Chapter 9 Buffer Zones and Posting Requirements

Chapter 9 Buffer Zones and Posting Requirements

Module Three Chapters 7, 8, & 9 Chapter 7 Site Assessment and Weather PREPARING FOR SOIL FUMIGATION The first step in such preparation is site assessment evaluate the suitability of the site.

Site assessment will help to: protect people and the environment. choose soil management methods, fumigants, and application techniques.. maximize fumigant efficacy. SITE ASSESSMENT Determine if the proposed application site is near areas where people gather (e.g., residences, businesses, public meeting sites, hospitals, or schools).

Nearness to occupied structures does not necessarily preclude fumigation (except for some occupied difficult-to-evacuate sites). However, it does require additional planning. SITE ASSESSMENT Evaluate the sites topography (surface features). Under stable air conditions, if fumigant vapors travel offsite, they can collect and concentrate down slope. When making a soil fumigant application, consider the

potential offsite movement to surrounding areas due to changes in topography. Take additional precautions if these areas contain structures occupied by humans or animals, or if you will need to enter them during or shortly after the fumigation. Such precautions include wearing appropriate PPE and monitoring for fumigant air concentrations. Identify and locate field obstacles that may pose risk to the applicator or application equipment. SOIL CHARACTERISTICS

Environmental and field conditions affect both the success and the safety of the fumigation. Be aware that fumigant labels carry specific directions for mandatory GAPs to prepare soil before fumigation. Soil GAPs refer to soil preparation, condition, moisture, and temperature. PREPARING FOR SOIL FUMIGATION

PREPARING FOR SOIL FUMIGATION WEATHER FORECAST Present and immediate postapplicaton weather conditions affect fumigant vapors that escape from the soil. These vapors can move offsite and expose nearby people, animals, and plants. This includes both weather conditions at the start of the application and immediately after the application. The certified applicator supervising the application must check the National Weather Service (NWS) forecast before

a soil fumigation. This check will help determine if unfavorable weather conditions may occur when a fumigation is planned and whether the application should proceed. WEATHER FORECAST Check the weather forecast: On the day of and preceding the start of the application. Each day during the application if the time elapsed from the start of the application

until the application is complete is greater than 24 hours. ONCE AGAIN WEATHER FORECAST You may obtain detailed NWS forecasts for local weather conditions, wind speed, and air stagnation advisories online at: - http://www.nws.noaa.gov, - on National Oceanic and Atmospheric

Administration (NOAA) weather radio, - or by contacting your local NWS forecasting office. TEMPERATURE INVERSIONS Temperature inversions are often to blame for human exposure to fumigants. In an inversion, warmer (lighter) air rises above cooler (heavier) air, which settles near the ground. Under inversion conditions, normal air mixing does not take place; fumigant vapors settle and concentrate near the

ground. When an inversion happens, fumigant vapors often move offsite with low-level air movement or settle in low-lying areas. Low-level winds (less than 2 mph) are highly unpredictable in the direction they move. TEMPERATURE INVERSIONS Clues that inversion conditions exist include: Road dust that hangs in the air and has little upward or lateral movement.

Ground fog or smog that remains concentrated with little upward movement. Smoke from the ground that rises little, flattens out, and moves as a concentrated cloud. TEMPERATURE INVERSIONS TEMPERATURE INVERSIONS Temperature inversion conditions typically start an hour before sunset and continue past sunrise.

They may persist as late as noontime. However, inversions can persist all day long. Inversion conditions are common on nights with limited cloud cover and little to no wind. Look for ground fog, smog, or smoke that flattens out below a ceiling layer and moves sideways in a concentrated cloud. (Note that coastal fog generated by inland movement of sea air masses does not necessarily indicate temperature inversions.) TEMPERATURE INVERSIONS

Air Stagnation Advisory Most labels (except 1,3-D only formulations) prohibit an application to proceed if an air stagnation advisory issued by the NWS is in effect for the area anytime from the start of application until 48 hours after the application is scheduled to be complete. If an air stagnation warning occurs during the application, the application must stop. ONCE AGAIN

LIGHT WINDS Most labels (except 1,3-D only formulations) prohibit an application to proceed if light wind conditions (less than 2 mph) are expected to persist for more than 18 consecutive hours from the time the application starts until 48 hours after the application is scheduled to be complete.

