United States Prevention, Pesticides EPA 738-R-09-311 

Environmental Protection and Toxic Substances May 2009 

Agency (7508P) 

Amended Reregistration Eligibility 

Decision for Methyl Bromide 

(soil and non-food structural uses) 

3

Glossary of Terms and Abbreviations 

AHEF Atmospheric Health Effects Framework 

ai Active Ingredient 

ANLA American Nursery and Landscape Association 

APHIS Animal and Plant Heath Inspection Service 

APR air-purifying respirator 

ARS Agricultural Research Service 

ATV all-terrain vehicle 

BEAD Biological and Economic Analysis Division 

BrO bromine monoxide 

CDPR California Department of Pesticide Regulation 

CFC chlorofluorocarbons 

CFR Code of Federal Regulations 

ClO chlorine monoxide 

CMTF Chloropicrin Manufacturers’ Task Force 

CSF Confidential Statement of Formulation 

CUE Critical Use Exemption 

CUN Critical Use Nominations 

DCI Data Call-In 

DNT Developmental Neurotoxicity 

EDSP Endocrine Disruptor Screening Program 

EDSTAC Endocrine Disruptor Screening and Testing Advisory Committee 

EEC Estimated Environmental Concentration 

EPA Environmental Protection Agency 

EUP End-Use Product 

FDMS Federal Docket Management System 

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

FFDCA Federal Food, Drug, and Cosmetic Act 

FMP Fumigant Management Plan 

FQPA Food Quality Protection Act 

ft feet 

GAP Good Agricultural Practices 

GENEEC GENeric Estimated Exposure Concentration model 

GLN Guideline Number 

GPS Global Positioning System 

ha hectare 

HCFC hydrochlorofluorocarbons 

HDPE High-density Polyethylene 

HED Health Effects Division 

ISCST3 Industrial Source Complex Short Term model 

KTS Potassium Thiosulfate 

lb pound 
4

LC50 Median Lethal Concentration. A statistically derived concentration of a 

substance that can be expected to cause death in 50% of test animals. It is 

usually expressed as the weight of a substance per weight or volume of 

water, air, or feed, e.g., mg/l, mg/kg, or ppm. 

LD50 Median Lethal Dose. A statistically derived single dose that can be 

expected to cause death in 50% of the test animals when administered by 

the route indicated (oral, dermal, inhalation). It is expressed as a weight 

of substance per unit weight of animal, e.g., mg/kg. 

LOC Level of Concern 

LOAEL Lowest Observed Adverse Effect Level 

MBAO Methyl Bromide Alternatives Outreach 

MBIP Methyl Bromide Industry Panel 

MBTOC Methyl Bromide Technical Options Committee 

MCFA Minor Crop Farmer Alliance 

mg/kg/day Milligram Per Kilogram Per Day 

mg/L Milligram Per Liter 

MITC methyl isothiocyanate 

MOE Margin of Exposure 

MRID Master Record Identification Number. EPA’s system for recording and 

tracking studies submitted. 

MSHA Mine Safety and Health Administration 

MUP Manufacturing-Use Product 

NAM National Association of Manufacturers 

NIOSH National Institute for Occupational Safety and Health 

NOAEL No Observed Adverse Effect Level 

NPDES National Pollutant Discharge Elimination System 

OAP Office of Atmospheric Programs 

OAR Office of Air and Radiation 

ODP ozone depletion potential 

OPP EPA Office of Pesticide Programs 

OPPTS EPA Office of Prevention, Pesticides, and Toxic Substances 

ORE Occupational and Residential Exposure 

OSHA Occupational Safety and Health Administration 

PC Pesticide Chemical 

PDCI Product-specific Data Call-in 

PERFUM Probabilistic Exposure and Risk model for Fumigants 

PLHCP Physician or Other Licensed Health Care Professional 

PPE Personal Protective Equipment 

ppm Parts Per Million 

PrG Pressurized gas 

PRZM/EXAMS Pesticide Root Zone Model/Exposure Analysis Modeling System. A Tier 

II Surface Water Computer Model. 

PSA public service announcement 

psi pounds per square inch 
5

PVC Polyvinyl Chloride 

QPS Quarantine and Preshipment 

RED Reregistration Eligibility Decision 

REI Restricted Entry Interval 

RQ Risk Quotient 

RUP Restricted Use Pesticide 

SAB Science Advisory Board 

SCBA self-contained breathing apparatus 

SLA State Lead Agency 

SRRD Special Review and Reregistration Division 

TEAP Technical and Economic Assessment Panel 

TRED Tolerance Reassessment and Risk Management Decision 

TWA time weighted average 

UNEP United Nations Environment Programme 

USC United States Code 

USDA United States Department of Agriculture 

UF Uncertainty Factor 

UV Ultraviolet 

VIF Virtually Impermeable Film 

WPS Worker Protection Standard 
6 

Table of Contents 

Methyl Bromide Reregistration Eligibility Decision Team.........................................................................9 

Abstract......................................................................................................................................................10 

I. Introduction..........................................................................................................................................12 

II. Chemical Overview .............................................................................................................................16 

 A. Chemical Identity...........................................................................................................................16 

 B. Use and Usage Profile....................................................................................................................17 

 C. Regulatory History .........................................................................................................................18 

III. Fumigant Overview and Agency Documents......................................................................................18 

 A. General Overview of Soil Fumigants.............................................................................................18 

 B. Human Health Risks.......................................................................................................................18 

 C. Stratospheric Ozone Depletion.......................................................................................................21 

 D. Environmental Fate and Ecological Risks .....................................................................................25 

 1. Hazard.......................................................................................................................................25 

 2. Exposure ...................................................................................................................................26 

 a. Terrestrial Exposure............................................................................................................26 

 b. Aquatic Exposure................................................................................................................26 

 3. Risk ...........................................................................................................................................27 

 a. Terrestrial Risk....................................................................................................................27 

 b. Aquatic Risk........................................................................................................................27 

 E. Benefits...........................................................................................................................................28 

 F. Impacts of RED Mitigation ............................................................................................................29 

IV. Risk Management and Reregistration Decision...................................................................................31 

 A. Determination of Reregistration Eligibility ...................................................................................31 

 B. Public Comments and Responses...................................................................................................35 

 C. Regulatory Position........................................................................................................................36 

 1. Regulatory Rationale ................................................................................................................36 

 a. Generic Risk Management..................................................................................................37 

 1) Use Sites .......................................................................................................................37 

 2) Formulations.................................................................................................................37 

 3) Application Methods ....................................................................................................38 

 4) Maximum Application Rates........................................................................................38 

 b. Human Health Risk Management.......................................................................................39 

 1) Bystander Risk Mitigation............................................................................................40

 i. Buffer Zones ..........................................................................................................41 

 ii. General Buffer Zone Requirements.......................................................................41 

 iii. Buffer Zone Reduction Credits..............................................................................59 

 iv. Restriction for Schools and Other Difficult to Evacuate Sites ..............................65 

 v. Posting....................................................................................................................66 

 2) Occupational Risk Mitigation.......................................................................................69 

 i. Handler Definition .................................................................................................69 

 ii. Handler Requirements ...........................................................................................70 

 iii. Respiratory Protection ...........................................................................................71 

 iv. Tarp Perforation and Removal...............................................................................81 

 v. Entry Prohibitions ..................................................................................................84 
7 

 3) Other Mitigation ...........................................................................................................89 

 i. Good Agricultural Practices (GAPs) .....................................................................89 

 ii. Fumigant Management Plans (FMPs) ...................................................................97 

 iii. Site Specific Response and Management ............................................................104 

 iv. Notice to State Lead Agencies.............................................................................111 

 v. Soil Fumigation Training for Applicators and Training Information for 

Other Handlers.....................................................................................................112 

 vi. Community Outreach and Education Program....................................................117 

 c. Environmental Risk Management.....................................................................................122 

 d. Stratospheric Ozone Depletion Risk Management...........................................................123 

 2. Endocrine Disruptor Effects ...................................................................................................124 

 3. Endangered Species Considerations .......................................................................................125 

 D. Conclusions..................................................................................................................................125 

V. What Registrants Need To Do ...........................................................................................................125 

 A. Manufacturing Use Products........................................................................................................126 

 1. Additional Generic Data Requirements..................................................................................126

 a. Human Health Risk...........................................................................................................126 

 b. Environmental Fate and Ecological Risk..........................................................................127 

 c. Other Data Requirements..................................................................................................128 

 2. Labeling for Manufacturing-Use Products .............................................................................130 

 B. End-Use Products.........................................................................................................................131 

 1. Additional Product-Specific Data Requirements....................................................................131 

 2. Labeling for End-Use Products...............................................................................................131 

APPENDICES 

Appendix A. Methyl Bromide PC Code 053201 Pre-plant Soil Uses Eligible for Reregistration .........158 

Appendix B. PERFUM Model Inputs and Outputs ................................................................................160

Appendix C. FMP Template for Methyl Bromide Soil Applications.....................................................164 

Appendix D. Technical Support Documents ..........................................................................................177 

LIST OF TABLES 

Table 1. Modifications from 2008 to 2009 Amended Soil Fumigant REDs ............................................13 

Table 2. Implementation Schedule for Soil Fumigant Risk Mitigation Measures ...................................15 

Table 3. Maximum Application Rates for Pre-plant Soil Methyl Bromide Uses.....................................39 

Table 4. Tarped Bedded Buffer Zone Distances (feet).............................................................................51 

Table 5. Tarped Broadcast Buffer Zone Distances (feet) .........................................................................53 

Table 6. Deep Untarped Buffer Zone Distances (feet) .............................................................................55 

Table 7. Outdoor Tarped Hot Gas Buffer Zone Distances (feet)..............................................................55 

Table 8. Greenhouse Hot Gas Buffer Zone Distances (feet) ....................................................................55

Table 9. Projected Buffer Zones for Methyl Bromide Critical Use Exemptions Based on Current 

Typical Application Rates ..........................................................................................................56 

Table 10. Summary of Generic Labeling Changes for Methyl Bromide.............................................132 

Table 11. Standard Tarp (no credits) Buffer Zone Driver Table ..................................................156 

Table 12. Standard Tarp (no credits) Buffer Zone Driver Table ..................................................156 

Table 13. Deep (≥ 18 inches) Untarp Buffer Zone Driver Table .................................................157 

Table 14. Deep (≥ 18 inches) Untarp Buffer Zone Driver Table .................................................157 
8 

LIST OF FIGURES 

Figure A. Requirements for when handlers should cease operations .......................................................76 

Figure B. Requirements for when handlers should put on a respirator ....................................................77 

Figure C. Untarped Applications ..............................................................................................................86 

Figure D. Tarp Broadcast Applications (tarps removed before planting) ................................................87 

Figure E. Tarp Bed Applications (Tarps not removed before planting)...................................................88 

Figure F. Tarp Bed/Broadcast Applications (Tarps are not perforated until 14 days after 

application) ...............................................................................................................................89 

Figure G. Example Site Map for Informing Neighbors..........................................................................110 
9 

Methyl Bromide Reregistration Eligibility Decision Team 

Office of Pesticide Programs: 

Human Health Risk Assessment

Jeffrey L. Dawson, Chemist/Risk Assessor 

Elizabeth Mendez, Ph.D., Toxicologist/Risk Assessor 

Toiya Goodlow, Chemist 

Ruth Allen, MPH, Epidemiologist 

Monica Hawkins, MPH, Environmental Health Scientist 

Michael Metzger, Branch Chief 

Biological and Economic Analysis Assessment

T J Wyatt, Ph.D., Senior Agricultural Economist 

Jonathan Becker, Ph.D., Senior Science Advisor 

Bill Chism, Ph.D., Senior Agronomist 

David Donaldson, Agricultural Economist, Team Leader 

Colwell Cook, Ph.D., Entomologist 

Nicole Zinn, Biologist 

Stephen Smearman, Economist 

Leonard Yourman, Ph.D., Plant Pathologist 

John Faulkner, Ph.D., Economist 

Monisha Kaul, Biologist 

William Phillips, II, Ph.D., Agronomist 

Andrew Lee, Ph.D., Economist 

Angel Chiri, Ph.D., Entomologist, Team Leader 

Elisa Rim, Economist 

Nikhil Mallampalli, Ph.D., Entomologist 

Sunil Ratnayake, Ph.D., Botanist 

Environmental Fate and Effects Risk Assessment

Mah Shamim, Ph. D., Branch Chief 

Faruque Khan, Ph.D., Senior Fate Scientist 

James Felkel, M.S., Wildlife Biologist 

Gabriel Rothman, M.S., Environmental Scientist 

Registration Support

Mary Waller, Product Manager for Methyl Bromide and Chloropicrin 

Kathy Monk, Senior Advisor 

Risk Management

Susan Bartow, Chemical Review Manager for Methyl Bromide 

Andrea Carone, Chemical Review Manager for Chloropicrin 

Steven Weiss, Industrial Hygienist 

Eric Olson, Team Leader 

John Leahy, Senior Advisor 

Office of General Council: Andrea Medici 

Office of Enforcement and Compliance: David Stangel
10 

Abstract 

This document presents the Environmental Protection Agency’s (hereafter referred to as 

EPA or the Agency) amended decision regarding the reregistration eligibility of the registered 

soil and structural (non-food) uses of methyl bromide. This follows the 105-day public comment 

period on the Reregistration Eligibility Decision provided for stakeholders to have the 

opportunity to review and provide comments on issues related to the implementation of the risk 

mitigation measures. The Agency’s risk conclusions for methyl bromide have not changed. In 

addition, all measures established in the July 2008 Reregistration Eligibility Document (RED) to 

reduce risks to bystanders and workers will still be required. However, the Agency has 

determined that certain modifications in how and when some measures will be implemented are 

appropriate. Products containing methyl bromide uses are eligible for reregistration provided 

that: (1) current data gaps are addressed; (2) the risk mitigation measures identified in the 

document are adopted; and (3) labels are amended to implement these measures. 

The Agency has determined that methyl bromide-containing products for pre-plant soil 

uses that currently qualify for exemptions under the Montreal Protocol are eligible for 

reregistration provided that the risk mitigation measures identified in this document are adopted 

and labels are amended to implement these measures. Throughout this document measures 

described as “required” are those necessary to be eligible for reregistration. Additionally, 

registrants must address data gaps that have been identified. 

Concurrent to EPA’s review of the soil fumigant uses of methyl bromide, EPA assessed 

the risks and developed risk management decisions for four other soil fumigant pesticides, 

including: chloropicrin, dazomet, metam sodium/metam potassium, and a new active ingredient, 

iodomethane. Risks of a fifth soil fumigant, 1,3-dichloropropene (1,3-D), were also analyzed 

along with the other soil fumigants for comparative purposes. The RED for 1,3-D was 

completed in 1998. The Agency evaluated these soil fumigants concurrently to ensure that 

human health risk assessment approaches are consistent, and that risk tradeoffs and economic 

outcomes were considered appropriately in reaching risk management decisions. This review is 

part of EPA’s program to ensure that all pesticides meet current health and safety standards. 

The report of the Food Quality Protection Act (FQPA) Tolerance Reassessment and Risk 

Management Decision (TRED) for Methyl Bromide and RED for Methyl Bromide’s Commodity 

Uses was published on August 9, 2006 1

 (hereafter referred to as the Methyl Bromide 

TRED/RED). In January 2008, representatives of the Methyl Bromide Industry Panel (MBIP) 

presented to the EPA a preliminary summary of new emission studies for three flour mills. The 

information presented by the MBIP indicates that the new data could impact the Agency’s 

modeling of buffer zones for commodity uses. A final report was submitted to the Agency on 

April 23, 2008 2. The Agency plans to make appropriate updates to the Methyl Bromide 

 

1

 EPA-HQ-OPP-2005-0123-0231 The report of the Food Quality Protection Act (FQPA) Tolerance Reassessment 

and Risk Management Decision (TRED) for Methyl Bromide and Reregistration Eligibility Decision (RED) for 

Methyl Bromide’s Commodity Uses 

2

 MRID 47420302, Measurement of Structural and Ambient Methyl Bromide During Fumigation Activities at Food 

Processing Facilities: Final Report
11 

TRED/RED and respond to all comments upon review of the new data and based on comments 

submitted to the docket. 

EPA has identified potential human health risks of concern associated with the registered 

methyl bromide uses described in this document from inhalation exposure to handlers, 

bystanders, and workers. EPA also has concerns for risks associated with methyl bromide’s role 

in the depletion of stratospheric ozone. To reduce inhalation exposures and to address associated 

risks of concern, EPA is requiring a number of mitigation measures, such as: 

• Removing of uses with low benefits and/or alternatives; 

• Reducing maximum application rates; 

• Limiting use of 98:2 formulations to essential crops; 

• Buffer zones; 

• Respiratory protection and air monitoring for handlers; 

• Restrictions on the timing of perforating and removing tarps; 

• Posting; 

• GAPs; 

• FMPs; 

• Emergency preparedness and response plans; 

• Notice to state lead agencies; 

• Training for applicators and other handlers; and 

• Community outreach and education programs. 

The focus of the Agency’s mitigation measures for this decision (and for the Methyl 

Bromide TRED/RED) is on reducing direct exposure to methyl bromide via the inhalation route. 

However, the Agency has concluded that many of these measures, combined with the methyl 

bromide phase-out mandated by the Montreal Protocol, will also further reduce the potential 

health effects (e.g., skin cancer) from ozone depletion that may be attributable to methyl 

bromide’s uses. 

End-use products for registered pre-plant soil uses of methyl bromide also contain 

chloropicrin. All formulations must contain at least 2% chloropicrin as a warning agent. 

Chloropicrin is also formulated with methyl bromide at higher concentrations as an active 

ingredient. A separate amendment to the RED document has been completed for chloropicrin 

(see docket number EPA-HQ-OPP-2007-0350). In accordance with Agency policy, if the 

required risk mitigation measures differ for two active ingredients in a product, the more 

stringent mitigation measure is required on product labels. 

 The Agency is issuing this decision document for methyl bromide as announced in a 

Notice of Availability published in the Federal Register. 
12 

I. Introduction 

 This amends and supersedes the document, “Reregistration Eligibility Decision for 

Methyl Bromide,” published by the U.S. Environmental Protection Agency (hereafter, EPA) on 

July 16, 2008. That day EPA opened a 60-day public comment period on the implementation 

aspects of the risk mitigation measures that were required as conditions of reregistration 

eligibility under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). EPA received 

requests to extend the comment period from the MBIP, California Specialty Crops Council, the 

Chloropicrin Manufacturers’ Task Force (CMTF), the National Association of Manufacturers 

(NAM), the American Nursery and Landscape Association (ANLA), the California Strawberry 

Nurserymen’s Association, the Agricultural Retailers Association, the American Forest and 

Paper Association, and McDermott, Will, and Emery LLP, on behalf of the Minor Crop Farmer 

Alliance (MCFA). In response to these requests, on August 29, 2008, EPA published a notice in 

the Federal Register extending the comment period for an additional 45 days. The comment 

period closed on October 30, 2008. EPA has completed its review of public comments as well as 

new scientific data and other information provided and determined that all measures established 

in the July 2008 RED to reduce risks to bystanders and workers will still be required. The 

Agency has determined that certain modifications in how and when some measures will be 

implemented are appropriate. The public comments and EPA’s responses, as well as other 

supporting documents, may be found in the public docket for methyl bromide at EPA-HQ-OPP2005-0123. EPA has determined that the modifications described herein will achieve the same 

protection goals for persons potentially exposed to methyl bromide but with a greater likelihood 

of compliance, fewer impacts on the benefits of methyl bromide use, and with less uncertainty 

regarding the protectiveness of the required measures. Please see Table 1 for a summary of the 

modifications. 

FIFRA was amended in 1988 to accelerate the reregistration of products with active 

ingredients registered prior to November 1, 1984. The amended Act calls for the development 

and submission of data to support the reregistration of an active ingredient, as well as EPA’s 

review of all submitted data. Reregistration involves a thorough review of the scientific database 

underlying a pesticide’s registration. The purpose of the Agency’s review is to reassess the 

potential risks arising from the currently registered uses of the pesticide; to determine the need 

for additional data on health and environmental effects; and to determine whether or not the 

pesticide meets the “no unreasonable adverse effects” criteria of FIFRA. 

This document presents the Agency’s amendment to the reregistration eligibility decision 

for registered soil, and non-food structural uses of methyl bromide (i.e., uses not included in the 

August 2006 Methyl Bromide TRED/RED). The document consists of five sections. Section I 

contains the regulatory framework for reregistration and a synopsis of modifications from the 

2008 soil fumigant RED. Section II provides a profile of the use and usage of the chemical. 

Section III provides a general overview of fumigants and summarizes methyl bromide’s human 

health and ecological risk assessments, as well as benefit and impact assessments. Section IV 

presents the Agency’s reregistration eligibility and risk management decisions. Section V 

summarizes label changes necessary to implement the risk mitigation measures outlined in 

Section IV. Unless otherwise noted, all Agency references in this document are available for 

review in the methyl bromide docket (EPA-HQ-OPP-2005-0123) at www.Regulations.gov. 
13 

Table 1. Modifications from 2008 to 2009 Amended Soil Fumigant REDs 

Mitigation 2008 REDs 2009 Amended REDs 

Buffer Zones Buffer zones based on 

available data 

New chloropicrin data support smaller 

buffers and increased confidence in safety. 

New dazomet data support larger buffers 

Buffer Credits Credits allowed based on 

available data; capped at 

50% 

New data support additional credits and an 

increase in the cap to 80% 

Rights of Way Permission from local 

authorities must be granted 

if buffers extend onto 

rights of way 

Permission from local authorities is only 

required when a sidewalk or permanent 

walkway is present 

Buffer Overlap Buffers may not overlap Buffers may overlap; separate applications 

by 12 hours and increase emergency 

preparedness and response measures 

Structures within 

Buffer Zones 

Monitor with devices 

before reentry 

Monitor with devices only for applications 

with < 20 % chloropicrin; otherwise 

monitor for sensory irritation before 

reentry 

Restrictions Around 

Difficult to Evacuate 

Sites 

1⁄4 mile restriction around 

hard to evacuate areas 

including day care centers, 

nursing homes, schools; 

was to be in effect for the 

duration of the buffer zone 

period 

Maintain 1⁄4 mile restriction but allow a 

reduced restricted area of 1⁄8 mile for 

applications with smaller buffers (300 feet 

or less); is to be in effect during the 

application and for 36 hours following the 

start of the application 

Posting Posting required at buffer 

zones points of entry, 

where people are likely to 

approach, and areas 

between these locations 

The posting requirement is retained but no 

longer requires areas between the entry 

areas to be posted 

Information required on the signs has been 

simplified to encourage reuse of signs 

Handler Protection Described tasks that may 

only be performed by 

handlers and situations 

when 2 handlers were 

required to be present 

while in the buffer zone 

Tasks that may only be performed by 

handlers have been updated and clarified. 

The situations have been clarified 

requiring 2 handlers to be present based on 

the chemical properties of the different soil 

fumigants, and current label statements 

Respiratory 

Protection 

Required monitoring 

devices to trigger 

additional measures 

Allow sensory irritation properties to 

trigger additional measures for MITC and 

chloropicrin 

Monitoring with devices still required to 

remove respirators 

Monitoring with devices still required for 

methyl bromide formulations with <20% 

chloropicrin 

Tarp Perforation and 

Removal 

Perforating tarps restricted 

to mechanical means only 

Perforating tarps by hand is allowed for 

areas less than 1 acre in size and for flood 

prevention activities 
14 

Mitigation 2008 REDs 2009 Amended REDs 

Entry Prohibitions Entry for non-handlers is 

prohibited for the duration 

of the entry restricted 

period, until tarps have 

been removed, or if 14 

days has passed 

No major changes 

Restricted Use 

Classification 

The MITC generating 

compounds required to be 

classified as restricted use 

No change 

GAPs Certain GAPs required for 

all fumigant applications 

Some clarifications and refinements have 

been made based on stakeholder comments

FMPs FMPs required to be 

completed before fumigant 

application begins and 

post-application summary 

report required following 

the application 

No major changes. Based on comments an 

example of an FMP has been included to 

illustrate how the required information 

may be presented effectively 

Emergency Response 

and Preparedness 

If neighbors are near 

buffers they must be 

provided with information 

or buffer zones must be 

monitored every 1-2 hours 

over 48 hours with 

monitoring devices 

Same basic measures apply, however: 

monitoring required only during peak 

emission times of the day; irritation 

detection acceptable for MITC and 

chloropicrin in lieu of devices; methyl 

bromide requires direct read devices for 

formulations with <20% chloropicrin 

Notice to SLAs Applicators required to 

provide notice to the 

appropriate state/tribal lead 

agency before fumigating 

to facilitate compliance 

assistance and assurance 

States may determine if they wish to 

receive this information 

All states required to include strategies for 

compliance assistance and assurance for 

soil fumigation in their cooperative 

agreements 

Applicator Training Certified applicators 

required to receive 

registrant soil-fumigant 

training every year 

Certified applicators required to receive 

registrant soil-fumigant training every 

three years 

Community Outreach 

and Education 

Registrants required to 

develop and implement 

community outreach and 

education programs along 

with information for first 

responder in high fumigant 

use areas 

Same basic requirement. The Agency is 

providing information on where registrants 

are required to focus these efforts 

 With regard to implementation timing, EPA has determined that most measures can be 

efficiently implemented via revised product labels by the 2010 use season. Other measures, in 

particular those related to buffer zones, will present greater compliance challenges and will 

require additional time for EPA to conduct the necessary outreach, and communication activities 

with states, tribes, other regulatory partners, fumigant users, and other stakeholders to facilitate 

transition. EPA has determined that these measures will be implemented via revised product 
15 

labels by the 2011 use season. As a result, all measures described in this amended RED that are 

necessary for reregistration eligibility will appear on product labels by 2011. Table 2 below 

shows the measures that will be implemented in 2010 and the additional measures that will be 

implemented in 2011. 

