeration via sulfuryl fluoride labeling

43. What and how to inspect: 43 Requirement #30: Information on warning signs For more information: B&P Code § 8505.10 / *16CCR § 1974(c) Check Inspection Procedures Manual For more information: B&P Code § 8505.10 / *16CCR § 1974(c) Check Inspection Procedures Manual Warning Signs: specific dimensions, colors, statements, and images Warning Signs shall include specific information Include fumigant trade name & active ingredient? Fumigator info complete? “Time shot” included? Difference between signs on structure vs on tarp? In addition to English, is Spanish required? Do letters / images meet required height? Is it the correct color? Neither BPC 8505.10 nor 16CCR 1974 mention requirements for the Spanish translation on the Warning Sign; however, the sign image included in regulation, which includes Spanish text (16 CCRi1974) is enforceable. The image contains the text required to be in Spanish. Companies can include other text in Spanish. 16CCR 1974(c) is not in the 2010 Structural Act. It can be found on SPCB’s website: http://pestboard.ca.gov/pestlaw/pestact.pdf http://pestboard.ca.gov/pestlaw/pestact.pdf (click to close) Click for more info Structural Fumigation: Aeration via sulfuryl fluoride labeling

44. 44 Requirement #30: Information on warning signs Answer: Is this Warning Sign in compliance (yes or no) ? Structural Fumigation: Aeration via sulfuryl fluoride labeling Date listed Time Not Given Yes, since sign is on ___________. If sign was on _________, no. structure tarp Meets 12 of 13 required* items (BPC 8505.10): -Warning sign (letters/images) printed in red on white background -Contains “Danger-Fumigation” statement -Danger-Fumigation statement is >2” tall -Skull & Crossbones present -Skull & Crossbones >1” tall -Fumigant name present -Date present -Item 6 & 7 letters >.5” -Registered company name -Registered company address -Registered company phone numbers (day & night) -Items 9, 10, 11 letters >.5” *13) Time fumigant introduced (shot) – Not Required since sign is obviously posted on the structure (underneath the tarp). Time is required on Warning Signs posted on the fumigation tarp. (click to close) Click for more info

45. 45 CONGRATULATIONS! * 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) Structural Fumigation: Aeration via sulfuryl fluoride labeling You have completed the Aeration via sulfuryl fluoride module that covers 15* requirements on the Structural Fumigation Use Inspection Form: #REQUIERMENT# 1Registered in county19Proper management of treated area 2County notified 24 hours prior20Connecting structures 7Labeling – aeration/ certification23Structure vacated/ secured against re-entry 12Handler(s) trained252 SCBA/ CPR chart/ mfg. instructions 13Emergency medical care, posting28Direct supervision 15SCBA worn/ cont. monitoring / CAP29Warning signs on all sides of structure 172 trained employees30Required information on warning signs 18Fume of enclosed spaces /proper entry

46. 46 Please complete both modules before conducting an actual inspection of the aeration phase of a structural fumigation: Aeration via CAP Aeration via SF product labeling Reason: Aeration that began via CAP may require aeration completion via SF product labeling procedures Examples: Blowouts, malfunction of CAP equipment, intentional cutting of tarps (burglary) Inspectors need to be prepared for both aeration methods. Structural Fumigation: Aeration via sulfuryl fluoride labeling

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