Review Questions Which of the following items must you consider during a site assessment? 1. Topography. 2. Geneology. 3. Geology 0% 1

0% 2 0% 3 A fumigant handler is planning to apply a fumigant to a sloping field. The loam soil contains some surface crop residue and 60 % available soil moisture. Which site or soil characteristic should be

the handlers biggest concern? 1. The steepness of the slope. 2. The amount of crop residue. 3. The available moisture. 0% 1

0% 2 0% 3 Which of the following predicted weather conditions will prohibit a fumigant application? 1.

2. 3. If wind speed of 3 mph or less persists for 18 consecutive hours from the start of the application until 48 hours after the application is scheduled to end. If an air stagnation advisory

will occur any time from the start of the application until 48 hours after the application is scheduled to end. If wind speed between 5 and 10 mph occurs during a solid stream chemigation application. 0% 1

0% 2 0% 3 Which two statements about temperature inversions are correct? 1.

2. 3. (1) They typically start an hour before sunset; (2) they are common on nights with limited cloud cover (1) Cooler air is above warmer air; (2) normal air mixing does not take place.

(1) Warmer air rises above cooler air; (2) wind speed exceeds 7 mph. 0% 1 0% 2 0% 3

Fumigant Management Plan (FMP) A Fumigant Management Plan (FMP) is a site-specific plan prepared before any fumigation begins. An FMP is intended to ensure that all aspects of a safe and effective fumigation have been planned ahead of the actual work. It captures how a certified applicator is planning to comply with label requirements and serves as a record of compliance.

Fumigant Management Plan (FMP) Fumigant Management Plan (FMP) Anyone may develop the FMP. However, the certified applicator-in-charge of the application must, before beginning the fumigation: review, sign, and date the plan to verify that it is accurate, up to date, and complies with the label.

Fumigant Management Plan (FMP) You must record all of the following elements in a soil fumigation FMP: Certified applicator and owner information. General site information. General application information. Tarp plan (if tarp is used). Soil conditions. Buffer zones.

Fumigant Management Plan (FMP) You must also record all of the following elements in a soil fumigation FMP: Emergency response plan. Posting of fumigant treated area and buffer zone signs. Emergency preparedness and response measures (if applicable). State and/or tribal lead agency advance notification. Communication plan.

Fumigant Management Plan (FMP) You must also record all of the following elements in a soil fumigation FMP: Fumigant handler information, training, and PPE. Air-monitoring plan. Chemigation and drip application monitoring information (if applicable). Good agricultural practices. Pesticide product labels and Material Safety Data Sheets (MSDSs).

Fumigant Management Plan (FMP) FMP DOCUMENTATION AND RECORDKEEPING A certified applicator or other worker must prepare and review an FMP before a soil fumigation begins. The FMP must be kept on site during all handler activities. It must also be made immediately available to handlers; local, state, federal, and tribal enforcement personnel; and emergency responders.

Both the certified applicator and the property owner/lessee must keep a copy of the FMP on file for two years from the date of the application. GROWERS MAY CHOOSE TO DEVELOP A FARM-WIDE FMP A farm-wide FMP allows growers to: keep the information common to all application blocks on the farm in one document and in one place (for example, in the first section of a binder). include information about the certified applicator, owner,

fumigant handlers, and emergency response plans. include details on the product, tarps, and/or application method. Information unique to each separate application block is recorded in different sections. This might include the location and size of each application block, buffer sizes, application dates, weather, and soil conditions. GROWERS MAY CHOOSE TO DEVELOP A FARM-WIDE FMP

Fumigant Management Plan (FMP) Fumigant Management Plan (FMP) Postapplication Summary (PAS) Fumigant Management Plan (FMP) Postapplication Summary (PAS) FMP/PAS Soil fumigant labels require that:

both the certified applicator and the owner/ operator retain the FMP and PAS for two years. Note: Federal RUP application record retention requirements are also two years. Additional Information: Several templates and web-based systems exist for preparing FMPs and PASs. These are available from EPA, pesticide registrants, and commercial entities.

Some of the commercially-available programs may contain enough information to meet the application record, FMP, and PAS reporting requirements. Review Questions The certified applicator-in-charge of the fumigation is the only person who may prepare a fumigant management plan (FMP).

1. True 2. False 0% 1 0% 2 During a soil fumigation, how long must

the FMP be kept on site? 1. Only while fumigant is being applied. 2. Only at the start of the application. 3. During all handler activities. 0% 1

0% 2 0% 3 Select the two statements that describe how the postapplication summary (PAS) differs from the fumigant management plan (FMP)? 1.