Table 2. Implementation Schedule for Soil Fumigant Risk Mitigation Measures

Risk Mitigation Measure Currently 2010 2011 

Restricted Use ● ● ●

New Good Agricultural Practices ● ●

Rate reductions ● ●

Use site limitations ● ●

New handler protections ● ●

Tarp cutting and removal restrictions ● ●

Extended worker reentry restrictions ● ●

Training information for workers ● ●

Fumigant Management Plans ○ ●

First responder and community outreach ○ ●

Applicator training ○ ●

Compliance assistance and assurance measures ○ ●

Restrictions on applications near sensitive areas ●

Buffer zones around all occupied sites ●

Buffer credits for best practices ●

Buffer posting ●

Buffer overlap prohibitions ●

Emergency preparedness measures ●

○ = under development 

● = adopt completely 
16 

II. Chemical Overview 

A. Chemical Identity 

Chemical Structure: H 

 | 

H-C-Br 

 | 

 H 

Empirical Formula: CH3Br 

Common Name: Methyl bromide 

CAS Registry Number: 74-83-9 

OPP Chemical Code: 053201 

Case Number: 0335 

Technical or 

Manufacturing-Use 

Registrants: 

Albemarle Corporation, ICL-IP America Inc.3

, Great Lakes 

Chemical Corporation (a Chemtura Company), and TriCal. All four 

companies are members of the Methyl Bromide Industry Panel of the 

American Chemistry Council (MBIP). 

 

3 On July 1, 2008, Ameribrom Inc. changed the corporate name to “ICL-IP America Inc.”
17 

B. Use and Usage Profile 

Pesticide Type: Methyl bromide is a broad-spectrum fumigant chemical that can be 

used as an acaricide, antimicrobial, fungicide, herbicide, insecticide, 

nematicide, and vertebrate control agent. 

Target pests: Methyl bromide controls a wide range of pests including spiders, 

mites, fungi, plants, insects, nematodes, rodents, and snakes. 

Use patterns: Methyl bromide’s most prevalent use pattern is as a soil fumigant. It 

is also used as a post harvest treatment of commodities and structural 

fumigation. Structural non-food treatments (e.g., residential 

buildings) are reportedly no longer performed. 

Formulations: Pressurized gas (PrG) formulations are used for all methyl bromide 

applications. All methyl bromide products are classified as restricted 

use pesticides (RUP). The “Restricted Use” classification restricts a 

product, or its uses, to use by certified pesticide applicators or those 

working under the direct supervision of a certified applicator. 

Methods of Application: Soil uses: Methyl bromide is injected into the soil at various depths 

using tractors equipped with shanks of varying shapes, sizes, and 

orientations. Applications have historically been done with and 

without tarps but tarp use is prevalent. With the hot gas method, 

methyl bromide is forced through a heat exchanger into the drip 

tubing under tarps. Applications can be made to flat areas of a field or 

in user created raised bed culture. Applications are typically 

accompanied by some degree of soil compaction or use of shank trace 

closure devices. 

Other Uses: Methyl bromide gas is injected into an enclosure, 

chamber, structure, or under a tarp remotely using flexible tubing 

connected to pressurized gas tanks. 

Application Rates: Soil uses: Common pre-plant agricultural field uses for various crops 

have maximum application rates that range from 200 lb 

ai/acre/application up to 430 lb ai/acre/application (e.g., EPA 

registration numbers 5785-4 and 5785-42). Rates as high as 2 lbs 

ai/100 square feet are generally reserved for more specialized 

applications such as hot gas applications and tree planting scenarios 

which are less prevalent. 

Other Uses: Application rates for commodity fumigations can range 

from 1 to 20 lb ai/1000 ft3

, but most perishable goods with established 

food tolerances under 40 CFR have application rates in the range of 1 

to 4 lb ai/1000 ft3 (e.g., grapes). 
18 

Annual Usage in the 

U.S.: 

In 2007, 5,482 metric tons of methyl bromide were applied (4,269 

metric tons from newly-produced material and 1,213 metric tons from 

pre-2005 stocks). This amount does not include quarantine and 

preshipment (QPS) exemption usage. QPS production is tracked by 

the Agency but usage is not. EPA’s Office of Air and Radiation 

(OAR) reports that as of January 1, 2008, there were 6,458 metric tons 

of pre-2005 methyl bromide stocks. Additional information on the 

decline of the methyl bromide inventory can be found at: 

http://www.epa.gov/ozone/mbr/MeBr_FactSheet2008.html. 

C. Regulatory History 

Methyl bromide was introduced as a pesticide in 1932 and first registered in the U.S. in 

1961. Under the Clean Air Act and the Montreal Protocol on Substances that Deplete the Ozone 

Layer, as of January 1, 2005, U.S. production and import of methyl bromide is banned, except 

for uses that qualify for (1) a critical use exemption (CUE), (2) a QPS exemption, or (3) an 

emergency exemption. For more information about the phase out of methyl bromide, see 

http://www.epa.gov/ozone/mbr/. 

III. Fumigant Overview and Agency Documents 

A. General Overview of Soil Fumigants 

Soil fumigants are pesticides that form gasses when applied to soil. Once in the soil, the 

fumigants work by controlling pests that can disrupt plant growth and crop production. Soil 

fumigants play a very important role in agriculture, but they also have the potential to pose risk 

concerns to people involved in application of the chemicals (handlers), workers who re-enter 

fumigated fields (workers), and people who may be near the treated area (bystanders). 

B. Human Health Risks 

The main risk of concern for handlers, workers, and bystanders associated with the soil 

uses of methyl bromide is from acute inhalation exposure as a result of fumigant off-gassing. 

Methyl bromide handlers also are at risk from direct fumigant exposure during applications. The 

term handler refers to persons involved in the application of methyl bromide. For soil 

applications, handlers also include persons involved in perforating and removing of tarps. The 

term worker in this document refers to persons performing non-handler tasks within the 

application block, after the fumigation process has been completed, such as planting. The term 

bystander refers to any person who lives or works in the vicinity of a fumigation site. 

Estimating exposure to fumigants is different from non-fumigant pesticides due to 

fumigants’ volatility, and thus, their increased ability to move off site during and after 

application. For example, pesticide spray drift is the physical movement of pesticide particulate 

or droplets from the target site during the application and soon thereafter. In the case of soil 

fumigants, the pesticide moves as a gas (not as particulate or droplets) and movement off-site can 

occur for an extended period after application. Importantly, fumigants have a well-documented 
19 

history of causing large-scale human exposure incidents up to several thousand feet from treated 

fields. Assessing fumigant exposure takes into account the size of the fumigated field, the 

amount of fumigant applied, and the rate at which the fumigant escapes from the treated field. 

The term “flux rate” or “emission rate” defines the rate at which a fumigant off-gasses 

from a treated field. Many factors influence the rate of emissions from treated fields after the 

application of soil fumigants. Factors such as the application method, soil moisture, soil 

temperature, organic matter levels, water treatments, the use of tarps, biological activity in the 

soil, soil texture, weather conditions, soil compaction, and others influence the amount of 

fumigant that comes off the field and is available to move off-site to areas where bystanders may 

be located. 

Neurotoxicity is a common toxic effect for methyl bromide inhalation exposure, with 

neurotoxic exposure effects seen in all tested species of animals. Both acute (1-day) and 90-day 

inhalation neurotoxicity studies in rats showed evidence of neurotoxic effects characterized by 

decreased activity, tremors, ataxia and paralysis. Neurotoxic effects were also seen in the 

chronic/carcinogenicity inhalation study in mice (ataxia, limb paralysis, degenerative changes in 

the cerebellum), the developmental inhalation study in rabbits (lethargy, right side head tilt, 

ataxia), and the Developmental Neurotoxicity Study [DNT] (decreased motor activity). In 

addition, a subchronic study (5- to 7-week) showed dogs to be the most sensitive species to the 

neurotoxic effects of methyl bromide. 

A non-reversible acute (1 day) inhalation endpoint was selected from a developmental 

rabbit study with a LOAEL based on agenesis of the gall bladder and increased incidence of 

fused sternebrae. Fetal effects are presumed to occur after one exposure. The human equivalent 

concentration used for the risk assessment was 10 ppm for a 24-hour time weighted average 

(TWA) to assess non-occupational bystanders and 30 ppm for an 8-hour TWA to assess 

occupational exposures. An uncertainty factor (UF) of 30 with a 3x for interspecies 

extrapolation and 10x for intraspecies variation was employed in the human health risk 

assessment. Please see the Agency’s April 11, 2007 risk assessment and other human health risk 

documents listed at the end of this section for a more detailed explanation of the toxicity 

endpoints. 

In assessing risks from methyl bromide, the Agency considered multiple lines of 

evidence, using the best available information from monitoring studies, modeling tools, and from 

incident reports. 

• Monitoring: For the human health risk assessments completed for methyl bromide and 

the other soil fumigants within the group, several field-scale monitoring studies were 

considered, as well as monitoring of workers and handlers involved in various tasks. 

These studies quantify methyl bromide concentrations in and around fields at various 

times and distances during and after applications. Many of these data indicate that there 

can be risks of concern associated with methyl bromide use at a broad range of distances 

from treated fields. However, these data are limited in their utility because they provide 

results only for the specific conditions under which the study was conducted. 
20 

• Modeling: Models enable the use of data from monitoring studies to estimate 

concentrations and potential risks under a wide range of conditions and use patterns. 

EPA used the Version 2.1.4 of the Probabilistic Exposure and Risk model for Fumigants 

(also called the PERFUM model), to evaluate potential risks at distances around treated 

fields. PERFUM incorporates actual weather data and flux distribution estimates, and 

then accounts for changes and altering conditions. Analyses based on a variety of model 

outputs were used to compare the potential risks at a range of distances. The PERFUM 

model and users manual are public domain and can be downloaded at 

http://www.exponent.com/perfum/. 

• Bystander, handler, and worker incident reports: Incidents for the soil fumigants 

generally occur at a low frequency relative to the total number of fumigant applications 

performed annually. However, when incidents occur, there are often many people 

involved. Incidents involving handlers and workers tend to occur more often than 

incidents with bystanders. 

Reconstructing incidents to examine the exact factors which led to the incident can be 

difficult, especially when bystanders are involved since all the factors that contributed to 

the incident may not have been documented. Some of the factors that have been linked to 

incidents in the past have included equipment failure, handler accidents, applicator failure 

to adhere to label recommendations and/or requirements, and temperature inversions. 

Incidents have occurred to bystanders close to fields and up to two miles away from the 

fumigated field. 

Based on these lines of evidence, and as described in more detail in the risk assessments, 

EPA has determined that methyl bromide risks to handlers, workers, and bystanders are of 

concern given current labels and use practices. The human health risk assessments indicate that 

inhalation exposures to bystanders who live and work near agricultural fields and greenhouses 

where methyl bromide fumigations occur have the potential to exceed the Agency’s level of 

concern without additional mitigation measures. There are also risks of concern for occupational 

handlers involved in methyl bromide applications and tarp perforation/removal activities, and for 

workers who may re-enter treated area shortly after fumigation or tarp perforation has been 

completed. 

For more information about the specific information in the Agency’s human health risk 

analyses, refer to the documents listed below: 

• EPA-HQ-OPP-2005-0123-0285, Methyl Bromide: Phase 5 Health Effects Division 

(HED) Human Health Risk Assessment for Soil, Greenhouse, and Residential/Structural 

Uses 

• June 2, 2008 addenda to April 10, 2007 Phase 5 Health Effects Division (HED) Human 

Health Risk Assessment For Soil, Greenhouse, and Residential/Structural (DP Barcode: 

D350818) 

• June 9, 2008 memo, Factors Which Impact Soil Fumigant Emissions - Evaluation for 

Use in Soil Fumigant Buffer Zone Credit Factor Approach (DP Barcode: 306857) 

• EPA-HQ-OPP-2005-0123-0317, Review of Fumigants Group Incident Reports 
21 

• EPA-HQ-OPP-2005-0123-0318, Summary Fumigants Group Incident Reports 

• EPA-HQ-OPP-2005-0123-0319, Summary Fumigants Group Incidents 

• Methyl Bromide (PC Code 053201), Chloropicrin (PC Code 081501), Dazomet (PC 

Code 035602), Metam Sodium and Potassium (PC Codes 039003 & 039002), MITC (PC 

Code 068103), DP Barcode 362369, Updated Health Effects Division Recommendations 

for Good Agricultural Practices and Associated Buffer Credits (Date May 14, 2009) 

C. Stratospheric Ozone Depletion 

In addition to methyl bromide’s direct effects previously described in Section B, methyl 

bromide soil fumigant use poses indirect chronic health risks, and is being phased out 

internationally, because it depletes the stratospheric ozone layer. 

Ozone-depleting substances, including methyl bromide and other halogenated gases such 

as chlorofluorocarbons (CFCs), halons, and hydrochlorofluorocarbons (HCFCs), are very stable 

in the lower atmosphere. They eventually drift into the stratosphere, where they undergo a series 

of cyclical reactions that destroy ozone. In the presence of ultraviolet light, halogenated source 

gases react to release chlorine or bromine atoms, which quickly break down ozone molecules 

while producing the free radicals bromine monoxide (BrO) or chlorine monoxide (ClO). These 

chemicals continue to react and eventually regenerate the original bromine or chlorine, which 

begin the cycle again – enabling one chlorine or bromine atom to destroy 100,000 ozone 

molecules before being removed from the stratosphere. 

The 2006 Scientific Assessment of Ozone Depletion, produced by the U.N. Environment 

Programme and the World Meteorological Organization, is the consensus work of hundreds of 

atmospheric scientists, many of them U.S. experts. The Executive Summary of the 2006 

Assessment, released on August 18, 2006, noted that “bromine continues to play a major role in 

stratospheric ozone depletion” and that “methyl bromide abundance decreased by 14% between 

1997 and 2004. This decrease was larger than expected and suggests that when anthropogenic 

emissions of bromine are reduced, its atmospheric abundance decreases more than previously 

thought.” 

Thinning of the ozone layer leads to an increase in ultraviolet (UV) radiation reaching the 

earth’s surface, leading to increased incidence of skin cancer, cataracts, immunosuppression, and 

other ecological and economic impacts. 

The Agency has previously undertaken and provided analyses of methyl bromide’s role 

in stratospheric ozone depletion including estimates of mortalities and incidences of skin cancer. 

These analyses were based in part, on the Atmospheric Health Effects Framework 

(AHEF). For more information about the specific information in the Agency’s assessment of 

stratospheric ozone depletion, refer to the following documents: 

• EPA-HQ-OPP-2005-0123-0165, Methyl Bromide: Science of Ozone Depletion and 

Health Effects Estimates 
22 

• EPA-HQ-OPP-2005-0123-0166, Human Health Benefits Of Stratospheric Ozone 

Protection 

• EPA-HQ-OPP-2005-0123-0167, Regulatory Impact Analysis, Protecting Stratospheric 

Ozone: Process for Exempting Critical Uses from the Phaseout of Methyl Bromide 

• EPA-HQ-OPP-2005-0123-0168, OAP’s Economic Impact Analysis For Methyl Bromide 

Allocation In The United States 

• EPA-HQ-OPP-2005-0123-0169, OAP’s Benefits Analysis 

The AHEF model predicts mortality and incidence for increased emissions of compounds 

that deplete stratospheric ozone, projects impacts of increased emissions on stratospheric ozone, 

models resulting changes in ground-level UV radiation, and uses a dose-response relationship to 

project incremental skin cancer mortality and incidence. 

The AHEF model was peer-reviewed by EPA’s Science Advisory Board (SAB) several 

times for use in various regulatory decisions, most recently in 2003. The final SAB reports for 

the peer reviews are available on the EPA’s internet site4

. All comments of the peer reviewers 

were considered, and the AHEF was modified appropriately. 

The starting point in the AHEF modeling performed by EPA assumed the total amount of 

methyl bromide applied in the U.S. was 23,000,000 lbs (10,433 metric tons). Consistent with the 

intent of the Montreal Protocol, the amount of methyl bromide applied, produced, and stockpiled 

has decreased since 2004 and is expected to continue to decline until supplies are exhausted. 

The Agency modeled 5 scenarios for continued methyl bromide use from 2005-2037, ranging 

from no drawdown (continued use at 23,000,000 lb per year) to full phase-out of all uses by 

2017. For all uses, depending on the use scenario, 125 to 797 deaths and 24,221 to 155,020 

incidences of skin cancer from 2005-2100 were estimated. 

 Skin cancer is the most common form of cancer in the U.S., with more than 1,000,000 

new cases diagnosed annually5

. Melanoma, the most serious form of skin cancer, is also one of 

the fastest growing types of cancer in the U.S.; melanoma cases in this country have more than 

doubled in the past two decades, and the rise is expected to continue6

. In 2007, invasive 

melanoma was expected to strike more than 59,000 Americans and kill more than 8,0007. 

 Nonmelanoma skin cancers are less deadly than melanomas, but left untreated they can 

spread, causing disfigurement and more serious health problems. The most common 

nonmelanoma skin cancer - basal cell carcinoma - grows slowly and rarely spreads to other parts 

of the body but can penetrate to the bone and cause considerable damage. Squamous cell 

carcinomas, by comparison, can develop into large masses and can spread to other parts of the 

body. 

 

4

 EPA Science Advisory Board reports, http://yosemite.epa.gov/sab/sabpeople.nsf/WebCommittees/BOARD

5

 National Cancer Institute, “Common Cancer Types,” at www.cancer/gov/cancertopics/commoncancers 6 Ries, L., Eisner, M.P., Kosary, C.L., et al, eds. SEER Cancer Statistics Review, 1973-1999. Vol 2003. Bethesda 

(MD): National Cancer Institute; 2002. 

7 National Cancer Institute, “Melanomas,” at www.cancer/gov/cancertopics/types/melanoma
23 

Actinic keratoses are skin growths that occur on body areas exposed to the sun, 

particularly the face, hands, forearms, and the “V” of the neck. Although premalignant, actinic 

keratoses are a risk factor for squamous cell carcinoma. Chronic exposure to the sun also causes 

premature aging, which over time can make the skin become thick, wrinkled, and leathery. 

Research has shown that UV radiation increases the risk of certain cataracts - a form of 

eye damage in which a loss of transparency in the lens of the eye clouds vision. Other kinds of 

UV-related eye damage include pterygium (tissue growth that can block vision), skin cancer 

around the eyes, and degeneration of the macula (the part of the retina where visual perception is 

most acute). 

Scientists have found that overexposure to UV radiation may suppress proper functioning 

of the body’s immune system and the skin’s natural defenses. All people, regardless of skin 

color, might be vulnerable to effects including impaired response to immunizations, increased 

sensitivity to sunlight, and reactions to certain medications. 

Because of these impacts, methyl bromide and other ozone-depleting substances are 

being phased out worldwide under the Montreal Protocol on Substances that Deplete the Ozone 

Layer, the international agreement designed to reduce and eliminate the production and 

consumption of stratospheric ozone-depleting substances. The U.S. was one of the original 

signatories to the 1987 Montreal Protocol and the U.S. Senate ratified the treaty in 1988. The 

Clean Air Act Amendments of 1990, which included Title VI on Stratospheric Ozone Protection, 

codified as 42 U.S.C. Chapter 85, Subchapter VI, ensure that the United States could satisfy its 

obligations under the Protocol. 

In the United States methyl bromide is classified as a “Class I” ozone-depleting substance 

due to its high ozone depletion potential (ODP). A substance’s ODP is a measure of its ability to 

destroy stratospheric ozone molecules. The other Class I substances, such as 

chlorofluorocarbons (CFCs), halons, and carbon tetrachloride, were almost completely phased 

out in the 1990s. Methyl bromide is the only remaining Class I substance still commonly 

produced and used in the United States. 

Under the Montreal Protocol, the U.S. and other developed countries were required to 

reduce the quantity of methyl bromide produced and consumed, relative to a 1991 consumption 

baseline, by 25 percent in 1999, 50 percent in 2001, 70 percent in 2003, and 100 percent (full 

phase out) by 2005. 

The Montreal Protocol provides some exemptions from the phase-out. The first is an 

exemption permitting limited production and import of methyl bromide to meet critical uses for 

which technically and economically feasible alternatives are not yet available. The critical use 

exemption is designed to permit the production and import of methyl bromide for uses that do 

not have technically and economically feasible alternatives. In 2004, EPA established the 

framework for the critical use exemption; listed the approved critical uses for 2005; and specified 

the amount of methyl bromide that could be supplied in 2005 from stocks and new production or 

import to meet the needs of approved critical uses. Since then, through the notice-and-comment 

rulemaking process, EPA has authorized critical uses of methyl bromide on an annual basis. 
24 

 In Decision IX/6 (1997), the Parties to the Montreal Protocol agreed that “a use of methyl 

bromide should qualify as ‘critical’ only if the nominating Party determines that: (i) The specific 

use is critical because the lack of availability of methyl bromide for that use would result in a 

significant market disruption; and (ii) there are no technically and economically feasible 

alternatives or substitutes available to the user that are acceptable from the standpoint of 

environment and public health and are suitable to the crops and circumstances of the 

nomination.” These criteria are reflected in EPA’s definition of “critical use” at 40 CFR 82.3. 

 Under the annual critical use process, applicants requesting critical use exemptions 

provide data on the technical and economic feasibility of alternatives, their use of methyl 

bromide, research programs into the use of alternatives to methyl bromide, and efforts to 

minimize methyl bromide use and emissions. EPA reviews this information, as well as other 

data from governmental and academic sources, to establish whether there are technically and 

economically feasible alternatives available for a particular use of methyl bromide and whether 

there would be a significant market disruption if no exemption were available. In addition, EPA 

reviews other parameters of the exemption applications such as dosage and emissions 

minimization techniques and applicants’ research or transition plans. Following this assessment, 

the U.S. Government submits the critical use nomination to the United Nations Environment 

Programme (UNEP) Ozone Secretariat. The Methyl Bromide Technical Options Committee 

(MBTOC) and the Technical and Economic Assessment Panel (TEAP), independent advisory 

bodies to Parties to the Montreal Protocol, review critical use nominations and make 

recommendations to the Parties, which then authorize critical uses and amounts. As required in 

Section 604(d)(6) of the Clean Air Act, for each exemption period, EPA consults with the United 

States Department of Agriculture and other federal agencies, and provides an opportunity for 

public comment on the amounts of methyl bromide that the Agency has determined to be 

necessary for critical uses and the uses that the Agency has determined meet the criteria of the 

critical use exemption. 

A second exemption currently in use under the Montreal Protocol is an exemption for 

methyl bromide that is used for QPS. QPS fumigation is used for rapid treatment of imports and 

exports such as fresh fruits, vegetables, flowers, timber, and grains where necessary to meet 

official quarantine or sanitary requirements in other jurisdictions. An example of a quarantine 

use is the fumigation of commodities such as rice and spices that are subject to infestation by a 

specific and officially-recognized quarantine pest. Quarantine fumigation prevents the 

introduction of specific quarantine pests into a defined geographical area, such as an importing 

country. An example of a preshipment use is application to wheat because of official 

phytosanitary requirements at the shipment destination. 

The Montreal Protocol also provides for a narrow “emergency use” exemption, under 

which a Party may produce or import up to 20 metric tons of methyl bromide to address an 

emergency event. This use, however, is to be subsequently reviewed by the Parties according to 

critical use criteria. EPA’s Office of Atmospheric Programs (OAP) has not promulgated a 

regulation for the implementation of an emergency use exemption. 
25 

D. Environmental Fate and Ecological Risks 

The Agency’s environmental fate and ecological effects risk assessments indicate that 

there are some concerns for non-target organisms that may be exposed to methyl bromide. For 

more information about the specific information in the Agency’s assessment of environmental 

fate and ecological risks, refer to the following documents: 

• EPA-HQ-OPP-2005-0123-0029, Revised Draft Methyl Bromide Environmental Fate and 

Ecological Risk Assessment - Following the Review of 30-Day Error Correction Comments 

• EPA-HQ-OPP-2005-0123-0038, Reregistration Environmental Risk Assessment for Methyl 

Bromide 

• Response to Public Comments on the 7/9/08 Methyl Bromide RED (DP Barcode 304616) 

Since methyl bromide is highly volatile and is a gas at room temperature and standard 

pressure, inhalation of vapor following soil fumigation is the major exposure pathway for nontarget mammals and birds. For aquatic organisms, exposure in surface water could result from 

runoff with soluble methyl bromide from fumigated fields. 

The acute aquatic endangered species Level of Concern (LOC) is exceeded for aquatic 

invertebrates. However, the PRZM model does not account for the reduction in exposure that 

would likely result from using tarps. This amendment to the reregistration eligibility decision 

requires tarps for all methyl bromide applications except for California Orchard Replant. 

1. Hazard 

Methyl bromide is considered moderately toxic to birds (oral LD50 is 73 mg ai/kg) and 

mammals (oral LD50 is 86 mg/kg) from oral exposure. No acute inhalation studies were 

available in registrant studies or in open literature studies for birds, so inhalation toxicity has 

been estimated based on the oral and inhalation data from mammals compared to the oral data 

for birds. For mammals, the LC50 for methyl bromide from the inhalation route is 780 ppm. 

 Methyl bromide is slightly to moderately toxic to fish by acute exposure (LC50 is 3.9 

mg/L), and to aquatic invertebrates (LC50 of 2.6 mg/L). The no observed adverse effect level in 

a chronic fish toxicity study was 0.1 ppm. An unpublished aquatic plant study performed with a 

single species of algae resulted in an acute LC50 of 2.2 ppm8

. 

 

8 Data on the toxic effects of methyl bromide to algae are only available from a single study (Canton et al. 1980), 

which appears to be an internal report and not published in the peer-reviewed literature 
26 

2. Exposure 

a. Terrestrial Exposure 

 The Industrial Source Complex Short Term (ISCST3) model together with historical air 

monitoring data were used to evaluate the range of methyl bromide air concentrations which 

might be found under different conditions of application rate, weather, source size and shape 

(e.g., field size in acres), tarping and distance from treated fields. The PERFUM model, which is 

described in the Human Health Risk section, was not used to estimate exposures since terrestrial 

acute risks of concern were not identified based on ISCST3 modeling (see Terrestrial Risks

Section 3.a. for further details). 

b. Aquatic Exposure 

The aquatic exposure assessment for methyl bromide relied on Tier II aquatic models. 

The Pesticide Root Zone Model (PRZM version 3.12) simulates fate and transport on the 

agricultural field, while the water body is simulated with Exposure Analysis Modeling System 

(EXAMS version 2.98). Simulations are run for multiple (usually 30) years and the reported 

EECs represent the values that are expected once every ten years based on the thirty years of 

daily values generated during the simulation. 

PRZM/EXAMS simulates a 10 hectare (ha) field immediately adjacent to a 1 ha pond, 2 

meters deep with no outlet. The location of the field is specific to the crop being simulated using 

site specific information on the soils, weather, cropping, and management factors associated with 

the scenario. The crop/location scenario in a specific state is intended to represent a high-end 

vulnerable site on which the crop is normally grown. Based on historical rainfall patterns, the 

pond receives multiple runoff events during the years simulated. PRZM has limited capabilities 

in capturing the amount of a volatile chemical in air, water and sediment. The estimated 

concentrations of chemicals like methyl bromide in surface water bodies may be upper bound. 

 To simulate field application of methyl bromide, multiple scenarios were selected, 

including Florida strawberry, California tomato and California grape scenarios that were 

assessed with an application rate of 400 lbs ai/A. A North Carolina tobacco scenario was also 

assessed at the maximum rate of 855 lbs ai/A. The scenarios with the highest exposure of methyl 

bromide were the California tomato and Florida strawberry scenarios, even though the maximum 

application rate for the North Carolina tobacco scenario was more than twice as high. 

There is an uncertainty in estimating methyl bromide exposure in water bodies due to 

post-application tarping of the treated area. If tarping is used to minimize the volatilization of 

methyl bromide, the loading of the chemical through runoff will be limited until the tarp is sliced 

or removed from the field. The present version of PRZM model has limited capabilities in 

simulating the transport of a volatile chemical escaping the soil after removal of a tarp, and the 

resulting surface-water concentrations should be considered upper-bound values. 
27 

3. Risk 

a. Terrestrial Risk 

 The most likely route of exposure to methyl bromide for terrestrial animals is through 

inhalation of methyl bromide volatilizing from a treated field. The concentration of methyl 

bromide in air used in the assessment came from two sources. The first represented the highest 

concentration measured in field monitoring studies. This value of 27 ppm was detected in a 

1987 study in which air concentrations 25 feet from a treated mill were measured 5 to 90 minutes 

after fumigation. Available historical monitoring after soil fumigations resulted in 

concentrations ranging as high as 3.35 ppm. The second source of concentrations used in the 

terrestrial risk assessment was based on air dispersion modeling, which estimated a concentration 

of about 9.1 ppm adjacent to a 40-acre field treated with 400 lb ai/A of methyl bromide. 

 These concentrations were compared to acute inhalation toxicity values to evaluate 

potential risk. Mammalian acute inhalation toxicity data were available, but avian acute 

inhalation toxicity endpoints had to be estimated using the mammalian inhalation and oral 

toxicity data, avian oral toxicity data, and a factor used to account for inhalation physiology 

differences between birds and mammals. The Agency has not set a LOC for inhalation exposure, 

but the resulting RQs for both estimated air concentrations were below the standard acute LOCs 

of 0.1 and 0.5 used for dietary risk assessments. The Agency will require that avian inhalation 

acute toxicity studies be submitted to confirm the results of this risk assessment performed with 

estimated toxicity endpoints. 

The volatility of methyl bromide causes it to disperse quickly from a treated field when it 

is not constrained to remain in the soil. However, it is possible that animals could potentially be 

exposed repeatedly if their range were to extend over several adjacent fields which were treated 

over multiple days. Available toxicity data from the dog 5 to 7 week inhalation test resulted in a 

no observed effect level of 5.3 ppm, which was higher than the peak short-term concentration 

from soil treatments observed in historical data, and higher than a range of ambient air 

concentrations found in historical monitoring data. 

b. Aquatic Risk 

 The only aquatic risks that were above the Agency’s LOC are the acute risk to 

endangered or threatened aquatic invertebrates species. The acute aquatic listed species LOC 

(0.05) is exceeded for aquatic invertebrates in two of the four modeled scenarios (CA tomatoes, 

0.06 and FL strawberries, 0.07), but not with CA grapes or NC tobacco. However, the PRZM 

model does not account for the reduction in exposure that would likely result from tarping the 

field immediately after methyl bromide application. Given the low levels of exceedence (RQs of 

0.06 to 0.07), the potential effect of tarping will likely lower the RQ values below the LOC. 

Bromide ion is one degradation product of methyl bromide that is formed in soil. The 

risk assessment evaluated the potential for risk to aquatic organisms from bromide ion generated 

by methyl bromide degradation using the Tier 1 surface-water exposure model GENEEC. This 

assessment calculated the potential concentration from runoff that could occur from the highest 
28 

application rate of 575 lb ai/A, assuming that 20% of applied methyl bromide is lost to 

volatilization, and that the remainder of the methyl bromide degrades to bromide ion on site. 

This conservative screening assessment resulted in an EEC of 5.4 ppm, which is below the most 

sensitive available toxicity endpoint of 7.8 ppm, for chronic risk to freshwater invertebrates. The 

next lowest bromide ion toxicity endpoint for aquatic animals was an order-of-magnitude less 

sensitive. 

E. Benefits 

Soil fumigation can provide benefits to both food consumers and growers. For 

consumers it means more fresh fruits and vegetables can be cheaply produced year-round 

because severe pest problems can be efficiently controlled. Growers benefit because crops 

grown in fumigated soil produce fewer blemished products, which translates into an increase in 

marketable yields. Fumigation can also provide benefits to growers by increasing crop 

management flexibility. This includes shorter crop rotational intervals (i.e., less time when fields 

are left fallow), improved ability to meet quarantine requirements (which are imposed when 

states or other jurisdictions require a pest-free harvested product), and consistent efficacy against 

critical pests. The magnitude of benefits depends on pest pressure, which varies over space and 

time, and the availability and costs associated with the use of alternatives. 

There are a number of benefits assessments that have been completed by the Agency to 

estimate the value of these chemicals to various industries. Below is a list of the specific benefits 

assessments that include methyl bromide. 

• EPA-HQ-OPP-2005-0123-0321, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Metam-Sodium, and Methyl Bromide in Eggplant Production 

• EPA-HQ-OPP-2005-0123-0322, Assessment of the Benefits Soil Fumigants (Methyl 

Bromide, Chloropicrin, Metam-Sodium, Dazomet) Used by Forest Tree Seedling 

Nurseries 

• EPA-HQ-OPP-2005-0123-0323, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin, Dazomet, Metam Potassium and Metam Sodium for Use 

in Raspberry Nurseries, Fruit and Nut Deciduous Tree Nurseries, and Rose Bush 

Nurseries in California 

• EPA-HQ-OPP-2005-0123-0324, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin and Metam-sodium In Onion Production 

• EPA-HQ-OPP-2005-0123-0325, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin and Metam-sodium In Grape Production 

• EPA-HQ-OPP-2005-0123-0326, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin and Metam-sodium In Tree Nut Production 

• EPA-HQ-OPP-2005-0123-0327, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, and Methyl Bromide In Pome Fruit Production 

• EPA-HQ-OPP-2005-0123-0328, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin, and Metam Sodium In Stone Fruit Production 

• EPA-HQ-OPP-2005-0123-0329, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam-Sodium in Bell Pepper Production 
29 

• EPA-HQ-OPP-2005-0123-0330, Assessment of the Benefits of Soil Fumigation with 

Metam-sodium in Potato Production 

• EPA-HQ-OPP-2005-0123-0331, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam-sodium In Strawberry Production 

• EPA-HQ-OPP-2005-0123-0332, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, Metam-sodium, and Dazomet In Strawberry Nursery 

Runner Production 

• EPA-HQ-OPP-2005-0123-0333, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide and Metam-sodium In Sweet Potato Production 

• EPA-HQ-OPP-2005-0123-0334, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin In Tobacco Production 

• EPA-HQ-OPP-2005-0123-0335, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam-sodium in Tomato Production 

• EPA-HQ-OPP-2005-0123-0336, Assessment of the Benefits of Soil Fumigation with 

Metam Sodium in Carrot Production 

• EPA-HQ-OPP-2005-0123-0337, Assessment of the Benefits of Soil Fumigation with 

Metam Sodium in Peanut Production 

• EPA-HQ-OPP-2005-0123-0338, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, Metam Sodium and Dazomet in Ornamental Production 

• EPA-HQ-OPP-2005-0123-0339, Summary of the Benefits of Soil Fumigation with 

Methyl Bromide in Crop Production 

• EPA-HQ-OPP-2005-0123-0340, BEAD’s Planned Impact Assessments on Agricultural 

Sites with Significant Use of Soil Fumigants 

F. Impacts of RED mitigation 

Requirements in the July 2008 RED 

The July 2008 RED acknowledged that even with the use of credits, there could be 

significant economic impacts to some growers who may not be able to accommodate large 

buffers based on their current application practices. However, the Agency believed that the 

options provided in the scalable buffer approach in the fumigant REDs would allow growers the 

flexibility to modify their practices to achieve smaller buffers; for example, by treating smaller 

application blocks, switching to a lower emission application method, or by switching to an 

alternative fumigant that would require smaller buffers. In addition, EPA noted that pest control 

efficacy may be improved with high barrier tarps which may enable growers to use the buffer 

zone credits and utilize lower application rates resulting in further reductions of the buffer zone 

distances. Therefore, the Agency concluded that growers would be able to alter their fumigation 

applications, given the flexibility designed into the system, in a manner that would enable 

growers to minimize the impact on production. The Agency noted, however, that the buffers 

would significantly impact some growers by the use of more expensive high barrier film, delays 

in planting due to longer fumigation operations, additional planning, and more trips to the field 

for planting and other operations if fumigating in smaller blocks resulted in staggered operations. 

It was determined that some of these costs could be substantial in some production scenarios. 
30 

Comments on the July 2008 RED 

 The July 2008 RED requested commenters to submit a description of fumigation 

practices and provide maps of their property illustrating locations of fields, offices, residences, 

roads, and property lines so that the Agency could better understand the impacts of the mitigation 

plan. In response, various stakeholders, including several forest seedling nursery operations, 

submitted detailed information. From an analysis of the information submitted, including an 

analysis of a nursery and options they would have for compliance, the Agency concludes that it 

had overestimated the ease with which many growers and fumigators would be able to comply 

with the buffer requirements as presented in the July 2008 RED, and that potential impacts 

would be much greater than previously anticipated for some types of production. The analysis 

indicates that the buffer system identified in the July 2008 RED can be less flexible than 

expected for certain scenarios and the associated field topography, field infrastructure, and need 

for a consistent orientation in the application of a fumigant, which constrain how a field may be 

divided. 

From the Agency’s analysis, the primary driver of the impacts is the size of the buffer 

zones, which will require many growers to divide their fields into smaller fumigation blocks to 

achieve smaller buffer zone distances. Two other contributing factors are the prohibition on 

buffers overlapping in space and time and the duration of the buffer zone. Together, these 

requirements could result in the loss of part of a grower’s field that can be effectively fumigated. 

Further, there may be substantial delays in completing fumigations and multiple trips to a field 

with fumigation equipment may often be necessary. Not only could there be delays in 

production activities in these instances, but it may also be difficult to maintain proper soil 

moisture over the period that multiple blocks would be fumigated. Soil moisture has been 

identified as a critical element in controlling emissions. Some growers will face numerous 

scheduling conflicts if they rely on commercial applicators, and the Agency estimates that 

growers would be more likely to conduct their own fumigations. In addition, repeated trips to 

the field to fumigate small blocks will increase costs, a further incentive for growers to conduct 

their own fumigations. 

The Agency does agree that compliance with buffer zones requirements as outlined in the 

July 2008 RED would be a significant challenge for applicators and growers. However, field 

flux studies, monitoring data, modeling analyses, and information from incidents involving 

fumigants continue to support a conclusion that methyl bromide off-gasses and moves away 

from treated fields at concentrations that have the potential to cause adverse effects. Therefore, 

the Agency still believes that buffer zones that exclude bystanders are a critical aspect of 

mitigating risks from the use of methyl bromide. 

In addition to these impacts, if emergency preparedness and response requirements were 

triggered due to proximity of neighbors, for example, the requirement in the July 2008 RED to 

monitor the buffer zone for its 48-hour duration was estimated to impose the highest direct costs. 

The Agency estimates that the cost of sampling tubes alone could range from $1,000 to over 

$3,000 for a field or enterprise, not including the cost of labor. These costs would fall 

disproportionately on growers with small acreage. As an alternative, growers could notify their 

neighbors of their intent to fumigate. However, the Agency understands and appreciates the 
31 

many comments indicating that notification may not be an attractive option due to the potential 

for neighbors to attempt to impede or block fumigant applications. 

Finally, the Agency concludes that the development and implementation of workable 

fumigation strategies, considering buffer and other requirements, will require substantial new 

information and management skills on the part of growers and applicators. While the Agency’s 

risk management approach provides flexibility to the grower, providing a reasonable period of 

time for growers to adapt would reduce impacts. 

Based on this new information and EPA’s analyses, the Agency has identified 

modifications to the mitigation which will maintain the important protections necessary for the 

health and safety of workers and bystanders, but will increase the ability of fumigant users to 

comply by reducing impacts associated with the mitigation. This includes allowing buffer zone 

overlap and changes in monitoring requirements. In addition, due to new data that have been 

submitted to the Agency, buffer zones distances for some scenarios have been refined for certain 

chemicals and additional buffer zone credits have been provided. The Agency also anticipates 

receiving additional field flux data for methyl bromide that may allow refinement of these buffer 

zone distances in the future. Although many aspects of the RED mitigation will appear on labels 

in 2010, the Agency will not require buffers until the 2011 growing season.

IV. Risk Management and Reregistration Decision 

A. Determination of Reregistration Eligibility 

 Section 4(g)(2)(A) of the FIFRA calls for the Agency to determine, after submission of 

relevant data concerning an active ingredient, whether pesticides containing the active ingredient 

are eligible for reregistration. The Agency has previously identified and required the submission 

of the generic (i.e., active ingredient specific) data required to support reregistration of products 

containing methyl bromide. 

 The Agency has completed its assessment of the dietary (water), residential, 

occupational, and ecological risks associated with the use of pesticides containing the active 

ingredient methyl bromide. Dietary (food) risks were assessed in the 2006 Methyl Bromide 

TRED/RED and associated tolerances were reassessed1

. The TRED/RED, which covered 

commodity fumigation, included similar mitigation measures required in this document (e.g., 

fumigation management plans, buffer zones, respiratory protection, air monitoring). The uses 

covered by this document (i.e., those not included in the TRED/RED) are not considered 

food/feed uses and do not have associated tolerances. In addition to the risk assessments, the 

Agency completed benefit assessments on crops with significant methyl bromide usage9. 

 

9

 EPA-HQ-OPP-2005-0123-0340, BEAD’s Planned Impact Assessments on Agricultural Site with Significant Use 

of Soil Fumigants 
32 

In Phase 5, the Agency published a risk mitigation options paper10. This document 

detailed potential mitigation options and sought public comment on these options. The following 

is a list of potential mitigation discussed in the Agency’s paper: 

• Buffer zones; 

• Sealing methods; 

• Timing of applications; 

• Application block size limitations; 

• Respiratory protection; 

• Tarp cutting/removal procedures; 

• Entry-restricted period; 

• Application method/practice restrictions; 

• FMPs; 

• FMP certification; 

• Responsible parties; 

• Record keeping/reporting/tracking; 

• Restricted Use Pesticide Classification (this option does not apply to methyl 

bromide, since it is already a RUP). 

• Notification and posting; 

• Good agricultural practices; 

• Fumigant manuals; and 

• Stewardship programs. 

Based on a review of the methyl bromide data base and public comments on the 

Agency’s assessments for the active ingredient methyl bromide, the Agency had sufficient 

information on the human health, ecological effects, stratospheric ozone depletion, and benefits 

of methyl bromide to make decisions as part of the reregistration process under FIFRA. For the 

purposes of determining reregistration eligibility, methyl bromide uses were placed into two 

groups: 

• Group 1 included only methyl bromide uses, users, and locations that qualify for exemptions 

under the Montreal Protocol (see http://www.epa.gov/ozone/mbr/cueuses.html for further 

details on methyl bromide uses that qualify for CUEs). 

Given the high acute risks associated with methyl bromide use and methyl bromide’s 

status as an ozone depleting substance which contributes to the destruction of stratospheric ozone 

and incidence of skin cancer, EPA determined in the July 2008 RED that only uses with very 

high benefits and no economically or technologically feasible alternatives are eligible for 

reregistration. The robust processes set forth in the Montreal Protocol and EPA’s implementing 

regulations for determining the critical uses of methyl bromide, and for identifying uses with 

economically and technologically feasible alternatives, provide a clear picture of uses for which 

methyl bromide has very high benefits (for further details see “The 2010 Critical Use Exemption 

Nominations from the Phaseout of Methyl Bromide” at 

 

10 EPA-HQ-OPP-2005-0123-0282, Risk Mitigation Options to Address Bystander and Occupational Exposures from 

Soil Fumigant Applications 
33 

http://www.epa.gov/ozone/mbr/cueinfo.html). Based upon those analyses, EPA determined that 

the uses in Group 1, those that qualify for exemptions under the Montreal Protocol, have benefits 

which justify reregistration eligibility. 

Because of their high benefits, the Agency determined in the July 2008 RED that Group 

1 uses of methyl bromide will not pose unreasonable risks or adverse effects to humans or the 

environment provided that the risk mitigation measures and label changes outlined in the RED 

were implemented. Therefore, products containing methyl bromide for these uses were eligible 

for reregistration as long as they have CUE or QPS status under the Montreal Protocol. Required 

label changes are described in Section V of this document. The Agency determined in the July 

2008 RED that any Group 1 uses that no longer qualify for CUE and QPS status should be 

canceled. The list of critical uses of methyl bromide, as well as the limiting critical conditions 

for its use, is found in 40 CFR Part 82, Subpart A, Appendix L. 

• Group 2 uses are uses that do not qualify for exemptions under the Montreal Protocol. The 

import or production of new methyl bromide for these uses is prohibited. Currently, only 

methyl bromide produced before 2005 and stockpiled may be used for Group 2 use-sites. 

Based on a consideration of the risks and benefits, EPA determined in the July 2008 RED 

that Group 2 uses were not eligible for reregistration. Substantial information available to EPA 

as a result of (1) the exemption processes under the Montreal Protocol, (2) OPP’s benefits 

assessments for the soil fumigants, and (3) public comments provided during OPP’s Six-Phase 

Public Participation Process for methyl bromide’s reregistration review, indicated that these 

uses have economically and technologically feasible alternatives. 

The Agency determined that use sites in Group 2 for which no data is available to 

demonstrate high benefits or a lack of effective alternatives should be canceled following 

completion of the comment period on the July 2008 RED and EPA’s consideration of those 

comments to determine whether sufficient benefits data on any additional Group 2 uses warrant 

reconsideration of any part of this decision. The RED stated that if stakeholders are able to 

provide new information during the comment period on this decision indicating that certain uses 

have high benefits and/or do not have feasible alternatives, EPA will consider whether to allow 

continued use for a finite period of time to allow for the orderly transition among users to 

alternate pest control products and/or methods. 

Following publication of the methyl bromide RED in July 2008, the Agency announced a 

public comment period for the RED and requested comments on the importance of the Group 2 

uses. The Agency received comments on the Group 2 uses during the post-RED comment 

period. Following review of the comments, the Agency has determined that the benefits of the 

Group 2 uses are not high enough to allow them to be eligible for reregistration. However, the 

Agency has determined that certain uses do provide benefits for growers and EPA will allow 

these uses to continue for a finite period of time. These uses include; caneberries, fresh market 

tomatoes and peppers in California, Vidalia onions in Georgia, and ginger in Hawaii. The 

Agency has determined that tobacco growers, golf courses, or turf producers would not incur 

substantial impacts if they could not use methyl bromide. Alternative treatments to control pests 

appear to be available and no information was submitted demonstrating that the alternatives are 
34 

prohibitively expensive. Therefore, the Agency has determined that these uses should end 

immediately. The Agency will work with the registrants to cancel the Group 2 uses under 

Section 6(f) of FIFRA. If registrants do not request voluntary cancellation, EPA will take 

additional regulatory action. For more details on the benefits assessment for these uses, please 

refer to; BEAD Response to Stakeholder Comments on Non-CUE Uses of Methyl Bromide and 

Methyl Bromide Rate Reductions (DP# 363545) in the methyl bromide docket. 

EPA believes that eliminating Group 2 uses will reduce the total amount of methyl 

bromide applied in the U.S., and therefore reduce the incidence of skin cancer resulting from 

stratospheric ozone depletion. While the Agency acknowledges that limiting use to only Group 

1 uses may slow the drawdown of the pre-2005 stockpile, it is reasonable to expect that new 

production for exempted uses will also continue to decline as there will be more pre-2005 

stockpile material available for critical uses. 

 Based on its evaluation of methyl bromide, the Agency has determined that methyl 

bromide products, unless labeled and used as specified in this document, would present risks 

inconsistent with FIFRA. Accordingly, should a registrant fail to implement any of the risk 

mitigation measures identified in this document, the Agency may take regulatory action to 

address the risk concerns from the use of methyl bromide. If all changes outlined in this 

document are incorporated into the product labels, then current risks for methyl bromide will be 

adequately mitigated for the purposes of this determination under FIFRA. 

A substantial amount of research is currently underway or is expected to begin in the near 

term to (1) address current data gaps, and (2) refine understanding of factors that affect fumigant 

emissions. Additionally, a number of new methods and technologies for fumigation are 

emerging. EPA plans to move the soil fumigants forward in Registration Review, from 2017 to 

2013, which will allow EPA to consider new data and information relatively soon, determine 

whether the mitigation included in this decision is effectively addressing the risks as EPA 

believes it will, and to include other soil fumigants which are not part of the current fumigant 

group review. 

USDA is currently conducting eradication programs to eliminate the potato cyst nematode 

in Idaho and the golden nematode in New York, federally recognized invasive, non-indigenous 

pests. These nematode species pose serious threats to the potato industries in these regions and 

can cause serious economic damage. Currently, limited acreage is infested with these 

nematodes. However, there is great concern that these pests could move into other potato 

growing areas. The USDA program goals include limiting the spread of the nematodes 

eradicating current infestations. These programs currently rely on use of high rates of methyl 

bromide. USDA supervises the fumigation of infested fields by professional commercial 

applicators. In their comments on the July 2008 REDs, USDA expressed concern that the 

mitigation measures as outlined in the 2008 methyl bromide RED could severely impact the 

effectiveness of these programs. USDA has implemented extensive outreach programs to 

increase community awareness in these areas, and has conducted air monitoring to help ensure 

early warning if methyl bromide concentrations exceed current action levels. EPA believes these 

steps greatly enhance the safety of methyl bromide use under these programs. While EPA 

believes that several of the amendments to the methyl bromide RED will reduce impacts on 
35 

benefits that these programs provide, EPA will continue to work with USDA on these specific 

uses to explore alternative methods to achieve safety goals while ensuring the benefits of these 

programs continue. Additionally, the studies the MBIP has committed to conduct, described 

later in this document, may allow for refinement of buffer distances which could further reduce 

the impacts. 

The Registration Review process for methyl bromide and the other soil fumigants will also 

include a comprehensive endangered species assessment. Once that endangered species 

assessment is completed, further changes to methyl bromide labels may be necessary. 

B. Public Comments and Responses 

The Phase 3 public comment period on the preliminary risk assessments and related 

documents lasted from July 13 through October 12, 2005. EPA-HQ-OPP-2005-0123-0284 

contains the Agency responses to Phase 3 public comments related to methyl bromide soil uses. 

After the Phase 3 comment period, the Agency revised the human health risk assessment, 

completed benefit assessments, and developed risk mitigation options. These documents were 

put out for public comment on May 2, 2007 and the comment period ended on November 3, 

2007. Comments on issues which were significant to many stakeholders and directly influenced 

EPA’s decisions are highlighted in this decision document, as well as EPA’s responses to those 

comments. The following documents include the EPA’s responses to comments. These 

documents are located in the methyl bromide docket, EPA-HQ-OPP-2005-00123.