2. 3. (1) PAS contains agreements made with neighbors; (2) PAS documents if tarps were damaged (1) PAS may be prepared by anyone; (2) PAS includes the

weather forecast during and after the application. (1) PAS records any deviations from the FMP; (2) PAS reports any incidents or complaints. 0% 1 0%

2 0% 3 Both the certified applicator and the property owner/lessee must keep a copy of the FMP on file for two years from the date of the application. 1. True 2. False

0% 1 0% 2 Chapter 9 Buffer Zones and Posting Requirements

Buffer Zones Buffer zones are required for most fumigations. A buffer zone is a restricted-access area surrounding the application block. It must remain in place From the start of the application until 48-hours after for most products. To protect bystanders from fumigant exposure. Only trained fumigant handlers wearing appropriate PPE may be in the buffer zone, with the exception

of vehicular or bicycle traffic on roadways. Application Block The area being treated during the fumigation An application block can be a field, contiguous fields, a greenhouse, or a series of beds or planting strips undergoing fumigation. The perimeter of the application block is the border that connects

the outermost edges of the total area treated with the fumigant. The size of the application block is the area within the perimeter of the field where the fumigant is applied. Buffer zones are established around the application block and extend outward from the perimeter of the treated area equally in all directions. Buffer Zone Period The buffer zone period extends from the time that the fumigant application begins until 48 hours after the application ends

One exception to the 48-hour period is for products formulated with 1,3-D as the only active ingredient, which have a seven day buffer zone period. Methyl bromide labels require a longer buffer zone period or a second buffer zone for certain tarps. Read labels carefully to make sure you understand buffer zone. During the buffer zone period, all nonhandlers, field workers, nearby residents, pedestrians, and other bystanders must stay out of the buffer zone with one exception: people in transit (vehicular and bicycle) on roadways may move through the

buffer zone. Buffer Zone Size Labels include tables showing required buffer zone sizes. The minimum buffer distance noted on most labels is 25 feet. Buffer zone size is based on several factors:

Fumigant being used. Application rate. Application block size. Application method. Use these tables to determine the size. Labels include separate tables for different application methods.

Application is prohibited for rates or block sizes that exceed those presented in the buffer zone table. Roundup to the nearest rate or block size. Buffer Zone Distances in Feet Shank Injection Application 60 acres

80 acres 100 acres 120 acres 160 acres

80 lbs a.i./acre 200 275 350 400

533 120 lbs a.i./acre 500 600 700

800 1067 160 lbs a.i./acre 750 925

1050 1250 1667 200 lbs a.i./acre 938

1156 1313 1563 2083 240 lbs a.i./acre

1125 1388 1575 1875 2500

Buffer Zone Credits Buffer zone credits on fumigant labels allow reductions in buffer zone distance. Here are several factors that may earn buffer zone credits: Use of specific high-barrier tarps Soil conditions (e.g., soil organic matter and soil temperature). Use of certain application equipment. Buffer Zone Credits

There is a maximum buffer zone reduction that can be earned using these credits, for example: 80% maximum credit for methyl bromide, chloropicrin, metam sodium, and metam potassium. 40% maximum credit for dazomet. The certified applicator must record certain information on buffer zones in the FMP: the buffer zone distance, any credits (if earned), and any measurements taken to determine the size of the

buffer zone. Remember these two important factors about buffer zones: If, after applying all applicable buffer zone credits, the buffer zone is greater than a half mile (2,640 ft), then the application is prohibited. In all cases where buffer zones are required, the minimum buffer zone allowed is 25 feet.

Overlapping Buffer Zones Fumigant labels specify that buffer zones of multiple application blocks may overlap only if at least 12 hours pass between the completion of the first application and the start of the second. Other Buffer Zone Restrictions

Residential and Business Areas: Buffer zones may not include residential areas unless the occupants sign a written agreement to voluntarily vacate the buffer zone during the buffer zone period. Other Structures: Buffer zones must not include buildings used for storage (such as sheds, barns, and garages), unless both of the following are true: The storage buildings are not occupied during the buffer zone period.

The storage buildings do not share a common wall with an occupied structure. Roadways, Rights-of-Way, and Transit through Buffer Zones A buffer zone may include roadways and/or rights-of-way only if all three of the following are true: The area is unoccupied during the buffer zone period. Entry by nonfumigant handlers is prohibited. Certified applicators comply with all local laws and regulations.