• HED Component of Response To Comments Document On Methyl Bromide Phase 5 

Fumigant Risk Assessment (DP Barcode 353907) 

• Review of Stakeholder Submitted Impact Assessments of Proposed Fumigant Buffers, 

Comments on Initial Buffer Zone Proposal, and Case Studies of the Impact of a Flexible 

Buffer System for Managing By-Stander Risks of Fumigants (DP Barcode 353940) 

• Response to Phase 5 BEAD Related Public Comments Received on the Reregistration of 

Chloropicrin, Dazomet, Metam Potassium, Metam Sodium, and Methyl Bromide. June 25, 

2008. (DP Barcode 353940) 

• SRRD’s Response to Phase 5 Public Comments for the Soil Fumigants (July 2008) 

The Agency also opened a 60-day public comment period following the publication of 

the methyl bromide RED on July 16, 2008. The Agency received requests to extend the 

comment period, so in response to these requests, on August 29, 2008, EPA published a notice in 

the Federal Register extending the comment period for an additional 45 days. The comment 

period closed on October 30, 2008. The Agency has reviewed these public comments as well as 

new scientific data and other information provided and determined that all measures established 

in the July 2008 RED to reduce risks to bystanders and workers will still be required. The 

Agency has determined that certain modifications in how and when some measures will be 

implemented are appropriate. The following documents include EPA’s responses to comments 

on the methyl bromide RED which may be found in the methyl bromide docket: 
36 

• Response to BEAD Related Public Comments Received on the Reregistration Eligibility 

Decision for Chloropicrin, Dazomet, Metam Potassium, Metam Sodium, and Methyl 

Bromide (DP# 363545). 

• BEAD Response to Stakeholder Comments on Non-CUE Uses of Methyl Bromide and 

Methyl Bromide Rate Reductions (DP# 363545). 

• Response to Public Comments on the 7/9/08 Completed Methyl Bromide RED (DP Barcode 

304616). 

• Methyl Bromide, 1,3-Dichloropropene, Chloropicrin, Dazomet, Metam Sodium/Potassium, 

MITC: Health Effects Division (HED) Component of Agency Response To Comments On 

2008 Reregistration Eligibility Documents (Date May 14, 2009). 

• Analysis of Soil Fumigant Risk Management Requirements using Geographic Information 

Systems: Case Studies based on a Forest Seedling Nursery (DP Barcode 363546) 

• SRRD’s Response to Post-RED Comments for the Soil Fumigants (May 27, 2009). 

C. Regulatory Position 

1. Regulatory Rationale 

 The Agency has determined that Group 1 methyl bromide uses described above are 

eligible for reregistration provided the risk mitigation measures outlined in this document are 

adopted and label amendments are made to reflect these measures. This decision considers the 

risk assessments conducted by the Agency and the significance of methyl bromide use. 

As detailed in Section III, there are risks of concern to humans and the environment 

resulting from methyl bromide use. Understanding these risks and also the benefits of methyl 

bromide (also outlined in Section III), the Agency’s goal for this decision is to be protective, 

especially of severe and irreversible effects, encourage best practices, and to reduce the potential 

impacts on benefits. To reach this goal, EPA considered a range of factors including: 

• characteristics of bystander and other populations exposed to methyl bromide; 

• hazard characteristics of methyl bromide (the methyl bromide endpoint is based on a 

severe and irreversible effect); 

• hazard characteristics of chloropicrin (the chloropicrin endpoint is based on a minor and 

reversible symptom, eye irritation) since all products are formulated with at least 2% 

chloropicrin; 

• methyl bromide’s ozone depletion potential; 

• the phasing out of methyl bromide under the Montreal Protocol, 

• available information on levels of exposure, feasibility, cost, and effectiveness of various 

risk mitigation options; 

• bystander, handler and worker incident reports; 

• potential impacts of mitigation on growers’ ability to produce crops; 

• uncertainties and assumptions underlying the risk and benefit assessments; and 

• public comments. 
37 

Considering these factors, EPA determined that a suite of complimentary measures 

designed to reduce risks, along with a flexible approach allowing for some site-specific 

decisions, would best meet the overall objective of reducing risk and minimizing impacts on 

users. 

 The following is a summary of the rationale for managing risks associated with the use of 

methyl bromide. Where labeling revisions are warranted, specific language is set forth in the 

summary table in Section V of this document. 

a. Generic Risk Management 

Mitigation measures including restricting use sites, reducing maximum applications rates, 

limiting formulations with high percentages of methyl bromide to specified crops/use sites, and 

only allowing untarped application with California orchard replant are described below. These 

mitigation measures will reduce risks for handlers, bystanders, and workers (i.e., human health) 

as well as ecological and stratospheric ozone risks. 

In addition, GAPs, FMPs, and a stewardship/training program ensure consistent 

achievement of sound fumigation applications which are the foundation to minimizing the 

potential for adverse effects to bystanders, handlers, and worker risks and are described below in 

the Other Mitigation section.

1) Use Sites 

 Any methyl bromide uses that do not currently qualify for exemptions under the Montreal 

Protocol (i.e., critical use, quarantine and pre-shipment, or other exempted uses) are not eligible 

for reregistration. The following describes the rationale for this decision: 

• This preserves uses with high benefits and no alternatives, and eliminates uses with lower 

benefits and/or alternatives given the risks associated with methyl bromide use; 

• reconciles inconsistency between phase-out of methyl bromide production and EPA 

registered uses; 

• does not inhibit methyl bromide use that growers and the international community have 

determined to be critical and that are permitted under the Montreal Protocol; 

• restricts the use of stockpiled methyl bromide to uses with high benefits, critical uses, and 

other exempted uses; and 

• contributes along with other mitigation to the reduction of methyl bromide use and thus 

the reduction of stratospheric ozone depletion and associated skin cancers (see 

stratospheric ozone depletion risk management section of Section IV for further details). 

2) Formulations 

 The Agency’s risk assessment for methyl bromide indicates that risks for the 98:2 

(methyl bromide:chloropicrin) formulations are higher than for other formulations. When 98:2 

formulations are used, the amount of methyl bromide applied is generally higher compared to 

amount applied for other formulations which results in higher human health, ecological, and 

stratospheric ozone risks. Additionally, EPA is concerned that 2% chloropicrin is not adequate 
38 

to be an effective warning agent11. Therefore, the Agency has decided to only reregister 98:2 

formulations for uses that have been determined to be essential, which include: 

• Orchard replant 

• Ornamentals (hot gas method only) 

• Forest seedlings 

• Quarantine uses 

3) Application Methods 

The Agency is requiring that in all cases, except very limited circumstances, that methyl 

bromide applications be tarped. The human health risk assessment indicates that untarped shank 

applications for typical rates and application blocks result in bystander risks that exceed the 

Agency’s LOC at significant distances from the field. These methods of application are rarely 

used in the U.S., and when they are used it is reported only for California orchard replant. 

Therefore, the Agency is allowing only deep (18 inches or greater) untarped shank applications 

for California orchard replant uses that qualify for a CUE or QPS exemption and tree-hole 

applications with deep (18 inches or greater) injection auger probes. EPA is requiring tarps for 

all other methyl bromide applications that are shank injected or applied with the hot-gas method. 

4) Maximum Application Rates 

The July 2008 methyl bromide RED required a reduction in maximum rates for certain 

uses. These reductions were based on information from critical use nominations (CUNs) and 

CUEs and acknowledgements from MBIP and other stakeholders that current methyl bromide 

use rates are substantially less than the current maximum rates on registered labels. Maximum 

rates for QPS and emergency exemptions uses are not affected by this decision but must be 

identified on end use labels. 

During the post-RED comment period, the Agency received comments from MBIP on 

the maximum application rates proposed in the RED. The Agency evaluated the comments and, 

in general, concludes that the rates proposed in the RED are in keeping with rates currently in 

use and should not pose significant problems to most growers. However, the rates specified in 

the RED are often near the average use rates and some growers may benefit from higher rates. 

The Agency also finds that vegetable producers may benefit if maximum rates are standardized 

at 200 lb methyl bromide/acre across vegetable crops as most producers plant a mix of crops. 

Most significantly, according to information recently obtained, nurseries (strawberry, orchard 

and forest seedlings) and some ornamental production facilities in California may occasionally 

be required to use a rate of almost 400 lb methyl bromide/acre in order to obtain pest-free 

certification. 

Based on the Agency’s review of the comments submitted by MBIP, EPA has 

determined that maximum rates for certain uses should be higher than what was described in the 

 

11 June 2, 2008 addenda to April 10, 2007 Phase 5 Health Effects Division (HED) Human Health Risk Assessment 

For Soil, Greenhouse, and Residential/Structural (DP Barcode: D350818) 
39 

July 2008 RED. These rates are still significantly lower than current labeled maximum rates and 

the Agency believes that these reductions in application rates will result in less methyl bromide 

applied and will help to reduce methyl bromide’s role in the depletion of stratospheric ozone. 

The mitigation measures described in this document will address acute risks resulting from these 

rates and provide incentives to use the lowest efficacious rate. Therefore, the Agency believes 

that a majority of applications will use rates that are lower than the maximum rates. EPA’s 

decision regarding maximum use rates is presented in Table 3. 

Table 3. Maximum Application Rates for Pre-plant Soil Methyl Bromide Uses 

Maximum Broadcast Equivalent Rates (lb a.i./acre) 

Approved Critical Uses Current Label 2008 RED RED Amendment 

Cucurbits 435 200 200 

Eggplant 400 170 200 

Pepper, Bell 480 170 200 

Tomato, Fresh Market 870 160 200 

Sweet Potato Slips 870 200 200 

Strawberry Fruit 870 200 235 

Strawberry Nursery 870 260 400 

Orchard Nursery 435 200 400 

Forest Seedling Nursery 870 260 400 

Orchard Replant (walnut, 

almond, stone fruit) 870 200 250 

Orchard Replant (grape) 870 250 250 

Ornamentals 870 360 400 

b. Human Health Risk Management 

For details on the methyl bromide human health risk assessment, please refer to the 

Human Health Risk Assessments and addenda for methyl bromide described in Section III of this 

document. These documents are also available in the public docket EPA-HQ-OPP-2005-0123, 

located on-line in the Federal Docket Management System (FDMS) at 

http://www.regulations.gov. 

The human health risk assessments indicate that inhalation exposures to bystanders who 

live and work near agricultural fields and greenhouses where methyl bromide fumigations occur 

and to handlers involved in the application of methyl bromide have the potential to exceed the 

Agency’s level of concern without additional mitigation measures. 

 To reduce the potential for exposure to bystanders, handlers, and workers and to address 

subsequent risks of concern, EPA is requiring a number of mitigation measures which include: 

• Removing of uses with low benefits and/or alternatives; 

• Reducing maximum application rates; 

• Limiting use of 98:2 formulations to essential crops; 

• Buffer zones; 

• Respiratory protection and air monitoring for handlers; 

• Restrictions on the timing of perforating and removing tarps; 
40 

• Posting; 

• Good agricultural practices; 

• Fumigant management plans; 

• Emergency preparedness and response plans; and 

• Notice to state lead agencies. 

The Agency also believes that registrant developed and implemented training and 

community outreach and education programs, will help reduce risk. Additionally, EPA will 

continue to work with registrants to identify additional measures that could be implemented as 

part of product stewardship. These additional measures should include efforts to assist users’ 

transition to the new label requirements. 

 Some of the required mitigation measures only address one group of potentially exposed 

individuals (i.e., bystanders, handlers, or workers), while other measures will help reduce risk to 

more than one group. All mitigation measures are designed to work together to reduce 

exposures, enhance safety, and facilitate compliance and enforcement. The Agency has based its 

risk mitigation decision on a flexible approach which EPA believes will be protective and allow 

users to make site-specific choices to reduce potential impacts on benefits of the use. While 

some of these measures, buffer zones for example, can be used to estimate margin of exposures 

(MOEs), others such as emergency preparedness and response and community education will 

contribute to bystander safety, but are difficult to express in terms of changes to quantitative risk 

estimates such as MOEs. However, EPA has determined that these measures, working together, 

will prevent unreasonable adverse effects on human health. 

 EPA recognizes that California has many similar requirements for methyl bromide but 

also includes permits for every application which are issued and administered by County 

Agricultural Commissioners. California’s approach has been effective at addressing bystander, 

handler, and worker risks. 

1) Bystander Risk Mitigation 

Bystanders are persons who live and/or work near fumigated fields and are potentially 

exposed to fumigant emissions that travel off-site. In some cases the bystanders are workers 

performing agricultural tasks in nearby fields. If they are employed by the grower who has 

control of the fumigated field, they are more likely to be aware that a fumigant application has 

occurred. 

Bystander risks for people that live near treated fields differ from other human health 

risks evaluated under FIFRA, for example residential and worker reentry risks. Unlike 

residential exposures resulting from use of products to control pests in and around the home, 

non-occupational bystanders receive no direct benefit from the pesticide which was applied 

elsewhere. These bystanders have not made a decision to purchase a pest control product or 

service, and as a result they have little access to information about the product (e.g., hazards, 

safety information, first aid, etc.) or symptoms of exposure. Additionally, non-occupational 

bystander exposures to fumigants are largely involuntary and unanticipated. In this regard nonoccupational bystander exposure is similar to dietary exposure in that people consuming foods or 
41 

drinking water expect to be safe from possible adverse effects associated with pesticide residues 

that could be present in their food and drinking water. 

Unlike workers, non-occupational bystanders typically receive no safety information or 

training related to the pesticide to which they may be exposed. Whereas workers are generally 

expected to play an active role in protecting themselves from pesticide risk, no such expectation 

exists for non-occupational bystanders. Workers who experience symptoms of pesticide 

exposure are also more likely to link their symptoms to the pesticide and take steps to receive 

appropriate treatment. Conversely, bystanders are much less likely to attribute adverse effects to 

pesticide exposures or to have access to information needed to take appropriate steps to mitigate 

the effects of the exposure. Thus, EPA’s mitigation includes elements for site specific response 

and management, notice to state lead agencies, training, and community outreach and education, 

as well as labeling changes. 

i. Buffer Zones 

The human health risk assessments indicate bystanders may be exposed to methyl 

bromide air concentrations that exceed the Agency’s level of concern based on current label 

requirements. In general, the risk from inhalation exposures decreases as the distance from the 

field where bystanders are located increases. Because of this relationship, the Agency has 

determined that a buffer zone must be established around the perimeter of each application block 

where methyl bromide is applied. The Agency acknowledges that buffer zones alone will not 

mitigate all risks or eliminate incidents caused by equipment failure, human error, adverse 

weather (e.g., temperature inversions), or other events. The Agency however does believe that 

buffer zones along with other mitigation measures required by this decision described below will 

mitigate risks so that bystanders will not experience unreasonable adverse effects. 

ii. General Buffer Zone Requirements 

General Requirements in the July 2008 RED 

The 2008 methyl bromide RED described general buffer zone requirements for methyl 

bromide and other soil fumigants. This included the definition of a buffer zone, the requirement 

to exclude non-handlers from the buffer zone during the buffer-zone period, and the definition of 

the application block. 

 The RED also did not allow buffer zones to overlap and fumigations were prohibited 

within 0.25 miles of difficult to evacuate sites such as schools, state licensed day care centers, 

nursing homes, and hospitals, if occupied during the buffer zone period. Exemptions for 

vehicular and bicycle traffic were allowed on roadways through the buffer zone. However, bus 

stops or other locations where persons wait for public transit were not permitted within the buffer 

zone. Structures within the buffer zone were also not allowed to be occupied during the buffer 

zone period and air samples were required before bystanders could enter the structure following 

expiration of the buffer-zone period. In addition, before a buffer zone could extend onto 

adjacent private or public property, the applicator needed to obtain written permission from the 
42 

owner/operator or local authority to allow the buffer zone to extend onto the property. This was 

to ensure that non-handlers would not enter the buffer zone and that buffer zones did not overlap. 

Comments on the July 2008 RED 

During the post-RED comment period, the Agency received many comments from 

stakeholders concerning the buffer zone requirements. Many comments stated that the large 

buffer zone distances would make fumigation infeasible and the mitigation options were not 

flexible enough to allow some fumigations to occur; however other comments expressed concern 

that buffers EPA specified would not be large enough to protect bystanders. 

The Agency also received numerous comments that buffer zone duration will present 

severe hardship for growers. Many commenters expressed concern that the buffer zone overlap 

restriction would have the unintended consequence of forcing some applications to occur during 

less-than-optimal weather and soil conditions, because the restriction could preclude nearby 

application blocks from being treated when weather and soil conditions would be optimal for 

reducing emissions. Hence, subsequent fumigations in adjacent fields would have an increased 

chance of occurring when weather and soil conditions are more conducive to off-gassing. 

Examples cited by commenters where this situation could occur include the Southeast and 

Pacific Northwest where optimal soil moisture conditions occur during a limited time period. 

The commenters felt that while the buffer zone is in effect, properly trained and equipped 

handlers should be allowed to enter adjacent application blocks to make applications. Several 

commenters felt that providing an exception to this prohibition would make buffers more 

workable, reduce delays, allow a more efficient use of equipment and labor, allow growers 

additional flexibility to achieve compliance with buffer requirements, and potentially reduce risk 

if applications could be made under more favorable soil and weather conditions. In addition, 

some comments suggested that allowing adjacent application blocks to be treated would not 

increase risk to bystanders since the Agency’s mitigation measures encourage users to split 

application blocks into smaller treatment areas which result in less fumigant being applied, less 

exposure, and less potential risk. 

Some comments also asked for clarification on various aspects of the buffer zone 

requirements, and some asked that EPA provide additional increments for acreages and 

application rates for buffer zone tables. In addition, many comments stated that buffer zone 

credits should be greater for the use of tarps and for certain environmental conditions. A number 

of comments indicated that obtaining written permission from local authorities for buffers to 

extend over roads and rights-of-way would be extremely difficult, and that neighbors may not 

provide permission. EPA also received additional field emissions (flux) data for some 

fumigants, as well as additional information regarding factors that affect fumigant emissions. 

Based on EPA’s review of the comments, and new data and information, the Agency has 

determined that certain amendments to the buffer zone requirements are appropriate. EPA 

believes these amendments will maintain the important protections for bystanders but will 

increase the feasibility of compliance with buffers and will reduce potential impacts of buffers on 

the beneficial uses of soil fumigants. The Agency does agree that compliance with buffer zone 

requirements as outlined in the July 2008 RED would be a significant challenge for applicators 
43 

and growers. However, field flux studies, monitoring data, modeling analyses, and information 

from incidents involving fumigants continue to support a conclusion that methyl bromide offgasses and moves away from treated fields at concentrations that have the potential to cause 

adverse effects. Therefore, the Agency still believes that buffer zones that exclude bystanders 

are a critical aspect of mitigating risks from the use of methyl bromide. The Agency believes the 

modifications to the buffer requirements, specified below, will increase compliance feasibility 

and encourage further adoption of emission reduction application techniques, while still 

protecting human health and the environment. 

Amended RED Requirements 

EPA has determined that no changes to several aspects of the general buffer zone 

requirements from the 2008 RED are appropriate. This includes: 

- the definition and duration of a buffer zone; 

- the requirement to exclude field workers, nearby residents, pedestrians, and other 

bystanders from the buffer zone during the buffer zone period; 

- the exemption for transit through buffer zones; 

- the definition of the application block; 

- the minimum buffer of 25 feet and maximum buffer of 1⁄2 mile. 

- the requirement limiting entry into buffer zones to handlers who have been properly 

trained and equipped according to EPA’s Worker Protection Standard; 

- the prohibition on including in buffer zones bus stops or other locations where 

persons wait for public transit; 

- the prohibition against including in buffer zones buildings under the control of the 

owner/operator of the application block used for storage such as sheds, barns, 

garages, etc., unless the storage buildings are not occupied during the buffer zone 

period, and the storage buildings do not share a common wall with an occupied 

structure; 

- the prohibition against including in buffer zones residential areas that are not under 

the control of the owner/operator unless occupants agree in writing that they will 

voluntarily vacate the buffer zone until the buffer zone period expires; 

- the prohibition against including in buffer zones agricultural areas that are not under 

the control of the owner/operator unless the owner/operator of the other area provides 

written agreement that they, their employees, and other persons will not enter the 

buffer zone; and 

- the prohibition against including in buffer zones publicly owned and/or operated 

areas such as parks, sidewalks, walking paths, playgrounds, and athletic fields 

without first obtaining written permission from local authorities. 

EPA has determined that certain other amendments to the July 2008 RED requirements 

are appropriate; these are discussed in greater detail below. The amended buffer zone 

requirements are summarized at the end of this section. 
44 

Buffer Zone Proximity - Exception to Allow Buffer Zone Overlap 

The Agency is concerned that emissions from multiple fields located close to one another 

could be higher than air concentrations from individually treated fields. As a result, bystanders 

outside of buffers for individual application blocks could be exposed to concentrations of 

concern particularly if peak concentrations from multiple application blocks in proximity to each 

other coincide. To reduce the potential for off-site movement of fumigant emissions beyond 

buffer zones for multiple fumigated fields, the July 2008 RED prohibited buffer zones from 

multiple application blocks from overlapping, including application blocks fumigated by other 

property operators. 

EPA has considered the comments submitted and has determined that allowing an 

exception to the buffer zone overlap prohibition, under the conditions specified below, is 

reasonable and will not demonstrably alter the protection goals provided to bystanders in the July 

2008 RED. EPA has determined that buffer zones from nearby application blocks may overlap 

one another provided at least 12 hours have elapsed from the end of one application until the 

start of the next application. By separating the application times by at least 12 hours the 

fumigant emission peaks are less likely to occur at the same time, which would sufficiently 

reduce potential exposure outside buffer zones and meets the Agency’s protection goals. 

The Agency is maintaining the requirement for buffer zones around each application 

block to be in effect for 48 hours and that only properly trained and equipped handlers are 

allowed to enter into buffers zones. 

To clarify, below are conditions when buffer zones may or may not overlap: 

- A buffer zone may NOT overlap buffer zones from other application blocks that are 

already in effect UNLESS a minimum of 12 hours has elapsed from the time the first 

application ends until the second application begins. 

EPA has determined that when fumigators exercise the exception to allow buffers to 

overlap, the emergency preparedness and response measures described later in this document 

must be implemented if there are homes, businesses, or property not within the control of the 

fumigator within 300 feet of the buffer zone regardless of the size of the buffer zone. 

To ensure handlers are aware that they are working in an existing buffer from an 

overlapping buffer zone area, the labels will require the certified applicator, before beginning the 

application, to determine whether the application block or its resulting buffer will overlap with a 

buffer that is already in effect. If so, the certified applicator must inform handlers of this and the 

health effects, early signs of exposure, and respiratory protection and PPE requirements for 

products applied in both the application block in which they are working and the other 

application block. The Agency is requiring that all treatment areas and buffers be clearly posted 

with proper signage to ensure handlers entering a treatment area are aware of previous treatments 

and the existence of buffers. In addition, certified applicators must obtain permission from other 

landowners when buffers extend onto other lands, which provides an additional mechanism to 

ensure handlers are aware when they are working in a buffer zone and that they have the 
45 

necessary information regarding health effects, warning properties, and respiratory/PPE 

requirements for all products to which they may be exposed. 

Areas not under the control of owner/operator of the application block 

For areas not under the control of the owner/operator of the application block, the 

requirements remain unchanged except (1) air samples do not need to be taken to allow 

occupants to reenter buildings or homes after the buffer zone period has expired, and (2) buffer 

zones may include publicly owned and/or operated roads, including rights of ways, without first 

obtaining written permission from local authorities; however, if a sidewalk or permanent walking 

path is associated with the road or right-of-way, written permission must be given by the 

appropriate state and/or local authorities. 

In summary, areas of a buffer zone not under the control of the owner/operator of the 

application block, may not include residential areas (including employee housing, private 

property, buildings, commercial, industrial, and other areas that people may occupy or outdoor 

residential areas, such as lawns, gardens, or play areas) unless the occupants provide written 

agreement that they will voluntarily vacate the buffer zone during the entire buffer zone period. 

Air samples for methyl bromide and chloropicrin do not need to be taken before the occupants 

can re-enter a building, home, or outdoor area that was vacated in order to permit the fumigation 

to occur unless the methyl bromide product applied is formulated with less than 20% 

chloropicrin. The Agency determined that the concentrations of the fumigants 48 hours after 

completion of the application were likely to be below the Agency’s level of concern, and that the 

warning properties of chloropicrin would alert persons reentering the site if concentrations were 

of concern. However, because methyl bromide is odorless and colorless, EPA is not confident 

that chloropicrin in low-concentration formulations would be an effective warning agent 48 

hours after treatment. Therefore, monitoring of buildings and outdoor areas after termination of 

the buffer zone is not necessary and will no longer be required except as noted for methyl 

bromide when it is applied in formulations with less than 20% chloropicrin. 

Buffer zones may still not include agricultural areas owned/operated by persons other 

than the owner/operator of the application block unless the owner/operator of the application 

block can ensure that the buffer zone will not overlap with a buffer zone from any adjacent 

property owners, taking into account the amended requirements for overlapping buffers. In 

addition, the applicator must still receive written permission from the owner/operator of areas 

that are not under the control of the applicator stating that the owner, their employees, and other 

persons other than handlers, consistent with buffer overlap provisions, will stay out of the buffer 

zone during the entire buffer zone period. The goal of this agreement is to ensure that a property 

owner of an agricultural field adjacent to an area that will be treated with a fumigant is aware 

when the fumigation will occur. This will allow the applicator to post on the adjacent property 

and take other required safety measures to ensure that persons on the property will not be 

exposed to a fumigant at levels above the Agency’s level of concern. Informing the property 

owner of the adjacent field will enable them to take any appropriate safety measures they deem 

necessary. The Agency believes that requiring the applicator to obtain written permission will be 

an enforceable measure that will meet the goal of protecting workers and bystanders on adjacent 

properties that fall within a buffer zone. 
46 

In addition, buffer zones still may include publicly owned and/or operated areas such as 

parks, sidewalks, walking paths, playgrounds, and athletic fields only if the area is not occupied 

during the buffer zone period and entry by non-handlers is prohibited during the buffer zone 

period. Written permission from the appropriate state and/or local authorities to include these 

public areas in the buffer zone is also still required. 

However, for roads and rights-of-ways, EPA has determined that these may be included 

in buffers, subject to local laws and regulations, as long as it is posted according to the 

requirements of this amended RED. If, as discussed above, the road or right-of-way has an 

associated sidewalk or permanent walking path, then written permission would also be required 

to include the area in the buffer zone. The Agency believes that if a town or county has invested 

resources into building a sidewalk or establishing a walking path, it is reasonable to anticipate 

pedestrian traffic at that location. In such circumstances EPA believes a local authority would be 

best positioned to make a determination about the practicality of preventing non-handlers from 

entering the buffer zone. EPA acknowledges that laws and regulations vary from jurisdiction to 

jurisdiction and that the requirement to post points of entry into buffer zones may necessitate 

additional steps on the part of fumigant applicators before a road or right-of-way can be included 

in a buffer. 

Maximum Application Block Sizes 

The maximum application block sizes allowed in the 2008 RED for methyl bromide 

applications were: 

• 100 acres for tarped bedded and broadcast applications, 

• 40 acres for untarped deep applications (e.g., California orchard replant), 

• 10 acres for outdoor hot gas applications, and 

• 45,000 square feet for greenhouse hot gas applications. 

These block size limits were based on the upper end of the range of acres treated under 

current practices and constraints of modeling for these scenarios. No comments were provided 

regarding these limits. 

Buffer zone distances - Requirements in the July 2008 RED

Because the methyl bromide target air concentration is based on a severe, irreversible 

effect, EPA believes it is important that the buffer zones required for methyl bromide result in an 

MOE of 30 (the target MOE) at high percentiles of the of the outputs from PERFUM model 

Version 2.1.4, one of the resources EPA used to help inform decisions regarding buffer zone 

distances. See Appendix B for more information on the PERFUM model. EPA believes the 

buffer zone distances that achieve this result will be protective of all potentially exposed 

bystanders including females at a critical phase of pregnancy. MOEs for non-pregnant 

bystanders would be higher. 

As discussed in the July 2008 RED, the buffer zones distances were not based on the 

selection of a specific percentile or distribution from the PERFUM modeling results. Rather, 

EPA used a weight of evidence approach to set the buffers which included consideration of the 
47 

hazard profile of methyl bromide, information from incident reports, monitoring data, 

stakeholder comments along with comprehensive analysis of results from PERFUM modeling 

and consideration of results using other models (e.g., Industrial Source Complex Model12). The 

analysis of PERFUM results considered distances at various percentiles of the whole field and 

maximum distance distributions, and predicted MOEs for various distances. The risk assessment 

characterizes additional types of analysis that were performed. EPA’s goal for risk management 

was to achieve buffer distances where associated risks were at or above target concentration 

levels at high percentiles of exposure. For methyl bromide, the buffers specified in the July 2008 

RED achieved this goal for protection. EPA also believed that the 2008 RED buffer zone 

distances would be manageable for most growers using existing cultural practices because of the 

flexibility and options provided to modify buffers by altering certain aspects of fumigation 

practices. 

For the 2008 RED, the Agency developed buffer zone distances that were scaled based 

on application method, application rate, and application block size. For each of the outdoor preplant soil emission profiles for the July 2008 RED, distances were first chosen for the rates 

identified in the risk assessment as the 10%, 25%, 50%, 75% and 100% of the maximum rates 

(i.e., 25, 63, 125, 188, and 250 lb ai/A for tarped bedded were provided in the tables) with 

application block sizes of 1, 5, 10, 20, 30, 40, 60, 80, and 100 acres. Distances for the other rates 

in the buffer zone tables were scaled by assuming a linear relationship between the 10%, 25%, 

50%, 75% and 100% maximum rates (e.g., distance at 37.5% rate = [distance at 25% rate + 

distance at 50% rate]/2 ). This scaling was necessary to provide an incremental spread of rates 

and buffer zone distances. It should be noted that the distances in the lookup tables are not 

model outputs, although as described above the model outputs were used to inform the selection 

of buffer zone distances. 

The risks associated with the buffer zone distances, which are presented in Tables 4, 5, 6, 

7 and 8, are characterized as follows: 

• For outdoor and greenhouse pre-plant soil applications, the buffer zone distances result in 

MOEs ≥ 30 at the upper percentiles (usually 95th percentile or greater) on the maximum 

distance and whole field distributions for all weather stations modeled. 

• The risk level corresponding to the buffer zone distances at the 95th percentile maximum 

distribution is equivalent to saying a person at the location on the perimeter of the buffer 

zone where the maximum concentration occurs during the worst case 24 hour period 

following the fumigation of a specific field during a 5 year period would have at least a 95 

percent chance of having of an acceptable level of exposure (i.e., MOE of ≥ 30). 

• The PERFUM model Version 2.1.4 provides outputs that show air concentrations at each of 

the modeled ring distances. The Agency has used this information to estimate the MOEs at 

various distances for each of the five weather stations. MOEs for the 99th percentile air 

concentrations at the distances selected exceed 30 for all the weather stations modeled. 

• The exposure time frame for which buffer zone distance modeling was performed was 24 

hours, which is longer than the duration that agricultural workers in nearby fields or other 

work areas are likely to be present. 

 

12 http://www.epa.gov/scram001/dispersion_alt.htm#isc3
48 

• It was assumed that methyl bromide air concentrations inside homes and other occupied 

structures are equal to outside concentrations. These structures could act as a barrier which 

could in some cases reduce potential inside air concentrations. However, there is insufficient 

data to quantify differences between indoor and outdoor concentrations. 

• The use of GAPs, FMPs, and other mitigation measures required by this decision will 

contribute to an additional decrease in risk. 

Minimum and Maximum Distances 

A minimum buffer zone of 25 feet was required in the July 2008 RED regardless of sitespecific application parameters. In some instances the PERFUM model predicts that the risks 

reach the target at the edge of the field. While modeling may support no buffer zone in some 

cases, a minimum buffer was required because of variability in the emission rates over a field 

and other factors not accounted for in the modeling; as such the Agency determined that a 25 

foot minimum buffer zone was a good agricultural practice. Also, in the 2008 RED, application 

scenarios requiring buffer zone distances of more than 1⁄2 mile (2,640 feet) were prohibited. EPA 

believes that for areas where methyl bromide is used, buffers greater than 1⁄2 mile are not 

practical and difficult to enforce. 

“Greenhouse” Uses 

The “greenhouse” industry sector is extremely varied because of the diversity of the 

facilities that are used across the country and because of the nature of the products that are 

produced. As a result, some clarification is required to interpret the required buffer zone 

distances for “greenhouses”. In typical “greenhouse” operations, many types of containerized 

ornamental plants and vegetable starter sets are produced in either closed structures that will be 

referred to as “greenhouses” or in other related nursery operations such as small fields, or in 

what are commonly known as “shade” houses (i.e., essentially fields with an overhead sunblock, 

typically a semi-translucent black shade cloth). In the latter type of operation, cultural practices 

related to methyl bromide use are essentially identical to the pre-plant field uses except they 

typically occur on a smaller scale (e.g., 1 acre applications or less). As a result, the minimum 

buffer zone distances for these types of use patterns must be determined from the applicable 

outdoor pre-plant soil lookup tables (i.e., Tables 4, 5, and 7). 

Methyl Bromide – Chloropicrin Formulations 

Methyl bromide formulations used for pre-plant soil uses are always formulated with at 

least 2 percent chloropicrin. The Agency has also completed a RED for chloropicrin which 

includes buffer zone distances based on risks associated with chloropicrin. In accordance with 

Agency policy, when a pesticide contains more than one active ingredient, the product labeling 

shall bear the more restrictive measures of pesticides in the mixture. Generally, formulations 

with higher concentrations of methyl bromide will have buffers zone distances based on methyl 

bromide, while the formulations with higher concentrations of chloropicrin will have buffers 

zone distances based on chloropicrin. However, the user must consult the label for the specific 

formulation intended for use to ensure the required buffer zone distances for the particular 

product are employed. 
49 

The July 2008 RED also provided detailed descriptions of the PERFUM model inputs 

and outputs. These descriptions have not changed and are included in this Amended RED in 

Appendix B. 

Comments on the July 2008 RED Buffer Distances and Amended RED Determinations 

Additional Acreage and Rate Increments

During the post-RED comment period, the Agency received comments requesting buffer 

zone distances for additional acreage increments for small fields and additional application rate 

increments for tarped bedded and tarped broadcast scenarios. In response, the Agency 

determined buffer distances for smaller block sizes (1, 2, 3, 4, 5, 6, 7, 8, 9, and 10 acres) as well 

as more application rates for tarped bedded and tarped broadcast scenarios. EPA believes this 

will help to better refine the buffer distances for these use scenarios (Tables 4 and 5), and will 

provide additional options for growers to achieve more workable buffers. 

Although the Agency added additional acreage and rate increments, not all increments 

may be captured by the tables presented. If the tables do not capture a specific acreage or rate, 

round up to the nearest acre or rate. For example, when applying to a 9.5 acre field, round up to 

10 acres. 

New Flux (Emissions) Studies

Since the RED was published in July 2008, the Agency has received new flux data that 

have allowed the Agency to refine buffer zone distances for certain fumigants. While no new 

methyl bromide studies were submitted, the MBIP has submitted a letter committing to conduct 

new field flux studies for methyl bromide that may allow EPA to further refine the buffer zone 

distances specified in the tables below. The studies will be conducted in San Joaquin Valley and 

Ventura County, California, and in Plant City, Florida. Emissions from various application 

methods will be conducted including: 

• Broadcast shallow tarped under standard high-density polyethylene (HDPE) 

• Broadcast shallow tarped under virtually impermeable film (VIF) 

• Broadcast shallow tarped under VIF with potassium thiosulfate soil spray 

• Deep, tarped strip under VIF 

• Bedded tarp shank injection with VIF 

• Bedded tarp shank injection with VIF and additional emissions reduction treatment 

• Bedded tarp shank injection with metalized film 

The studies are scheduled to be conducted in spring 2009 through winter 2010 and final 

reports are scheduled to be submitted to the Agency by March 2010. As noted above, the 

information from these studies may enable EPA to refine buffer zone distances that will appear 

on labels in 2011. See letter from Tracy Heinzman, Wiley Rein, LLP, to Debbie Edwards, 

“Methyl Bromide Reregistration -- Development of New Data to Calculate Flux Rates/Emission 

Factors and Update EPA’s By-Stander Exposure Assessment,” March 31, 2009, located in the 

methyl bromide docket. 
50 

In addition, new fumigant data submitted during the post-RED comment period has also 

allowed the Agency to refine and update buffer zone credits for tarps, certain application 

techniques, and environmental conditions. As a result, although the buffer zone distances 

specified in the tables in the July 2008 RED for methyl bromide have not changed except as 

noted to add rate and acreage increments, buffers for growers who use emission-reducing tarps 

or application methods, or have site conditions that qualify for credits will have smaller buffers 

than those specified in the 2008 RED. Available data indicate that for some crops and regions, 

pest control efficacy may be improved with high barrier tarps that may enable growers to use the 

buffer zone credits and utilize lower application rates, resulting in further reductions of the buffer 

zone distances. Some growers in the Southeast are commonly using high barrier tarps and lower 

rates. The amended credits are discussed in detail below in the section, Buffer Zone Reduction 

Credits. 

Methyl bromide buffer distances, amended as noted above, are specified in Tables 4-8 

below. Table 9, from the July 2008 RED, summarized the required buffer zone distances and 

corresponding PERFUM modeling results for the pre-plant soil uses that qualify for critical use 

exemptions with typical application rates (based on information identified in the Agency’s 

benefits assessments). The buffer zone distances have been updated to incorporate additional 

rates. Focusing on tomatoes as an example (last row of Table 9), the buffer zone is 185 feet for a 

10 acre application block in the Southeast at a rate of 120 lbs ai/A. At 185 feet, the PERFUM 

model predicts greater than the 99.9th percentile for the whole field distribution and greater than 

the 95th percentile for the maximum field distribution for the worst case weather station modeled 

(i.e., Bradenton, Florida). (See Appendix B for more details on the PERFUM model inputs and 

outputs.) The risk level corresponding to this buffer zone distance at the 99.9th percentile whole 

field distribution is equivalent to saying a person at any location on the perimeter of the buffer 

zone during the 24 hour period following the fumigation of a specific field during a 5-year period 

would have at least a 99.9 percent chance of having of an exposure below the level of concern 

(i.e., MOE of 30 or higher). The risk level corresponding to the buffer zone distances at the 95th

percentile maximum distribution is equivalent to saying a person at the location on the perimeter 

of the buffer zone where the maximum concentration occurs during the worst case 24 hour 

period following the fumigation of a specific field during a 5-year period would have a 95 

percent chance of having of an exposure below the level of concern (i.e., MOE of 30) for these 

typical use scenarios. Using the PERFUM model outputs of air concentrations to predict MOEs 

at the 99th percentile, at 185 feet for these application parameters, the MOE at the 99th percentile 

is greater than 40 for the worst case weather station modeled (i.e., Bradenton, Florida). 
51 

Table 4. Tarped Bedded Buffer Zone Distances (feet)

Application Block Size (acres) 

1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 

25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 30 25 25 25 25 25 25 25 25 25 25 25 25 25 25 28 31 34 38 35 25 25 25 25 25 25 25 25 25 25 25 25 25 25 31 38 44 50 40 25 25 25 25 25 25 25 25 25 25 25 25 25 25 34 44 53 63 45 25 25 25 25 25 25 25 25 25 25 25 25 25 25 38 50 63 75 50 25 25 25 25 25 25 25 25 25 25 25 25 25 25 41 56 72 88 55 25 25 25 25 25 25 25 25 25 25 25 25 25 25 44 63 81 100 60 25 25 25 25 25 25 25 25 25 25 25 25 25 25 47 69 91 113 65 25 25 25 25 25 25 25 25 25 25 25 25 25 25 50 75 100 125 70 25 27 28 30 31 33 35 36 38 40 46 52 56 60 86 113 144 175 75 25 28 31 34 38 41 44 48 51 54 67 79 88 96 123 150 188 225 80 25 30 34 39 44 49 54 59 64 69 88 106 119 131 159 188 231 275 85 25 31 38 44 50 57 63 70 77 83 108 133 150 167 196 225 275 325 90 25 33 41 48 56 65 73 81 90 98 129 160 181 202 232 263 319 375 95 25 34 44 53 63 73 83 93 103 113 150 188 213 238 269 300 363 425 

100 25 36 47 58 69 80 92 104 115 127 171 215 244 273 305 338 406 475 105 25 38 50 63 75 88 102 115 128 142 192 242 275 308 342 375 450 525 110 25 39 53 67 81 96 111 126 141 156 213 269 306 344 378 413 494 575 115 25 41 56 72 88 104 121 138 154 171 233 296 338 379 415 450 538 625 120 25 42 59 77 94 112 130 149 167 185 254 323 369 415 451 488 581 675 125 25 44 63 81 100 120 140 160 180 200 275 350 400 450 488 525 625 725 130 27 48 69 90 112 133 154 175 196 217 295 373 427 481 521 562 665 768 135 29 52 76 100 123 145 168 190 212 235 315 396 454 512 555 598 705 811 140 31 57 83 109 135 158 182 205 228 252 336 419 481 542 588 635 744 854 145 33 61 89 118 146 171 195 220 245 269 356 442 508 573 622 671 784 897 150 35 65 96 127 158 183 209 235 261 287 376 465 535 604 656 708 824 940 155 37 70 103 136 169 196 223 250 277 304 396 488 562 635 689 744 864 983 160 38 74 110 145 181 209 237 265 293 321 416 512 588 665 723 781 904 1027 165 40 78 116 154 192 222 251 280 309 338 437 535 615 696 757 817 943 1070 170 42 83 123 163 204 234 265 295 325 356 457 558 642 727 790 854 983 1113 

Broadcast Equivalent Application Rate (lb ai/A) 

175 44 87 130 173 215 247 278 310 342 373 477 581 669 758 824 890 1023 1156 
52 

Table 4. Tarped Bedded Buffer Zone Distances (feet)

Application Block Size (acres) 

1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 

180 46 91 137 182 227 260 292 325 358 390 497 604 696 788 858 927 1063 1199 185 48 96 143 191 238 272 306 340 374 408 517 627 723 819 891 963 1103 1242 190 50 100 150 200 250 285 320 355 390 425 538 650 750 850 925 1000 1143 1285 195 56 108 159 211 263 298 333 369 404 440 556 673 776 879 957 1035 1185 1334 200 63 116 169 222 275 311 347 383 418 454 575 696 802 908 990 1071 1227 1383 205 69 123 178 233 288 324 360 396 433 469 594 719 828 938 1022 1106 1269 1433 210 75 131 188 244 300 337 373 410 447 483 613 742 854 967 1054 1142 1312 1482 215 81 139 197 255 313 350 387 424 461 498 631 765 880 996 1086 1177 1354 1531 220 88 147 206 266 325 363 400 438 475 513 650 788 906 1025 1119 1213 1396 1580 225 94 155 216 277 338 375 413 451 489 527 669 810 932 1054 1151 1248 1439 1629 230 100 163 225 288 350 388 427 465 503 542 688 833 958 1083 1183 1283 1481 1678 235 106 170 234 298 363 401 440 479 518 556 706 856 984 1113 1216 1319 1523 1728 240 113 178 244 309 375 414 453 493 532 571 725 879 1010 1142 1248 1354 1565 1777 245 119 186 253 320 388 427 467 506 546 585 744 902 1036 1171 1280 1390 1608 1826 250 125 194 263 331 400 440 480 520 560 600 763 925 1063 1200 1313 1425 1650 1875 
53 

Table 5. Tarped Broadcast Buffer Zone Distances (feet) 

Application Block Size (acres) 

1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 

45 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 55 25 25 25 25 25 25 25 25 25 25 25 25 27 29 35 42 48 54 63 65 25 25 25 25 25 25 25 25 25 25 25 25 29 33 46 58 71 83 100 75 25 25 25 25 25 25 25 25 25 25 25 25 31 38 56 75 94 113 138 85 25 25 25 25 25 25 25 25 25 25 25 25 33 42 67 92 117 142 175 95 25 25 25 25 25 25 25 25 25 25 25 25 35 46 77 108 140 171 213 

105 25 25 25 25 25 25 25 25 25 25 25 25 38 50 88 125 163 200 250 115 25 28 31 34 36 39 42 45 47 50 59 68 88 107 149 191 236 282 339 125 25 31 36 42 48 53 59 64 70 75 93 111 138 164 210 257 310 364 427 135 25 34 42 51 59 67 75 84 92 100 127 155 188 220 272 323 384 445 516 145 25 36 48 59 70 81 92 103 114 125 161 198 238 277 333 389 458 527 605 155 25 39 53 68 82 95 109 123 136 150 195 241 288 334 394 455 532 609 693 165 25 42 59 76 93 110 126 142 159 175 230 284 338 391 456 520 606 691 782 175 25 45 65 85 105 124 143 162 181 200 264 327 388 448 517 586 680 773 870 185 25 48 70 93 116 138 160 181 203 225 298 370 438 505 578 652 753 855 959 195 25 51 76 102 127 152 176 201 225 250 332 414 488 561 640 718 827 936 104205 25 53 82 110 139 166 193 220 248 275 366 457 538 618 701 784 901 1018 113215 25 56 88 119 150 180 210 240 270 300 400 500 588 675 763 850 975 1100 122225 25 61 98 134 170 202 234 266 298 330 438 545 639 732 824 916 1053 1190 132235 25 66 108 149 191 225 258 292 325 359 475 591 690 789 885 982 1130 1279 142245 25 72 118 165 211 247 282 318 353 389 513 636 741 845 947 1048 1208 1369 152255 25 77 128 180 232 269 306 344 381 418 550 682 792 902 1008 1114 1286 1458 162265 25 82 139 195 252 291 330 370 409 448 588 727 843 959 1069 1180 1364 1548 172275 25 87 149 211 273 314 355 395 436 477 625 773 894 1016 1131 1245 1441 1637 182285 25 92 159 226 293 336 379 421 464 507 663 818 945 1073 1192 1311 1519 1727 192295 25 97 169 241 314 358 403 447 492 536 700 864 997 1130 1253 1377 1597 1816 202305 25 102 180 257 334 380 427 473 520 566 738 909 1048 1186 1315 1443 1675 1906 212315 25 107 190 272 355 403 451 499 547 595 775 955 1099 1243 1376 1509 1752 1995 223

Broadcast Equivalent Application Rate (lb ai/A) 

325 25 113 200 288 375 425 475 525 575 625 813 1000 1150 1300 1438 1575 1830 2085 233
54 

Table 5. Tarped Broadcast Buffer Zone Distances (feet) 

Application Block Size (acres) 

1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 

335 34 126 218 310 402 452 502 552 602 652 847 1041 1195 1350 1495 1641 1907 2173 242345 43 140 236 333 430 480 530 580 630 680 881 1082 1241 1400 1553 1707 1984 2260 252355 52 153 255 356 457 507 557 607 657 707 915 1123 1286 1450 1611 1773 2060 2348 261365 61 167 273 378 484 534 584 634 684 734 949 1164 1332 1500 1669 1839 2137 2436 271375 70 181 291 401 511 561 611 661 711 761 983 1205 1377 1550 1727 1905 2214 2524 281385 80 194 309 424 539 589 639 689 739 789 1017 1245 1423 1600 1785 1970 2291 2611 290395 89 208 327 447 566 616 666 716 766 816 1051 1286 1468 1650 1843 2036 2368 2699 300405 98 222 345 469 593 643 693 743 793 843 1085 1327 1514 1700 1901 2102 2445 2787 309415 107 235 364 492 620 670 720 770 820 870 1119 1368 1559 1750 1959 2168 2521 2875 319425 116 249 382 515 648 698 748 798 848 898 1153 1409 1605 1800 2017 2234 2598 2962 329435 125 263 400 538 675 725 775 825 875 925 1188 1450 1650 1850 2075 2300 2675 3050 338
55 

Table 6. Deep Untarped Buffer Zone Distances (feet) 

Block Broadcast Equivalent Application Rate (lb ai/acre) 

Size

(acres) 43 75 108 134 161 188 215 242 269 296 323 350 377 403 430 

1 25 25 25 25 25 25 25 45 65 85 100 135 165 200 225 

5 25 25 25 85 140 195 250 315 375 440 500 560 615 770 725 

10 25 25 25 135 240 345 450 545 640 735 825 910 990 1,070 1,150 

20 25 88 150 295 440 585 725 865 1,000 1,140 1,275 1,410 1,540 1,670 1,800 

30 25 125 225 410 590 770 950 1,125 1,300 1,475 1,650 1,825 2,000 2,175 2,350 

40 25 163 300 515 725 940 1,150 1,365 1,575 1,790 2,000 2,215 2,425 2,640 2,850 

Table 7. Outdoor Tarped Hot Gas Buffer Zone Distances (feet) 

Block Broadcast Equivalent Application Rate (lb ai/acre) 

Size

(acres) 43 75 108 134 161 188 215 242 269 296 323 350 377 403 430 

1 25 25 25 85 140 195 250 285 325 345 375 415 450 490 525 

5 25 150 275 385 490 595 700 790 875 965 1,050 1,140 1,225 1,315 1,400 

10 50 250 450 610 765 920 1,075 1,210 1,340 1,470 1,600 1,735 1,865 1,995 2,125 

Table 8. Greenhouse Hot Gas Buffer Zone Distances (feet) 

Block Size Broadcast Equivalent Application Rate (lb ai/100 square feet)

(square 

feet) 0.25 0.5 0.75 1 

5,000 25 25 50 100 

10,000 25 50 125 200 

15,000 25 100 175 250 

20,000 25 125 225 300 

25,000 25 150 250 350 

30,000 25 175 300 400 

35,000 50 200 350 450 

40,000 50 225 375 475 

45,000 75 250 400 500 
56 

Table 9. Projected Buffers Zones for Methyl Bromide Critical Use Exemptions Based on Current Typical Application 

Rates

Maximum 

Distribution 

Percentile where 

MOE reaches 302

MOE for 99th

Percentile Air 

Concentration from 

PERFUM2 output 

Crop Region 

Application 

Method1

Broadcast 

Equivalent 

Rate (lb 

ai/A) 

Block 

Sixe 

(acres) 

Buffer 

Zones 

without 

credits 

(ft) Bradenton Ventura Bradenton Ventura 

10 454 >95 >95 >40 >45 

MI 

Tarped 

Shank 

Bedded 

200 

20 696 >95 >97 >40 >45 

10 185 >95 >97 >40 >45 

Cucurbits 

Southeast 

Tarped 

Shank 

Bedded 

120 

20 323 >95 >97 >35 >40 

10 185 >95 >97 >40 >45 

Eggplant Southeast 

Tarped 

Shank 

Bedded 

120 

20 323 >95 >97 >35 >40 

10 389 >99 >99.9 >45 >50 236 20 636 >99 >97 >45 >50 

10 707 >97 >99 >50 >60 

Forest 

Seedlings Southeast 

Tarped 

Shank 

Broadcast 350 20 1,123 >99 >97 >50 >60 

Nursery, 10 225 >99 >99.9 >45 >50 

Fruit, Nut, 

and Rose 

National 

Tarped 

Shank 

Broadcast 

180 

40 652 >99 >99.9 >45 >50 

10 225 >99 >99.9 >45 >50 

Stone Fruit, 

Tree Nut 

Orchard 

Replant, 

Grape 

Vineyards 

CA 

Tarped 

Shank 

Broadcast 

182 

40 652 >99 >99.9 >45 >50 

10 359 >99 >99.9 >45 >50 

CA 

Tarped 

Shank 

Broadcast 

235 

20 591 >99 >97 >45 >50 

10 816 >99 >97 >55 >60 

Ornamentals 

FL 

Tarped 

Shank 

Broadcast 

390 

20 1,286 >99 >97 >55 >60 

10 454 >95 >95 >40 >45 

MI 

Tarped 

Shank 

Bedded 

200 

20 696 >95 >97 >40 >45 

10 185 >95 >97 >40 >45 Pepper, Bell 

Southeast 

Tarped 

Shank 

Bedded 

120 

20 323 >95 >97 >35 >40 

10 200 >99 >99.9 >45 >50 

CA 

Tarped 

Shank 

Broadcast 

175 

20 327 >99 >99.9 >45 >50 

10 185 >95 >97 >40 >45 

Strawberry 

Fruit 

FL 

Tarped 

Shank 

Bedded 

120 

20 323 >95 >97 >35 >40 

10 359 >99 >99.9 >45 >50 

CA 

Tarped 

Shank 

Broadcast 

235 

20 591 >99 >97 >45 >50 

Tarped 10 556 >95 >97 >35 >40 

Shank 

Bedded 

235 

20 856 >95 >97 >35 >35 

10 359 >99 >99.9 >45 >50 

Strawberry 

Nursery 

NC Tarped 

Shank 

Broadcast 

235 

20 591 >99 >97 >45 >50 

10 185 >95 >97 >40 >45 Tomato, 

Fresh Southeast 

Tarped 

Shank 

Bedded 

120 

20 323 >95 >97 >35 >40 

1

 Broadcast (flat fume) may be applied as strips with non-treated areas in between (e.g., for forest seedlings and orchards). 2

 The whole field percentile where MOEs reach 30 is >99.9 for all of the weather stations modeled.
57 

The Agency believes that the buffer zone distances described above, combined with other 

risk mitigations described herein, will provide protection against unreasonable adverse effects. 