Only vehicular and bicycle traffic are allowed to travel through buffer zones during the buffer zone period. Bus stops or other areas where people wait for public transportation must not be included in a buffer zone. Publically Owned or Operated Areas A buffer zone may include publically owned or operated areas (such as a public park) if all of the

following are true: The area is unoccupied during the buffer zone period. Nonfumigant handlers are prohibited from entering. Certified applicators comply with all local laws and regulations. The state or local authorities responsible for the management and operation of the area provide written permission. Other Agricultural Areas A buffer zone may include an agricultural

area owned by another person if both of the following are true: Buffer zones for different fumigations do not overlap. The owner or operator provides written agreement that no one will enter the buffer zone during the buffer zone period. Signage and Posting Requirements Most soil fumigant labels require two types of postings: Treated Area Posting, and

Buffer Zone Posting. All require treated area posting according to WPS requirements. Most require buffer zone posting (except 1,3-D only products). Some of the information on these signs is the same: contact information for the certified applicator and details of the product to be used. However, they are two different sets of signs with two different posting requirements.

Treated Area Posting Fumigant treated area signs are posted at the perimeter of the application block. The information on the signage is different from regular WPS signs. Skull and crossbones symbol. DANGER/PELIGRO. Area under fumigation, DO NOT ENTER/NO ENTRE.

[Name or names of the fumigant active ingredient] fumigant in use. [Name of the product]. Date and time of fumigation (start and finish). Date and time entry-restricted period is over. Name, address, and telephone number of the certified applicatorin-charge of the fumigation Treated Area Posting

For soil fumigations, the fumigant treated area sign replaces the WPS no-entry sign. Fumigant treated area signs must be: Posted at all entrances to the application block. Posted no sooner than 24 hours before application. In place for at least the duration of the entryrestricted period. Removed within three days after the end of the entry-restricted period. Buffer Zone Posting

Buffer zone signs warn workers and bystanders about the location of the buffer zone, entry prohibition, and other important information. Buffer zone signs are available at fumigant points of sale. You can also download templates from the EPAs soil fumigant website: http:// www.epa.gov/fumiganttraining/.

Buffer Zone Signs Buffer zone signs must include all of the following: Do Not Walk symbol. DO NOT ENTER/NO ENTRE. [Name of fumigant active ingredient]; [name of product]; fumigant buffer zone. Contact information for the certified applicator-in-charge of the fumigation. Buffer zone signs must be: Posted at all points of entry into the buffer zone and along likely travel routes (roads, sidewalks, walking paths, and bike trails), facing in the direction that

people approach the area. Legible. A minimum of 14 by 16 inches, with letters a minimum of 1 inch. Posted no sooner than 24 hours before application. In place until end of buffer zone period. Removed within three days after the end of buffer zone period. Buffer Zone sign Difficult-to-Evacuate Sites Some sites are difficult to evacuate in cases of an

accident or emergency. Product labels prohibit fumigant applications near occupied difficult-toevacuate sites, which include the following: Schools (pre-kindergarten through grade 12). State-licensed daycare centers. Nursing homes. Assisted-living facilities. Hospitals. In-patient clinics. Prisons. Review

Questions Select two practices that may earn buffer zone credits to reduce buffer zone distances: 1. (1) Applying at lower soil temperatures; (2) using certain application equipment. 2. (1) Selecting certain soil fumigants; (2) applying to highly organic soils.

3. (1) Applying at certain times of the day; (2) using a water seal over tarps. 0% 1 0% 2

0% 3 What is the maximum buffer zone credit for metam sodium and metam potassium? 1. 20% 2. 40% 3. 80% 0%

1 0% 2 0% 3 Besides fumigant handlers, who else may enter the buffer zone? 1. Vehicular and

bicycle traffic on roadways. 2. No one; only fumigant handlers may enter. 3. People passing through on a sidewalk or walking path 0%

1 0% 2 0% 3 In what way is posting of fumigant treated areas (the application block) different from the Worker Protection Standard (WPS) noentry posting of nonfumigated treated areas?

1. The location of the warning sign. 2. The information on the warning sign. 3. The length of time the warning sign remains posted. 0% 1

0% 2 0% 3 Two buffer zones can overlap if at least twelve hours have passed between the completion of the first and the start of the second. 1. True 2. False

0% 1 0% 2

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