The Agency is anticipating new emissions data from studies conducted by MBIP which may 

allow the Agency to determine if buffer zones of different sizes would meet or exceed the level 

of protection that the Agency established in the July 2008 RED. Reports from these studies are 

scheduled to be submitted to the Agency by March 2010. Therefore, buffer zone distances that 

are scheduled to be on methyl bromide labels in 2011 may be different from the distances 

provided in this document. 

Amended Buffer Zone Requirements 

The following describes the general buffer zone requirements, as amended, for methyl 

bromide: 

• “Buffer zone” is an area established around the perimeter of each application block or 

greenhouse where a soil fumigant is applied. The buffer zone must extend from the edge of 

the application block or greenhouse perimeter equally in all directions. 

• All non-handlers including field workers, nearby residents, pedestrians, and other bystanders, 

must be excluded from the buffer zone during the buffer zone period except for transit (see 

exemptions section). 

• The “buffer zone period” starts at the moment when any fumigant is delivered/dispensed to 

the soil within the application block and lasts for a minimum of 48 hours after the fumigant 

has stopped being delivered/dispensed to the soil. 

• An “application block” is a field or portion of a field treated with a fumigant in any 24-hour 

period. See exception provided in the Buffer zone proximity section below. (See Figures 1 

and 2 of Appendix B for further explanation.) 

Buffer zone proximity

• To reduce the potential for off-site movement from multiple fumigated fields, buffer zones 

from multiple methyl bromide application blocks may not overlap UNLESS: 

o A minimum of 12 hours have elapsed from the time the earlier application(s) for 

which a buffer is in place end(s) until the latter application begins, and 

o Emergency preparedness and response measures specified later in this document 

have been implemented if there are any homes, businesses, or property not within 

the control of the fumigator within 300 feet of each buffer zone, regardless of the 

size of the buffer zone. 

Buffer zone distances

• Buffer zone distances must be based on look-up tables on product labels. Twenty-five feet is 

the minimum buffer distance regardless of site-specific application parameters. 

• For selective replant fumigation in an orchard using hand held application methods (e.g., 

deep injection auger probes), the minimum buffer zone will be 25 feet measured from the 

center of each injection site (i.e., tree hole). 
58 

Authorized entry to buffer zones

• Only authorized handlers who have been properly trained and equipped according to EPA’s 

Worker Protection Standard (WPS) and label requirements may be in the buffer zone during 

the buffer zone period. 

Exemptions for transit through buffer zones

• Vehicular and bicycle traffic on public and private roadways through the buffer zone is 

permitted. “Roadway” means that portion of a street or highway improved, designed or 

ordinarily used for vehicular travel, exclusive of the sidewalk or shoulder even if such 

sidewalk or shoulder is used by persons riding bicycles. In the event a highway includes two 

or more separated roadways, the term “roadway” shall refer to any such roadway separately. 

(This definition is based on the definition of roadway in the Uniform Vehicle Code prepared 

by the National Committee on Uniform Traffic Laws and Ordinances. See 

http://www.ncutlo.org/ for more details) 

• Bus stops or other locations where persons wait for public transit are not permitted within the 

buffer zone. 

• See the Posting section of this document for additional requirements that may apply. 

Structures under the control of owner/operator of the application block

• Buffer zones may not include buildings used for storage such as sheds, barns, garages, etc., 

UNLESS, 

1. The storage buildings are not occupied during the buffer zone period, and 

2. The storage buildings do not share a common wall with an occupied structure. 

• See the Posting section of this document for additional requirements that may apply. 

Areas not under the control of owner/operator of the application block

• Buffer zones may not include residential areas (including employee housing, private 

property, buildings, commercial, industrial, and other areas that people may occupy or 

outdoor residential areas, such as lawns, gardens, or play areas) UNLESS,

1. The occupants provide written agreement that they will voluntarily vacate the buffer zone 

during the entire buffer zone period, and 

2. Reentry by occupants and other non-handlers must not occur until, 

° the buffer zone period has ended, 

° Sensory irritation is not experienced, and 

° for structures in buffer zones for methyl bromide applications with less than 20% 

chloropicrin: Two consecutive air samples for methyl bromide taken in the structure 

at least 1 hour apart show concentrations of methyl bromide are less than 1 ppm. 

• Buffer zones may not include agricultural areas owned/operated by persons other than the 

owner/operator of the application block, UNLESS,

1. The owner/operator of the application block can ensure that the buffer zone will not 

overlap with a buffer zone from any adjacent property owners, except as provided for 

above, and 

2. The owner/operator of the adjacent areas (i.e., areas that are not under the control of the 

owner/operator of the application block) provides written agreement to the applicator that 

they, their employees, and other persons will stay out of the buffer zone during the entire 

buffer zone period. 
59 

• Buffer zones must not include roads and rights of way UNLESS,

1. The area is not occupied during the buffer zone period, and 

2. Entry by non-handlers is prohibited during the buffer zone period. 

3. Applicators must comply with all local laws and regulations. 

• For all other publicly owned and/or operated areas such as parks, side walks, walking paths, 

playgrounds, and athletic fields, buffer zones must not include these areas UNLESS,

1. The area is not occupied during the buffer zone period, 

2. Entry by non-handlers is prohibited during the buffer zone period, and 

3. Written permission to include the public area in the buffer zone is granted by the 

appropriate state and/or local authorities responsible for management and operation of the 

area. 

4. Applicators must comply with all local laws and regulations. 

• See the Posting section of this document for additional requirements that may apply. 

iii. Buffer Zone Reduction Credits 

Requirements in the July 2008 RED 

In preparing for the July 2008 RED, the Agency undertook a significant effort to evaluate 

available empirical data results, modeling, and scientific studies reported in the literature 

regarding the factors and control methods that may reduce emissions from soil fumigants. For 

details on the Agency’s analysis, please see the June 9, 2008 memo, “Factors Which Impact Soil 

Fumigant Emissions - Evaluation for Use in Soil Fumigant Buffer Zone Credit Factor 

Approach,”13 in the methyl bromide docket. The Agency also coordinated and led fora to 

discuss this issue at the 2006 and 2007 Methyl Bromide Alternatives Outreach (MBAO) 

Conferences with leading researchers and other stakeholders. A general description of the 

MBAO sessions can be found at http://mbao.org. 

Based on the Agency’s analysis of the data, the 2008 methyl bromide RED gave buffer 

zone reduction credits for high barrier tarps, soils with high organic matter, and for soils with 

high clay content. The RED noted that changing current use practices or site conditions to utilize 

these credits may be a challenge. The Agency did determine, however, that in addition to 

reducing bystander risk and the size of buffer zones, the credit for high barrier tarps had the 

potential to decrease application rates, increase efficacy, and reduce depletion of stratospheric 

ozone. The methyl bromide RED stated that buffer zone credits were additive but could not 

exceed 45 percent in total (i.e., 25 percent credit for listed tarps, 10 percent for > 3 percent 

organic content, and 10 percent for ≥ 27 percent clay content). 

Comments on the July 2008 RED 

Data were submitted since the July 2008 RED was issued that show greater reductions in 

emissions from the use of tarps and environmental conditions than what was determined in the 

July 2008 RED. In addition, the information submitted during the comment period indicated an 

 

13 Factors Which Impact Soil Fumigant Emissions - Evaluation for Use in Soil Fumigant Buffer Zone Credit Factor 

Approach, June 9, 2008, DP Barcode: 306857 
60 

additive effect in reducing emissions when multiple factors were combined. As a result, EPA 

has updated the buffer reduction credits and determined that the 45% credit cap should be 

increased to 80%. The new credits for individual factors and the cap on credits are detailed 

below. For details on the Agency’s analysis please see the May 14, 2009 memo; “Methyl 

Bromide (PC Code 053201), Chloropicrin (PC Code 081501), Dazomet (PC Code 035602), 

Metam Sodium and Potassium (PC Codes 039003 & 039002), MITC (PC Code 068103), DP 

Barcode 362369, Updated Health Effects Division Recommendations For Good Agricultural 

Practices and Associated Buffer Credits”, in the methyl bromide docket. 

 High barrier tarps 

Credits in the July 2008 RED 

The July 2008 RED determined that a 25% buffer credit for methyl bromide was 

appropriate for the following high barrier tarps: Bromostop® (1.38 mil), IPM Clear VIF (1.38 

mil), and Eval/Mitsui (1.38 mil). The Agency believed that the actual reduction for tarps could 

be higher for certain conditions but that a 25% credit was appropriate based on uncertainties in 

the available data. 

Comments on the July 2008 RED 

Since the RED was published, data have been submitted by the United States Department 

of Agriculture- Agricultural Research Service (USDA-ARS) and other organizations that have 

shown a greater reduction in emissions for a larger number of tarps. 

Credits for the Amended RED 

From these data, the Agency has increased the credit for certain tarps and increased the 

number of tarps that are given credits. The Agency has determined that the tarps tested can be 

divided into two groups based on results in the emissions tests mentioned above. The first group 

includes the Canslit Heatstrip Silver and Canslit Metalized high-barrier tarps, which will be 

given a buffer credit of 30%. The second group includes the Olefinas Embossed VIF, Klerks 

VIF, Pliant Blockade, Bromostop® (1.38 mil), Eval/Mitsui TIF (1.38 mil), Hytiblock 7 Black 

(0.00125”), XL Black Blockade (0.00125”), Hytibar (1.5 mil), and IPM Clear VIF (1.38 mil) 

high barrier tarps, which will be given a buffer credit of 60%. 

It is important to note, however, that when considering the credits selected for highbarrier tarps for each fumigant, a number of issues must be taken into account, including: 

different tarp and fumigant combinations result in different degrees of emission control; 

difficulty in determining the exact impact that high-barrier tarps have on emissions in a full field 

flux study unless a co-located field is also monitored in the same vicinity using a standard tarp; 

and the lack of a standard fumigant tarp testing procedure. 

The Agency is currently validating a standard fumigant tarp testing procedure, developed 

at USDA, that measures the mass transfer coefficients of tarps. The purpose of this research is to 

develop a standardized method of testing and rating permeability of tarps based on mass transfer 
61 

coefficients. From these results a permeability database and a standardized method for testing 

tarp permeability will be developed. The database will allow the Agency to evaluate potential 

buffer zone credits for additional tarps. In addition, the method can be used by other laboratories 

or tarp manufacturers to test the permeability of their tarps which could augment the number of 

tarps that receive buffer credits. For more details on USDA’s research, please refer to the 

Agency’s May 14, 2009 memo; “Methyl Bromide (PC Code 053201), Chloropicrin (PC Code 

081501), Dazomet (PC Code 035602), Metam Sodium and Potassium (PC Codes 039003 & 

039002), MITC (PC Code 068103), DP Barcode 362369, Updated Health Effects Division 

Recommendations For Good Agricultural Practices and Associated Buffer Credits”. 

 The Agency has also co-funded a grant with USDA-ARS to conduct several flux studies 

in the southeastern U.S. These studies will provide field data on the emission reduction potential 

of certain barrier films to further enhance EPA’s understanding of the emission reduction value 

of various agricultural films, and possibly support additional buffer reduction credits and an 

affordable and reliable hybrid field/lab test to evaluate the many barrier films available to 

growers. 

 Soil conditions 

Credits in the July 2008 RED 

Like high barrier tarps, inherent soil conditions (e.g., organic matter and soil type) do 

have an impact on fumigant emissions. However, while the use of high barrier tarp is a choice 

an applicator can make, soil conditions are factors essentially beyond a grower’s ability to 

change. Although a grower may not be able to manipulate organic matter or soil type, the 

Agency’s factors document indicates that soil conditions can reduce fumigant emissions, and is 

offering credits for these conditions where they exist. 

In the July 2008 RED, the Agency determined that a 10 percent buffer zone credit was 

appropriate if the application block contains soil with organic matter of greater than 3 percent 

and/or for clay content of at least 27 percent. This was based on the review of literature 

available before the July 2008 RED and modeling with the CHAIN_2D model. 

Comments on the July 2008 RED 

Since the July 2008 RED, information from the CMTF has been submitted that has 

allowed the Agency to reevaluate credits for soil organic matter. Analysis of peak emissions of 

chloropicrin in five studies with very similar soil factors, except for organic matter, concluded 

that peak flux was reduced by approximately 50% for soils that were composed of approximately 

1.5% organic matter compared to soils that were composed of approximately 0.5% organic 

matter. 

Credits for the Amended RED 

From these studies the Agency has determined that a credit can be given when applying 

methyl bromide in soils with certain levels of organic matter because the affect of organic matter 
62 

in soil on emission would be relevant to other fumigants in addition to chloropicrin. This is 

based on modeling with CHAIN2D that shows the impact of changes in organic content is not 

fumigant specific. A 10% credit will be given if methyl bromide is applied in soils with an 

organic matter range of >1% - 2%; a 20% credit for soils with an organic matter range of >2% - 

3%; and a 30% credit for soils with an organic matter range of >3%. No credit will be given for 

soils with less than 1% organic matter. 

The Agency has not received any new data that would result in changes to the credit for 

soil type. Therefore, the credit for clay content of greater than 27% will remain at 10%. 

 Soil moisture 

Credits in the July 2008 RED 

The Agency’s document; “Factors Which Impact Soil Fumigant Emissions - Evaluation 

For Use In Soil Fumigant Buffer Zone Credit Factor Approach. DP Barcode D306857 (6/9/08)”, 

reviewed data examining the effects of proper soil moisture levels prior to application on 

fumigant emissions. Through review of these data it was determined that soil moisture is a 

critical parameter to reduce emissions for certain fumigants. However, in the July 2008 RED, 

the Agency did not provide a credit for soil moisture because the Agency could not justify credits 

based on the available data. The Agency established mandatory GAPs for soil moisture 

conditions. 

Comments on the July 2008 RED 

The Agency received comments that buffer zone credits should be considered for soil 

moisture. For chloropicrin in particular, this fact was further supported by a chloropicrin field 

flux study (performed in Wasco, CA) recently submitted to the Agency by CMTF. This study 

was conducted at soil moisture field capacities in the 70-75% range. When this study was 

compared to previous studies done with the same application methods at much lower field 

capacities, in the 35-55% range, and all other factors being relatively equal, a 3-4 fold reduction 

in emissions was observed. 

Credits for the Amended RED 

There are currently not sufficient data available to provide a credit for field capacity for 

methyl bromide. However, the MBIP has committed to conducting a number of new field flux 

studies in 2009/2010 for methyl bromide. These studies may provide more information about 

the effect of soil moisture on methyl bromide emissions. Soil moisture credit/GAP decisions for 

methyl bromide may be revisited if necessary after review of these data. 
63 

 Potassium thiosulfate (KTS) and tarps 

Credits in the July 2008 RED 

EPA gave a 5% credit for applications of KTS. The KTS credit was based on a field 

study conducted by Dr. Husein Ajwa that indicated reductions in chloropicrin emissions when 

KTS is applied to the top of tarps after the fumigation. In the 2008 RED, if KTS was used in 

conjunction with one of the approved high barrier tarps, the buffer zone could be reduced by 

45%. If KTS was used with any other tarp, the buffer zone reduction credit was 5%. 

Comments on the July 2008 RED 

The Agency received comments that buffer zone credits should be greater than 5% for 

KTS. In addition, results from Ajwa’s 2007 and 2008 research were published by the California 

Strawberry Commission titled, “Reduce Fumigant Emissions Using Impermeable Film and 

Water Seal in Strawberry Raised Beds. California Strawberry Commission Annual Production 

Research Report 2007-2008,” show that applying a water seal/KTS combination over the bedded 

tarped field resulted in a reduction in the peak flux of chloropicrin and the total mass of 

chloropicrin lost. The water seal/KTS combination resulted in an approximate reduction of peak 

flux of 36% and total mass loss was reduced by approximately 20% at Salinas when compared to 

the standard tarp water seal scenario. The water seal/KTS combination resulted in an 

approximate reduction of peak flux of 32% and total mass loss was reduced by approximately 

10% at the Oxnard site when compared to the standard tarp scenario. Because laboratory data 

looking at all halogenated fumigants, including methyl bromide, methyl iodide, chloropicrin, and 

1,3-D (Wang et. al., 2000), support application of an emission reduction credit for KTS to these 

compounds, EPA has determined that a credit for KTS would also apply to methyl bromide. 

Credits for the Amended RED 

 Based on the data, the Agency determined that a conservative credit of 15% is 

appropriate for KTS when applied with 1⁄4 to 1⁄2 inch of water over a tarp. When used with one of 

the high-barrier tarps listed above, the 15% credit will be added to the tarp credit. For example if 

KTS is applied over Bromostop® (1.38 mil) which qualifies for a 60% credit, the total credit 

would be 75%. If KTS is used with another tarp, the credit is 15%.

 Water seals 

Credits in the July 2008 RED 

 The July 2008 RED did not give credits for the application of water seals. 

Comments on the July 2008 RED 

The Agency received comments that buffer zone credits should be considered for water 

seals. In addition, results from Ajwa’s 2008 research study published by the California 

Strawberry Commission titled; “Reduce Fumigant Emissions Using Impermeable Film and 
64 

Water Seal in Strawberry Raised Beds. California Strawberry Commission Annual Production 

Research Report 2007-2008,” show that that applying a water seal over the bedded tarped field 

resulted in a reduction in the peak flux of chloropicrin and the total mass of chloropicrin lost. 

The water seal resulted in an approximate reduction of peak flux of 30% and total mass loss was 

reduced by approximately 39% at Salinas when compared to the standard tarp scenario. 

Credits for the Amended RED 

Based on the data, the Agency determined that a conservative credit of 15% is 

appropriate when 1⁄4 to 1⁄2 inch of water is applied over a tarp. When used with one of the highbarrier tarps listed above, the 15% credit will be added to the tarp credit. For example when a 

water seal is applied over Bromostop® (1.38 mil) which qualifies for a 60% credit, the total 

credit would be 75%. If a water seal is used with another tarp, the credit is 15%. 

 Soil temperature 

A credit for soil temperature will currently not be given for methyl bromide based on its 

extremely high vapor pressure. As with soil moisture, a soil temperature credit for methyl 

bromide may be revisited if the MBIP studies discussed above provide more information around 

the effect of soil temperature on methyl bromide emissions. Based on review of available data 

with certain soil fumigants, increased soil temperature typically corresponds to increased 

fumigant emissions. This is not a factor that growers can manipulate in the field but is directed 

more at different regions in the country where low soil temperatures may be typical during the 

fumigation season.

 Buffer zone credit cap 

Credits in the July 2008 RED 

In the July 2008 RED, the Agency determined that credits would be additive. This 

meant, for example, that a 25% credit for a tarp could be added to a 10 % credit for organic 

matter and to a 10% credit for clay content to achieve a total credit of 45%. The Agency placed 

a limit, or “credit cap,” of 45% on the total size of the credit allowed for methyl bromide. 

Comments on the July 2008 RED 

During the comment period, the Agency received new data concerning a number of 

factors that impact fumigant emissions as well as a number of comments indicating that there 

should not be a cap on credits or that the cap should be raised. Some suggested that the 45% cap 

would be a disincentive to growers considering whether to adopt emission-reducing application 

methods. 

Credits for the Amended RED 

Upon review of the new data and public comments, the Agency has decided to raise the 

credit cap to 80%. The Agency has reviewed the new studies to evaluate the extent to which the 
65 

various factors that reduce emissions act independently, and has reconsidered the earlier studies. 

As a result of this evaluation, the Agency concludes that credits be additive up to a cap of 80% 

for all fumigants. This revised credit cap is based on studies that show a greater-than-50% 

reduction in emissions when two or more factors are combined. Further, EPA believes that 

increasing the credit cap to 80% will encourage adoption of emission reduction techniques, result 

in lower off-site fumigant concentrations, and will allow for reduced application rates for various 

tarps. 

 Buffer zone credit example 

Focusing on tomatoes grown in the Southeast as an example, the buffer zone distance for 

a 10 acre application block at a rate of 120 lbs ai/A is 185 feet without any credits (see last row 

in Table 9). If the grower uses Bromostop® (1.38 mil) high barrier tarp, the buffer zone can be 

reduced by 60%. The resulting buffer zone distance for this case is 74 feet. If the organic matter 

in the application block is two percent and Bromostop® (1.38 mil) high barrier tarp is used, the 

total credit would be 80% (60% for the tarp and 20% for organic content), and the resulting 

buffer zone distance would be 37 feet. 

 Other buffer zone credits considered 

The Agency’s revised document; “Methyl Bromide (PC Code 053201), Chloropicrin (PC 

Code 081501), Dazomet (PC Code 035602), Metam Sodium and Potassium (PC Codes 039003 

& 039002), MITC (PC Code 068103), DP Barcode 362369, Updated Health Effects Division 

Recommendations for Good Agricultural Practices and Associated Buffer Credits (5/14/09)”, 

reviewed several other factors such as field preparation and compaction. The Agency 

determined that those factors could not be used to justify credits based on the available data. 

However, EPA has established mandatory GAPs for these conditions. See the GAP section of 

this document for further discussion. 

The Agency has used the best available data to estimate potential methyl bromide 

bystander risks and has both quantitatively and qualitatively evaluated the impact of potential 

emission control measures on bystander risk. The Agency recognizes that there is substantial 

research being conducted by stakeholders to further quantify emission reductions. The Agency 

will consider such data in future decisions if new data become available. Such data may also 

support the Agency’s decisions on additional emission credits in the future. 

iv. Restriction for Schools and Other Difficult to Evacuate Sites 

Certain types of sites are difficult to evacuate should an incident occur. EPA determined 

that additional measures to reduce the potential need to evacuate these types of sites were 

necessary to reduce risk of exposure to occupants and address potential challenges associated 

with an accident. There were many comments on this measure including: requests to delete this 

requirement; suggestions to reduce the size of the restricted area; a proposal to use a scalable 

approach to calculate the distance; requests to define and refine the places included on this list so 

that facilities such as research universities were excluded; suggestions to shorten the duration of 

the requirement so applicators may be able to take advantage of weekends to fumigate; questions 
66 

about how to determine where these sites are located, and other suggestions to change the 

required measures. 

Based on a review of the comments, the Agency has retained this mitigation measure to 

ensure the protection goals are still achieved and encourage lower-emission application methods. 

This mitigation measure has been refined such that compliance is more effective in achieving the 

protection goal. Modifications to this requirement include: shortening the duration of the 

restriction so weekends may be used to fumigate near schools and day care centers; clarifying the 

types of schools that are covered by this requirement; removing the term “elder care facilities” 

from the list since many of the same facilities are included in the terms, “ assisted living 

facilities, nursing homes, and in-patient clinics;” and reducing the restricted area from 1⁄4 mile to 

1⁄8 mile for application blocks with less than 300 foot buffers. The 1⁄8 mile (660 feet) distance is 

more than twice the required buffer distance and remains protective of people who may be 

difficult to evacuate while reducing the potential challenges of complying with the restrictions 

for some users who may be fumigating in close proximity to these types of institutions. EPA has 

determined that these modifications achieve the same protection goals as the 2008 RED but 

provide additional clarity and flexibility that will enhance users’ ability to practically and 

effectively comply with the requirements. EPA also believes that reducing the restricted area for 

blocks with buffers less than 300 feet will provide an incentive for some users to adopt loweremission application methods or practices. The revised measures are summarized below. 

• “Difficult-to-evacuate” sites include schools (preschool to grade 12), state licensed day care 

centers, nursing homes, assisted living facilities, hospitals, in-patient clinics, and prisons. 

• No fumigant application with a buffer zone greater than 300 feet is permitted within 1⁄4 mile 

(1,320 feet) of the sites listed above unless the site is not occupied during the application and 

the 36-hour period following the application. 

• No fumigant application with a buffer zone of 300 feet or less is permitted within 1⁄8 mile 

(660 feet) of the sites listed above unless the site is not occupied during the application and 

the 36-hour period following the start of application. 

v. Posting 

Posting is an effective means of informing workers and bystanders about areas where 

certain hazards and restrictions exist. Current soil fumigant labels require treated areas to be 

posted and handlers are required to wear specific PPE when they are in a treated area. For buffer 

zones to be effective risk mitigation, bystanders, including agricultural workers in nearby areas, 

need to be informed of the location and timing of the buffer zone to ensure they do not enter 

designated areas. 

In addition to alerting bystanders, posting a buffer zone will help handlers determine 

where and when they are required to use PPE. As described in the Handler section, handlers 

working in treated areas or buffers during the buffer zone period must use label-specified PPE 

and meet other requirements under the WPS. Therefore, EPA has determined that to ensure the 

protectiveness of buffer zones for bystanders and handlers, the perimeter of the fumigant buffer 

zones must be posted. 
67 

Comments received in response to the July 2008 RED decisions recommended some 

changes to the posting requirements to make them easier to understand and implement. Based on 

EPA’s review and consideration of these comments, EPA has slightly revised the posting 

requirements and provided additional clarification as described below. 

EPA had included two exceptions for the buffer zone posting requirement. The first 

exception did not require posting in situations where the land 300 feet from the edge of the 

buffer was under the control of the property operator. Based on comments that this measure was 

too complicated and confusing this exception has been removed. There were also comments that 

the examples provided in the description of a physical barrier may lead to misinterpretation of 

the requirement. EPA agrees and believes that a performance standard is a more effective means 

of communicating the requirement. Therefore, to reduce the potential for confusion, the 

examples have been removed. 

In the 2008 RED, signs were required to be posted at usual points of entry and likely 

routes of approach to buffer zones. If there were no usual points of entry or likely routes of 

approach, then posting was required in the corners of buffer zones, and between the corners, so 

signs could be viewed from one another. Many comments expressed concern over the burden 

and potential confusion with the number of signs that may need to be posted and how many signs 

may need to be posted depending on the configuration of the field. EPA agrees that signs posted 

in areas where there is low likelihood of workers or others approaching or accessing the buffer 

provide little risk reduction, but can add substantially to the challenges of compliance. As a 

result, the Agency has revised the criteria for location of signs since the areas that are of most 

concern are those where people are most likely to enter (e.g., roads, footpaths), and at likely 

routes of approach such as the perimeter of a buffer that faces a housing development. 

Comments also indicated that the requirement to include certain application-specific 

information on the posted signs would make reuse of the signs more difficult and would also 

substantially increase the amount of time needed to prepare signs before posting. These 

comments stated that the primary purpose of signs is to communicate to bystanders the buffer 

zone locations. EPA generally agrees with these comments; therefore certain applicationspecific details on the posted signs, like the date and time of the fumigation and buffer zone 

restrictions, have also been reduced to allow the signs to be reused more easily. 

Comments also stated that the posting example included in the 2008 RED was confusing. 

Since the posting restrictions have been simplified by removing the distance criteria, the example 

has been removed from this document. There were no substantive comments suggesting a 

change to the exception for posting multiple contiguous blocks and no changes have been made 

in this Amendment. 

The revised posting requirements are listed below and have been included in the revised 

label table. 
68 

Requirements 

• Posting of a buffer zone is required unless there is a physical barrier that prevents 

bystander access to the buffer zone. 

• Buffer zone posting signs must: 

o Be placed at all usual points of entry and along likely routes of approach from areas 

where people not under the land operator’s control may approach the buffer zone. 

o Some examples of points of entry include, but are not limited to, roadways, 

sidewalks, paths, and bike trails. 

o Some examples of likely routes of approach are the area between a buffer zone and a 

roadway, or the area between a buffer zone and a housing development. 

• Buffer zone posted signs must meet the following criteria: 

o The printed side of the sign must face away from the treated area toward areas from 

which people could approach. 

o Signs must remain legible during entire posting period and must meet the general 

standards outlined in the WPS for text size and legibility (see 40 CFR §170.120). 

o Signs must be posted before the application begins and remain posted until the buffer 

zone period has expired. 

o Signs must be removed within 3 days after the end of the buffer zone period. 

o Registrants must provide generic buffer zone posting signs which meet the criteria 

above at points of sale for applicators to use. The Agency is requiring registrants to 

submit proposals for these materials through the data call-ins that will accompany this 

RED. 

Exception: If multiple contiguous blocks are fumigated within a 14-day period, the entire 

periphery of the contiguous blocks’ buffer zones may be posted. The signs must remain posted 

until the last buffer zone period expires and signs may remain posted up to 3-days after the 

buffer zone period for the last block has expired. 

Additional requirements for treated-area posting: 

• The treated area posted signs must remain posted for no less than the duration of the entry 

restricted period after treatment. 

• Treated area signs must be removed within 3 days after the end of the entry-restricted 

period. 

• Signs must meet the general standards in the WPS for placement, text size, and location 

(40 CFR §170.120). 
69 

Contents of Signs 

The treated area sign (currently required for 

fumigants) must state the following: 

-- Skull and crossbones symbol 

 

-- “DANGER/PELIGRO,” 

-- “Area under fumigation, DO NOT 

ENTER/NO ENTRE,” 

-- “Methyl Bromide Fumigant in USE,”

-- the date and time of fumigation, 

-- the date and time entry prohibition is lifted 

-- Name of this product, and 

-- name, address, and telephone number of the 

certified applicator in charge of the fumigation. 

The buffer zone sign must include the 

following: 

-- Do not walk sign 

-- “DO NOT ENTER/NO ENTRE,” 

-- “Methyl Bromide OR [Name of product] 

Fumigant BUFFER ZONE,” 

-- contact information for the certified 

applicator in charge of the fumigation 

2) Occupational Risk Mitigation 

i. Handler Definition 

Based on stakeholder comments provided during the Phase 5 comment period, the July 

2008 RED clarified fumigation tasks that meet EPA’s definition of handler activities, as 

currently defined in the WPS and on fumigant labels. During the post-RED comment period the 

Agency received some comments from stakeholders who were concerned that the Agency was 

redefining handlers. It was not the Agency’s intention to change the current definition. As a 

result, the Agency has slightly changed the language from the July 2008 RED so it is clear that 

the Agency is just clarifying the existing definition and not writing a new definition. Below is 

the revised language. 

The following activities are prohibited from being performed in the fumigant application 

block or surrounding buffer zone during the buffer zone period by anyone other than persons 

who have been appropriately trained and equipped as handlers in accordance with the 

requirements in the WPS (40 CFR Part 170), from the start of the application until the entryrestricted period ends. Those activities include those persons: 

• Participating in the application as supervisors, loaders, drivers, tractor co-pilots, 

shovelers, cross ditchers, or as other direct application participants (note: the application 

starts when the fumigant is first introduced into the soil and ends after the fumigant has 

stopped being delivered/dispensed to the soil); 

• Using devices to take air samples to monitor fumigant air concentrations; 

• Persons cleaning up fumigant spills (this does not include emergency personnel not 

associated with the fumigation application); 

• Handling or disposing of fumigant containers; 
70 

• Cleaning, handling, adjusting, or repairing the parts of fumigation equipment that may 

contain fumigant residues; 

• Installing, repairing, or operating irrigation equipment in the fumigant application block 

or surrounding buffer zone during the buffer zone period; 

• Entering the application site or surrounding buffer zone during the buffer zone period to 

perform scouting or crop advising, or monitoring tasks; 

• Installing, perforating (cutting, punching, slicing, poking), removing, repairing, or 

monitoring tarps: 

o until 14 days after application is complete if tarps are not perforated and removed 

during those 14 days, or 

o until tarp removal is complete if tarps are both perforated and removed less than 

14 days after application; or 

o until 48 hours after tarp perforation is complete if they will not be removed within 

14 days after application. 

 In addition to the above, persons outside the perimeter of the buffer zone who monitor 

fumigant air concentrations must also be trained and equipped as handlers in accordance with the 

requirements in the WPS (40 CFR Part 170). 

ii. Handler Requirements 

 Currently, methyl bromide labels require that all handlers involved in a methyl bromide 

application must be under the supervision of a certified applicator who may not necessarily be 

on-site. Since many incidents are caused by human error and equipment failure, EPA believes 

the presence of on-site trained personnel will help to reduce these risks. Therefore, to address 

these risks, the July 2008 RED required that a certified applicator maintain visual contact with 

any fumigant handler while the fumigant is being incorporated into the soil. The Agency also 

stated that the certified applicator supervising the fumigation may also perform fumigant handler 

tasks. 

 During the post-RED comment period the Agency received many comments that stressed 

the difficulty of implementing a requirement that mandates certified applicators to maintain 

visual contact with handlers. The commenters also indicated that for longer applications this 

requirement would be a significant burden. Other stakeholders stated that the Agency should 

modify the requirement to ensure that the certified applicator is on-site, while others commented 

EPA should require that all handlers are certified applicators, which would eliminate the need for 

direct handler supervision. 

The Agency has considered the comments and has determined that the revisions outlined 

below accomplish the same handler-protection goals as the July 2008 RED mitigation while 

somewhat reducing the burden on users. The revised language is: 

• For all applications, from the start of the application until the fumigant has stopped being 

delivered/dispensed into the soil, i.e., after the soil is sealed, the certified applicator must 

be at the fumigation site and must directly supervise all persons performing handling 

activities. 

• For fumigant handling activities that take place after the fumigant has been 

delivered/dispensed into the soil until the entry restricted period expires, the certified 
71 

applicator does not have to be on-site, but must have communicated in writing to the site 

owner/operator and handlers the information necessary to comply with the label and 

procedures described in the FMP (e.g., emergency response plans and procedures). 

The July 2008 RED also required that certified applicators complete a registrant 

administered methyl bromide training program within the preceding 12 months before they apply 

a methyl bromide product. The Agency is still requiring that certified applicators complete the 

registrant training; however, the Agency is now requiring that certified applicators successfully 

complete the training every 36 months. Please see Soil Fumigation Training for Applicators and 

Other Handlers section for further details. 

In addition to the certified applicator supervision requirement, the Agency also required 

in the July 2008 RED that a minimum of two WPS trained handlers were on-site during all 

fumigation handling activities. This mitigation measure addresses the concern that handlers 

could be overcome with fumigant vapors and be unable to leave the area while they are 

performing handler tasks. The Agency did receive some comments offering suggestions and 

others asking clarifying questions. The Agency has modified the language of the requirement for 

clarity; however, the mitigation measure itself is not changing. Comments related to this 

requirement are more fully addressed in the following document; SRRD’s Response to Post-RED 

Comments for the Soil Fumigants (May 27, 2009). The revised language for this mitigation 

measure is as follows: 

• For all fumigant handling tasks at least two handlers trained under the provisions of the 

WPS 40 CFR 170.230 must be present. 

iii. Respiratory Protection 

The Agency’s human health risk assessment indicates that inhalation risks exceed the 

Agency’s level of concern without respirator protection for many handler activities. The 

addendum to the April 10, 2007 risk assessment (DP 350818) contains additional risk 

characterization regarding the use of air monitoring and the role of chloropicrin’s warning 

properties for methyl bromide-chloropicrin products. The combination of air monitoring, 

chloropicrin warning properties and respiratory protection along with the use of GAPs, FMPs, 

and other mitigation measures is expected to reduce methyl bromide inhalation risks to levels 

that are below EPA’s level of concern. 

To address acute, short-, and intermediate-term inhalation risks the July 2008 methyl 

bromide RED required air monitoring with colorimetric tubes or other real-time monitoring 

devices every two hours as a means of determining when respirators may be needed. The tubes 

were required to have a sensitivity of at least 1 ppm for methyl bromide and 0.15 ppm for 

chloropicrin, which is the level that corresponds to early signs of exposure. If air samples 

indicated methyl bromide levels were above the Agency LOC (5 ppm), chloropicrin levels were 

above the Agency’s LOC (0.15 ppm), or if any handler experienced sensory irritation indicative 

of chloropicrin exposure, then handlers were required to wear air-purifying respirators. 
72 

The Agency’s decision to require respiratory protection only if certain triggers were 

reached took into consideration current label requirements14, the identified risks, and stakeholder 

comments that respirators are not necessary because (1) chloropicrin’s warning properties are 

sufficient to alert handlers if there are unsafe concentrations; (2) respirators inhibit 

communication which could increase the risk of an accident; and (3) in warm weather respirators 

can cause heat stress and other ailments. 

During the post-RED comment period, the Agency received several comments on the 

Respiratory Protection section. For methyl bromide, comments focused on the feasibility, 

reliability, and protectiveness of using colorimetric tubes due to the current sensitivity and 

accuracy of the tubes, and the cost of the tubes. Other comments stated that handlers should 

have the option of ceasing the application until air concentrations of methyl bromide and 

chloropicrin are less than the action level. Comments also suggested that tractor drivers do not 

need to be monitored if occupants are in an enclosed cab that meets certain specifications. 

After reviewing the comments, the Agency is adding a stop work option for formulations 

of methyl bromide with 80 % or less methyl bromide where handlers can leave the field and 

surrounding buffer zone in lieu of putting on a respirator. If handlers remain in the field, EPA 

has determined that respiratory protection requirements are still needed to mitigate risks if 

concentrations reach a certain level. However, EPA is revising the required procedures for 

determining when respirators must be used due to technological limitations of the monitoring 

devices that are currently available for field use. The Agency is aware of several commercial 

systems for monitoring methyl bromide and chloropicrin including colorimetric tubes from 

manufacturers including: Matheson/Kitagawa, Sensidyne, and Dräger. While these tubes have 

detection limits that are less than 0.15 ppm, the Agency has opted not to require monitoring with 

colorimetric tubes or other devices as a trigger to put on respiratory protection because EPA 

believes that these devices are not consistently reliable at fumigant concentrations at or just 

below 0.15 ppm, the Agency’s action level for chloropicrin. EPA’s action level is typically at 

the lower end of the range for which the devices are rated, in fact, some of these action levels are 

at or near the device’s detection limits. Additionally, colorimetric devices provide snapshot 

measurements of the environment in which individuals are working. In conditions that are likely 

to be more static (e.g., monitoring an indoor fumigation such as a grain mill or warehouse) it is 

likely that minute to minute changes in conditions would not be as great as those anticipated for 

the more dynamic conditions characteristic of outdoor field fumigation where exposure 

concentrations could shift because of weather changes or stratification in soil conditions across a 

single treated field. Furthermore, commenters’ experience indicates that handlers will likely 

experience early sensory irritation before the air samples show concentrations at or above the 

action level. As such, the Agency does not believe that initial monitoring to trigger the use of 

respirators significantly reduces handler risks. In addition EPA is aware that monitoring with 

these devices adds significant costs to fumigations, please see (Analysis of Soil Fumigant Risk 

Management Requirements using Geographic Information Systems: Case Studies based on a 

Forest Seedling Nursery (DP Barcode 363546)) for more details. EPA is also concerned that 

monitoring with devices that are not reliable could cause handlers to believe that concentrations 

 

14 Current methyl bromide labels require respirators when the air concentration exceeds 5 ppm for methyl bromide 

and 0.1 ppm for chloropicrin but do not require that any measurements be taken. 
73 

are below the action level despite other indications such as eye irritation. As a result, the Agency 

is removing the initial monitoring requirement. 

EPA does believe, however, that monitoring devices that are currently available will 

generally be reliable at higher concentrations of chloropicrin and that there is high value in air 

monitoring using currently available devices in certain situations. As a result, EPA is 

maintaining the monitoring requirement once use of respirators has been triggered and 

respirators are being worn. This will enable handlers to detect concentrations that would exceed 

the upper working limit of the respirator. Additionally monitoring will still be required to help 

enable handlers to determine if concentrations have decreased and whether it is safe to either 

remove respirators or to resume the application if the fumigator has opted to cease the 

application rather than have handlers wear respirators. 

The Agency is modifying the procedures for respiratory protection because of 

technological limitations of currently available devices. However, the Agency does believe that 

quantitative air monitoring would enhance worker safety if the appropriate technology were 

available. Some equipment manufacturers have indicated interest in developing devices that 

would be more functional and reliable for field fumigation applications (e.g., badge-type 

monitors). EPA encourages such efforts and plans to stay abreast of developments and 

improvements in monitoring devices and will consider this issue again in Registration Review or 

sooner should such monitors become available in the short term. 

Respiratory Requirements 

Based on the Agency’s review of the comments as described above in the Respiratory 

Protection section, EPA has amended the requirements that trigger the need for respiratory 

protection. In addition to the revised respiratory protection requirements below, the Agency 

believes that GAPs, FMPs, and other mitigation measures will reduce inhalation risks to 

concentrations below the EPA’s level of concern. There are two regimens which differ based on 

the concentration of chloropicrin that is formulated with methyl bromide. Certain criteria apply 

if applications involve less than or equal to 80 percent methyl bromide and other criteria apply if 

applications involve greater than 80 percent methyl bromide relative to the amounts of 

chloropicrin used. See the Amended Reregistration Eligibility Decision for Chloropicrin for 

detailed information regarding the chloropicrin action levels. 

As the amount and percentage of chloropicrin applied increases, there is a greater likelihood 

handlers will immediately experience sensory irritation if exposed to air concentrations above the 

Agency’s level of concern. Respiratory protection is required whenever handlers experience 

sensory irritation. 

The EPA assumes that air-purifying respirators have a protection factor of between 10 

and 50 depending on whether a half-face or full-face respirator is used. The current upper limit 

of air-purifying respirator cartridges available for methyl bromide is 5 ppm (see respirator 

cartridges used with air purifying respirators section below for further details). A self-contained 

breathing apparatus (SCBA) has a protection factor of 1,000 but must only be used for brief 

durations to take actions to reduce air concentration levels or in case of an emergency.
74 

The following procedures must be followed for all formulations with 80 % or less 

methyl bromide:

• If at any time any handler experiences sensory irritation (tearing, burning of the eyes or 

nose) then either: 

o An air-purifying respirator (APR) must be worn by all handlers who remain in the 

application block and surrounding buffer zone, or 

o Operations must cease and handlers not wearing respiratory protection must leave 

the application block and surrounding buffer zone. 

• Handlers can remove respirators or resume operations if two consecutive breathing-zone 

samples taken at the handling site at least 15 minutes apart show that levels of methyl 

bromide have decreased to less than 1 ppm and levels of chloropicrin have decreased to 

less than 0.15 ppm, provided that handlers do not experience sensory irritation. Samples 

must be taken where the irritation was first experienced. 

• When respirators are worn, air monitoring samples must be collected at least every 2 

hours in the breathing zone of a handler performing a representative handling task. 

• If at any time: (1) a handler experiences any sensory irritation when wearing a respirator, 

or (2) a methyl bromide air sample is greater than 5 ppm or a chloropicrin air sample is 

greater than or equal to 1.5 ppm, then all handler activities must cease and handlers must 

be removed from the application block and surrounding buffer zone. If operations cease 

the emergency plan detailed in the FMP must be implemented. 

• Handlers can resume work activities without respiratory protection if two consecutive 

breathing-zone samples taken at the handling site at least 15 minutes apart show levels of 

methyl bromide have decreased to 1 ppm and levels of chloropicrin have decreased to 

less than 0.15 ppm, provided that handlers do not experience sensory irritation. 

• During the collection of air samples an air-purifying respirator must be worn by the 

handler taking the air samples. Samples must be taken where the irritation is first 

experienced. 

• Work activities may resume if the following conditions exist provided that the 

appropriate respiratory protection is worn: 

o two consecutive breathing zone samples for methyl bromide taken at the handling 

site at least 15 minutes apart must be less than 5 ppm, 

o two consecutive breathing zone samples for chloropicrin taken at the handling site 

at least 15 minutes apart must be less than 1.5 ppm, 

o handlers do not experience sensory irritation while wearing the APR, 

o cartridges have been changed, and 

o during the collection of air samples an air-purifying respirator must be worn by 

the handler taking the air samples. Samples must be taken where the irritation is 

first experienced. 

The following procedures must be followed for all formulations with more than 80 % 

methyl bromide: 

If the fumigant applied contains greater than 80 percent methyl bromide (e.g., 98:2 

formulations), air purifying respirators must be worn during all handler tasks and the following 
75 

air monitoring procedures must be followed to ensure that the upper protection limit of the 

respirator plus respirator cartridge is not exceeded (i.e., 5 ppm for methyl bromide and 1.5 ppm 

for chloropicrin): 

• Air monitoring samples for methyl bromide and chloropicrin must be collected at least every 

hour in the breathing zone of a handler performing a representative handling task. 

• If at any time (1) a handler experiences any sensory irritation while wearing a respirator, or 

(2) any air sample is greater than or equal to 5 ppm for methyl bromide, or (3) any air sample 

is greater than or equal to 1.5 ppm for chloropicrin, then all handler activities must cease and 

handlers must be removed from the application block and surrounding buffer zone until 

corrective action has been taken. 

• In order to resume work activities: 

° Two consecutive air samples for methyl bromide and chloropicrin taken in the treatment 

area at least 15 minutes apart must be less than 5 ppm for methyl bromide and less than 

1.5 ppm for chloropicrin. 

° During the collection of samples an air purifying respirator must be worn by the handler 

taking air samples. 

 Hot gas tarped applications 

During hot gas applications in greenhouses, the fumigant must be introduced from 

outside of the greenhouse. For outdoor hot gas applications, the fumigant must be introduced 

from outside of the application block. Once the fumigation has started, if entry into the 

greenhouse enclosure or the outdoor treatment area is required to perform a function necessary 

for the application, a SCBA must be worn. Handlers must wear SCBA to reenter the 

greenhouse/treated areas for a minimum of 48 hrs after the fumigant has stopped being 

delivered/dispensed to the soil. 

 Deep probe injection 

No exposure data were provided for using handheld equipment to apply methyl bromide. 

This method of application is done primarily with 98:2 formulations. The methyl bromide risk 

assessment indicates that the fumigation of tree holes was one of the factors identified in the 

more serious incident cases. Since air purifying respirators may only be used for concentrations 

up to 5 ppm, EPA is requiring that SCBA be worn when applying methyl bromide with handheld 

equipment. 

Figure A provides an illustration of the requirements when handlers cease operations. Figure B 

provides an illustration of the requirements when handlers put on a respirator. 
76 

Figure A. Requirements for when handlers should cease operations. 

Handler activity begins. Handlers 

are NOT wearing APRs. 

Sensory Irritation 

Certified applicator in charge 

decides to cease operations rather 

than continue with respirators. 

Handlers must stop work and 

leave application block and buffer 

zone. 

If 2 samples taken at least 15 minutes 

apart (by a handler wearing an APR) 

show concentrations are less than 1.0 

ppm (methyl bromide) and less than 0.15 

ppm (chloropicrin) and NO sensory 

irritation, then

Resume operations. 
77 

Figure B. Requirements for when handlers should put on a respirator. 

Handler activity begins. Handlers 

are NOT wearing APRs. 

Sensory Irritation 

Certified applicator in charge 

decides to continue operations. 

All handlers in the application 

block and buffer zone put on an 

APR. Air monitoring program 

begins.

Feel irritation through APR, OR 

monitoring indicates concentrations 

above 5 ppm (methyl bromide) and 

1.5 ppm (chloropicrin). 

Handlers must stop work and 

leave application block and buffer 

zone. 

If, 2 consecutive samples taken at least 

15 minutes apart, by a handler wearing 

an APR are above 1 ppm (methyl 

bromide) and 0.15 ppm (chloropicrin) 

BUT below 5 ppm (methyl bromide) and 

1.5 ppm (chloropicrin), no sensory 

irritation is felt, and the cartridge is 

changed, then 

If 2 consecutive samples taken at 

least 15 minutes apart, by a 

handler wearing an APR, are less 

than 1 ppm (methyl bromide) and 

0.15 ppm (chloropicrin) and NO 

sensory irritation, then

Resume operations wearing an 

APR. Air monitoring continues. 

Resume operations without an 

APR or remove respirator. 
78 

Respiratory Protection Equipment 

The purpose of this section in the July 2008 RED was to establish general conditions and 

requirements for respiratory protection equipment. Below is a summary of what was included in 

the July 2008 RED. 

• The Agency required half-face respirators with organic vapor cartridges when respirators 

are necessary. In the RED EPA noted that although currently there are no APR cartridges 

certified by the Mine Safety and Health Administration-National Institute for 

Occupational Safety and Health (MSHA-NIOSH) for protection against chloropicrin 

specifically, NIOSH/OSHA does recommend respirators with organic vapor cartridges 

for chloropicrin use. EPA also stated that it would consider other APR-cartridge 

combinations, provided written certification of their efficacy against chloropicrin is 

submitted to the Agency. 

• EPA assumes half-face respirators have a protection factor of 10, therefore these 

respirators are protective up to methyl bromide concentrations of 5 ppm; and if 

concentrations exceed 5 ppm operations must cease. 

• SCBA has a protection factor of 1,000, but, due to practical limitations, SCBA should 

only be used for short durations. 

EPA is making revisions to the requirements above taking into consideration the 

comments and the revisions to the Respiratory Requirements section. Since the Agency is 

relying on the warning properties of chloropicrin to indicate when an air-purifying respirator 

must be worn, the Agency does not believe that a half-face respirator would be appropriate 

because the handler would still experience eye irritation if a half-face respirator is worn. 

Therefore, EPA has determined that when handlers opt to continue operations when the action 

level for respiratory protection is triggered (i.e., sensory irritation is recognized), handlers must 

wear a full-face respirator. 

The Agency received additional comments regarding the cartridge recommendations, 

SCBA use, and the respirator protection factor. EPA is providing a clarification to address the 

concerns brought up in the comments. This was the Agency’s intention in the July 2008 RED. 

Others remarked that use of goggles should be prohibited. The Agency agrees with the 

comments regarding goggles and it was not EPA’s intention to imply a change in current label 

language with regard to closed goggles in the July 2008 RED. For more detailed responses on 

the above comments please see Methyl Bromide, 1,3-Dichloropropene, Chloropicrin, Dazomet, 

Metam Sodium/Potassium, MITC: Health Effects Division (HED) Component of Agency 

Response To Comments On 2008 Reregistration Eligibility Documents (Date May 14, 2009). 

 As a result of the changes discussed above the amended requirements are listed below: 

• The Agency is requiring full-face respirators with organic-vapor cartridges when 

respirators are necessary. 

• If methyl bromide concentrations exceed 5 ppm operations must cease. 
79 

Tarp Repair 

The July 2008 RED required handlers to wear APRs if they perform tarp repair 

operations before the entry-restricted period has ended. The requirements were different from 

other handling activities because the duration of tarp repair activities was believed to be shorter 

than other handling tasks and therefore tarp repair activities would not trigger the initial 

monitoring requirement. Upon consideration of comments the Agency received on this 

requirement, which are addressed in detail in Methyl Bromide, 1,3-Dichloropropene, 

Chloropicrin, Dazomet, Metam Sodium/Potassium, MITC: Health Effects Division (HED) 

Component of Agency Response To Comments On 2008 Reregistration Eligibility Documents

(Date May 14, 2009)., EPA has determined that respiratory protection for tarp repair activities 

should be handled consistently with other handler activities, i.e., handlers repairing tarps are not 

required to wear respirators unless sensory irritation is experienced. Additionally, the Agency 

believes that tarp repair like other handling activities described above would benefit from the 

development of sensitive monitoring devices to reliably inform handlers if and when 

concentrations are above the action level for respiratory protection. EPA will reevaluate this 

measure during Registration Review or sooner if such devices are available in the short term. 

Respirator fit testing, training, and medical qualification 

To ensure that respirators are mitigating inhalation risk, the July 2008 RED respirator 

requirements included fit testing, respirator training, and an annual medical evaluation. Without 

these requirements, it is unclear whether the reduction in inhalation exposure that is assumed by 

the use of respirators will be achieved. 

During the comment period the Agency received a variety of comments ranging from full 

support of the requirement, to comments about the cost and time burden associated with fittesting, training, and medical exams. The Agency also received several comments regarding the 

details of this requirement, for example, some commenters questioned who conducts the fittesting and medical exam and what the medical exam entails. Detailed responses to these 

comments are included in the following document, SRRD’s Response to Post-RED Comments 

for the Soil Fumigants (May 27, 2009). 

While EPA recognizes that there is a cost associated with the fit-testing, training, and 

medical exam requirements, the Agency still believes these are necessary to ensure respirators 

perform as intended. Also note that, in response to suggestions from several fumigators, EPA is 

now allowing fumigators the option to cease operations and have handlers leave the application 

block and surrounding buffer zone in lieu of wearing a respirator and continuing fumigation 

activities. Only handlers who will wear a respirator must be fit-tested, trained, and medically 

examined. For fumigators who exercise the cease operations option, the Agency believes that 

this revision will reduce the cost associated with the respirator requirement, while maintaining 

the same level of protection for the handlers that wear respirators. The following revised 

language takes into account the new cease operations option and must be added to product 

labels: 
80 

“Employers must also ensure that any handler who uses a respirator is: 

• Fit-tested and fit-checked using a program that conforms to OSHA’s requirements (see 

29CFR Part 1910.134) 

• Trained using a program that confirms to OSHA’s requirements (see 29CFR Part 1910.134) 

• Examined by a qualified medical practitioner to ensure physical ability to safely wear the 

style of respirator to be worn. A qualified medical practitioner is a physician or other 

licensed health care professional (PLHCP) who will evaluate the ability of a worker to wear a 

respirator. The initial evaluation consists of a questionnaire that asks about medical 

conditions (such as a heart condition) that would be problematic for respirator use. If 

concerns are identified, then additional evaluations, such as a physical exam, might be 

necessary. The initial evaluation must be done before respirator use begins. Handlers must 

be reexamined by a qualified medical practitioner at least annually or if their health status or 

respirator style or use-conditions change.” 

Respirator cartridges used with air purifying respirators 

Currently, there are no air-purifying respirator cartridges certified by the Mine Safety and 

Health Administration-National Institute for Occupational Safety and Health (MSHA-NIOSH) 

for protection against methyl bromide. While NIOSH does not have a test procedure to certify 

air-purifying filters for protection against methyl bromide, the 3M 60928 is a NIOSH-approved 

combination organic vapor/acid gas chemical cartridge/P100 particulate filter, this combination 

cartridge is recommended by 3M for use against radioiodine or methyl bromide at ambient 

concentrations up to 5 ppm and for not more than one shift. For further details on the 3M’s 

recommendations, see February 2001 “3M Technical Data Bulletin #146 Use Recommendations 

for 3M 60928 Cartridge/Filter”15. The EPA has decided that the use of 3M air purifying 

respirators (APRs) equipped with 3M Model 60928 Organic Vapor/Acid Gas/P100 cartridges 

may be used for concentrations up to 5 ppm, and not for more than one work shift per day. 

Respirator APR-cartridge combinations for other manufacturers will also be considered by the 

Agency, provided written certification of their efficiency against methyl bromide is provided. 

The maximum chloropicrin air concentration that handlers may be exposed to without 

respiratory protection is 0.15 ppm. When wearing an air purifying respirator with organic vapor 

cartridges, the maximum chloropicrin air concentration allowed is 1.5 ppm. For further details 

regarding chloropicrin respiratory protection requirements, see the chloropicrin RED 

(chloropicrin docket EPA-HQ-OPP-2007-0350). 

 

15 http://multimedia.mmm.com/mws/mediawebserver.dyn?6666660Zjcf6lVs6EVs666BraCOrrrrQ- 
81 

Respirator Availability 

The July 2008 RED required that every handler had the appropriate respiratory protection 

equipment available. This requirement has been slightly modified as a result of the cease 

operations option. The new language requires that the handler’s employer must confirm and 

document in the FMP that an air-purifying respirator and cartridge is immediately available for 

each handler who will wear one. The Agency is requiring that at minimum two handlers have 

the appropriate respirator and cartridges available and that these handlers are fit-tested, trained, 

and medically examined. 

Air-Rescue Device Availability 

EPA slightly altered the air-rescue device availability language from the July 2008 RED 

to include that the device is not only on-site, but also ready to use. This change was made to 

clarify the Agency’s previous requirement, and the following language must be added to product 

labels: 

• The fumigation handler employer must confirm and document in the FMP that at least 

one air rescue device (e.g., SCBA) is on-site and is ready for use in case of an 

emergency. 

iv. Tarp Perforation and Removal 

The Agency’s risk assessment indicates that there is a risk concern for handlers during 

the perforation (cutting, poking, punching, or slicing) and removal of tarps, and notes potential 

for increased risk when high barrier tarps are used. To address these risks EPA required the 

following mitigation in the July 2008 RED: 

• Tarps cannot be perforated until a minimum of 5 days (120 hours) after fumigation was 

complete. 

• Tarps cannot be removed until 24 hours after tarp perforation is complete. 

• If tarps are not removed after perforation, planting cannot start until 48 hours after 

perforation is complete. 

• If tarps are left intact for at least 14 days after the fumigation is complete then planting 

can take place as tarps are being perforated. 

• Broadcast tarps could be removed before 5 days if adverse weather compromised the 

integrity of the tarp provided that at least 48 hours had passed since the fumigation was 

completed, the buffer zone was extended until 24 hours after the tarp removal was 

complete, and untreated areas in the application block are not treated for at least 24 hours 

after tarp removal is complete. 

• Tarp perforation must be done using mechanical methods. 

• Each broadcast tarp panel must be perforated using a lengthwise cut. 

During the post-RED comment period the Agency received comments on the tarp 

perforation and removal requirements. In particular the Agency received comments on: the 

adequacy of the 5 day requirement for high barrier tarps to protect workers; the feasibility of 

leaving tarps down for 5 days in areas that use seepage irrigation for flood prevention; the 

difficulty implementing the 24 hour period between tarp perforation and removal; and concerns 
82 

regarding the weather condition exceptions, mechanical perforation, and broadcast panel 

perforation. 

 There is some uncertainty regarding potential risks if high barrier tarps are perforated 

after 5 days. This is because worker exposure data used in the risk assessments are generally 

based on what has been the industry standard tarping technology, i.e., low or high density 

polyethylene tarps, typically with higher application rates and no significant emphasis on using 

the GAPs as defined in the RED. Data indicate that high barrier tarps are effective measures to 

reduce fumigant emissions (See Factors Which Impact Soil Fumigant Emissions - Evaluation 

For Use In Soil Fumigant Buffer Zone Credit Factor Approach. DP Barcode D306857 (6/9/08) 

and Methyl Bromide (PC Code 053201), Chloropicrin (PC Code 081501), Dazomet (PC Code 

035602), Metam Sodium and Potassium (PC Codes 039003 & 039002), MITC (PC Code 

068103), DP Barcode 362369, Updated Health Effects Division Recommendations for Good 

Agricultural Practices and Associated Buffer Credits (5/14/09)). While this reduction decreases 

the risk to bystanders, it could increase the risk to handlers perforating or removing tarps because 

more fumigant could be trapped between the soil surface and the tarp—currently California 

Department of Pesticide Regulation (CDPR) prohibits the use of methyl bromide with certain 

high barrier tarps due to worker concerns. 

Based on CDPR’s prohibition and stakeholder’s comments, EPA considered requiring a 

longer interval such as 10 days before allowing high barrier tarps to be perforated. However, 

EPA was concerned that adding such a requirement could discourage fumigators from using high 

barrier tarps which potentially allow for lower application rates and reduce bystander risk 

associated with offgassing. New studies currently underway which involve use of high barrier 

tarps may enable EPA to refine estimates of handler risk in the future. EPA will consider these 

data during Registration Review, or sooner as the information becomes available. 

Since the Agency has designed the mitigation measures to work together and believes 

that measures to address handler risks are likely to protect these handlers when the reduced rates 

are considered in conjunction with other measures such as respiratory protection, GAPs, FMPs, 

and training, EPA is not increasing the number of days before high barrier tarps can be 

perforated. 

In the comment period EPA learned from stakeholders that leaving the tarps on for 5 days 

would pose problems for current flood prevention activities. According to the comment, for 

flood prevention fields must be properly drained. To ensure proper drainage, tarps must be 

manually cut, soil removed, and then tarps retucked. The Agency understands that the 5 day 

requirement before tarps can be perforated and the restriction on manual tarp perforation would 

be difficult for this situation and the Agency has added language to address this situation. 

During earlier comment periods EPA heard from various stakeholders that windy 

conditions sometimes caused tarps to blow off fields and create other hazards, e.g., to motorists 

on nearby roadways. As a result, in the July 2008 RED the Agency provided an exception to 

allow tarps to be removed after 48 hours under adverse weather conditions. During the postRED comment period EPA received comments that this exception did not fully address the issue 

since the mitigation required waiting a minimum of 48 hours after fumigation but tarps could 
83 

blow of fields sooner than that. Commenters also said waiting 24 hours between tarp perforation 

and removal and the requirement to cut every broadcast tarp panel added to the potential for tarps 

to blow off fields and create other hazards: once tarps are cut they are prone to blowing off 

when windy conditions occur. To decrease the potential of tarps blowing off commenters also 

suggested that the Agency add flexibility to the 24 hour requirement by giving tarp removers the 

option to remove tarps 2 hours after tarp perforation if monitoring indicated levels below the 

Agency’s LOC. Commenters also suggested that every 1-3 tarp panels should be cut based on 

the professional judgment of the handler. 

Upon review of the comments the Agency agrees that the mitigation should be revised 

somewhat to allow for tarp removal at any time if the tarp is no longer performing its intended 

function and it is creating other types of risk. Therefore, EPA is revising the exception outlined 

in the RED to address these comments. EPA notes that handlers undertaking these tasks must 

follow the respiratory protection procedures detailed in the Respiratory Protection section; this 

change still provides handler protection while reducing the unintended consequences of tarps 

creating other hazards. 

The Agency believes cutting every panel allows the fumigant trapped beneath each panel 

to offgas before the tarp is removed. If each panel is not cut, it is not likely that necessary offgassing can take place to reduce risks to handlers removing tarps. The Agency understands that 

the main concern for not cutting every panel is due to the potential for tarps to blow off and has 

determined that this concern is best addressed by modifying the 24-hour wait period. Tarps may 

be removed 2 hours after tarp perforation is complete provided that tarp removers follow the 

procedures set forth in the Respiratory Protection section; therefore the risk to handlers will not 

increase as a result of this modification. 

The Agency received comments supporting the requirement for mechanical tarp 

perforation, though other commenters stated that for some situations mechanical cutting is not 

feasible. Examples cited included at the start of a row when a mechanical device such as an 

ATV will be used to cut the tarps on the field, during flood prevention activities and for small 

fields. Based on comments, EPA believes these are necessary short-duration activities. Provided 

the respiratory protection procedures for handlers are followed, these activities would not 

increase the risk to handlers. With regard to small fields where mechanical cutting is not 

feasible, the Agency considered the duration of the activity and the respiratory protection 

considerations and will permit manual perforation only for application blocks that are 1 acre or 

less in size. 

As a result of the Agency’s review and consideration of comments, the following 

summarizes the revised mitigation measures to address inhalation risks from tarp perforation and 

removal activities: 

• As described in the Handler Definition section (link the document) tarp perforators and 

removers are considered handlers for a specified duration and every handler must adhere 

to the respiratory protection procedures outlined in the Respiratory Protection section. 

• Tarps must not be perforated until a minimum of 5 days (120 hours) have elapsed after 

the fumigant injection into the soil is complete (e.g., after injection of the fumigant 

product and tarps have been laid or after drip lines have been purged and tarps have been 
84 

laid), unless a weather condition exists which necessitates the need for early perforation 

or removal. (See Early Tarp Removal for Broadcast Applications Only and Early Tarp 

Perforation for Flood Prevention Activities sections below.) 

• If tarps will be removed before planting, tarp removal must not begin until at least 2 

hours after tarp perforation is complete and two air monitoring samples are less than 1 

ppm methyl bromide. (If two air monitoring samples have methyl bromide levels 

between 1 ppm and 5 ppm, then respirator protection is required before tarp removal can 

begin.) 

• If tarps will not be removed before planting, planting or transplanting must not begin 

until at least 48 hours after the tarp perforation is complete. 

• If tarps are left intact for a minimum of 14 days after fumigant injection into the soil is 

complete, planting or transplanting may take place while the tarps are being perforated. 

• Each tarp panel used for broadcast fumigation must be perforated. 

• Tarps used for fumigations may be perforated manually ONLY for the following 

situations: 

o At the beginning of each row when a coulter blade (or other device which 

performs similarly) is used on a motorized vehicle such as an ATV. 

o In fields that are 1 acre or less. 

o During flood prevention activities. 

• In all other instances tarps must be perforated (cut, punched, poked, or sliced) only by 

mechanical methods. 

• Tarp perforation for broadcast fumigations must be completed before noon. 

• For broadcast fumigations tarps must not be perforated if rainfall is expected within 12 

hours. 

• Early Tarp Removal for Broadcast Applications Only: 

o Tarps may be removed before the required 5 days (120 hours) if adverse weather 

conditions have compromised the integrity of the tarp, provided that the 

compromised tarp poses a safety hazard. Adverse weather includes high wind, 

hail, or storms that blow tarps off the field and create a hazard, e.g., tarps blowing 

into power lines and onto roads. A compromised tarp is a tarp that due to an 

adverse weather condition is no longer performing its intended function and is 

creating a hazard. 

o If tarps are removed before the required 5 days have elapsed due to adverse 

weather, the events must be documented in the post fumigation summary section 

of the FMP. 

• Early Tarp Perforation for Flood Prevention Activities 

o Tarp perforation is allowed before the 5 days (120 hours) have elapsed. 

o Tarps must be immediately retucked and packed after soil removal. 

v. Entry Prohibitions 

Current methyl bromide labels allow reentry to the treated field by workers 48 hours after 

application. The methyl bromide risk assessment indicates that risks exceed EPA’s LOC for 

workers entering fields after 48 hours. However, the risk assessment indicates that extending 

this period decreases workers’ risks. In addition, stakeholder comments prior to the July 2008 
85 

RED indicated that non-handler entry to perform post-application (i.e., non-handler) tasks is 

generally not needed for at least 10 to 14 days following the completion of the application. 

Due to the volatile nature of methyl bromide and the potential for worker exposure, in the 

July 2008 RED the Agency restricted entry into the treated area by anyone other than a properly 

trained and protected handler. This restriction differs from Restricted Entry Intervals (REIs) that 

are currently required for most conventional pesticides where dermal exposure is the primary 

pathway of exposure. Under the WPS, exceptions allow certain tasks to take place before the 

REI has expired as long as dermal contact with treated surfaces will be limited; however for 

fumigants where inhalation exposure is the primary risk concern, entry to a treated area is further 

restricted. 

During the post-RED comment period the Agency received some comments that 

expressed concern that extending the entry-restricted period for fumigants could prevent certain 

important activities from taking place, contrary to the comments received during earlier 

comment periods. Based on discussions with stakeholders, EPA’s review of public comments, 

and the risks identified in EPA’s risk assessment, EPA does not believe any change to the entryrestricted period is warranted. EPA’s review of comments indicates that extending the entryrestricted period to protect workers will not have a substantial impact on agricultural operations. 

Therefore, the Agency is not making any changes to this section of the July 2008 RED. The 

mitigation is listed below. 

EPA believes that risks will not exceed the Agency’s LOC provided entry (including 

early entry that would otherwise be permitted under the WPS) by any person – other than a 

correctly trained and PPE-equipped handler who is performing a handling task – is prohibited 

from the start of the application until: 

• 5 days (120 hours) after application has ended for untarped applications (see Figure C), 

or 

• after tarps are perforated and removed if tarp removal is completed less than 14 days after 

application (see Figure D), or 

• 48 hours after tarps are perforated if they will not be removed prior to planting (see 

Figure E), or 

• 5 days (120 hours) after application is complete if tarps are not perforated and removed 

until 14 days after the application is complete (see Figure F). 

Figures C, D, E, and F provide illustrations of tarp perforation/removal and entry prohibition 

mitigation required for various methyl bromide applications. The intervals depicted are the 

minimum that must be followed. 
86 

Figure C. Untarped Applications 

48 hours

Buffer Zone 

Period 

Begins 

Entry 

Restricted 

Period 

Begins 

Application 

Ends 

Buffer Zone 

Period Ends 

Entry 

Restricted 

Period Ends 

Application 

Begins 

5 days (120 hours)
87 

Figure D. Tarp Broadcast Applications (tarps removed before planting) 

Tarp Perforation Begins 

Buffer Zone Period Begins Entry Restricted Period Begins 

Application Ends 

Buffer Zone Period Ends 

Tarp Perforation Ends 

Entry RestrPerio

Tarp Removal Begins 

Tarp RemovaEnds 

Application Begins 

2 hours 

48 hours 

5 days (120 hours) 
88 

Figure E. Tarp Bed Applications (Tarps not removed before planting) 

Application Begins 

Buffer Zone Period Begins Entry Restricted Period Begins 

Application Ends 

Buffer Zone Period Ends 

Tarp Perforation Begins 

Tarp Perforation Ends 

Planting Can Begin Entry Restricted Period Ends 

48 hours 

48 hours 

5 days (120 hours) 
89 

Figure F. Tarp Bed/Broadcast Applications (Tarps are not perforated until 14 days after 

application) 

3) Other mitigation 

Below are requirements for FMPs, GAPs, emergency preparedness and response, notice 

to state lead agencies, training, and community outreach that the Agency concludes are needed to 

mitigate risks and the likelihood of incidents caused by human error, equipment failure, and 

weather events such as temperature inversions. 

i. Good Agricultural Practices (GAPs) 

Since the application methods and work practices of fumigators have direct impacts on 

the amount of fumigant applied and emitted, the Agency determined that labeling should require 

proven practices that will reduce risks to handlers, bystanders, and the environment. Registrants, 

applicators, growers, and other stakeholders have consistently reported to the Agency that GAPs 

are a key mitigation measure to reduce the amount of fumigants applied and fumigant emissions. 

The purpose of this section in the July 2008 RED was to specify GAPs that were required for soil 

applications of methyl bromide. The practices specified contribute to reducing emissions and 

thereby are expected to reduce potential for worker and bystander exposures. 

Application 

Begins 

Buffer Zone 

Period 

Begins 

Entry 

Restricted 

Period 

Begins 

Application 

Ends 

Buffer Zone 

Period Ends 

Entry 

Restricted 

Period Ends 

Tarp 

Perforation 

& Planting 

5 days (120 hours) 

48 hours 

14 days 
90 

The Agency received comments regarding the GAPs outlined in the July 2008 RED. These 

comments addressed a range of topics: 

• making the GAPs voluntary rather than mandatory label requirements, 

• buffer zone credits associated with GAP implementation, 

• wind speed requirements and the description of inversion conditions, 

• crop residue requirements, 

• application equipment requirements, 

• soil moisture and temperature requirements, 

• flexibility in the event that new GAPs are developed, 

• enforceability of GAPs, and 

• university research exemptions. 

These comments are addressed in detail in the Special Review and Reregistration 

Division’s response to comments document. Based on the comments, the Agency has revised 

some of the GAPs. 

The GAPs outlined in the RED, and this RED amendment, have been shown to reduce 

emissions and bystander exposures and will continue to be mandatory label requirements. Buffer 

zone credits have been reanalyzed and additional credits have been calculated for various GAPs 

depending on the soil fumigant used (see buffer zone credit section). 

The Agency has clarified the language regarding inversions and wind speed 

requirements. The Agency agrees that erosion control is an important consideration. However, 

removing the crop residue prior to fumigation is important to limit the natural “chimneys” that 

will occur in the soil when crop residue is present. These “chimneys” allow the soil fumigants to 

move through the soil quickly and escape into the atmosphere. This may create potentially 

harmful conditions for workers and bystanders and will limit the efficacy of the fumigant. To 

accommodate both of these important considerations (erosion control and human health 

protection), the Agency encourages that the field be cleared of crop residue as close to the timing 

of the fumigation as possible to limit the length of time that the soil would be exposed to 

potentially erosive weather conditions. 

Requirements for soil temperature monitoring have been revised from “air temperatures 

have been above 100 degrees F for more than three hours in any of the three days prior to 

application” to “air temperatures have been above 100 degrees F in any of the three days prior to 

application.” 

The GAPs outlined below must be followed during all fumigant applications. Registrants 

may develop additional optional GAPs to include on product labels provided they do not conflict 

with the required practices. All measurements and other documentation necessary to ensure that 

the mandatory GAPs are achieved must be recorded in the FMP and/or the post-application 

summary report as described in the FMP section. 
91 

 Tarps 

Required for all applications except for deep shank orchard replant [California only] and hand 

held tree-hole applications: 

• Tarps must be installed prior to starting hot gas applications. 

• Tarps must be installed immediately after the fumigant is applied to the soil for bedded or 

broadcast applications.

• A written tarp plan must be developed and included in the FMP that includes: 

o schedule and procedures for checking tarps for damage, tears, and other problems 

o plans for determining when and how repairs to tarps will be made, and by whom 

o minimum time following injection that tarp will be repaired 

o minimum size of tarp damage that will be repaired 

o other factors used to determine how and when tarp repair will be conducted 

o schedule, equipment, and methods used to perforate tarps 

o aeration plans and procedures following perforation of tarp, but prior to tarp removal 

or planting/transplanting 

o schedule, equipment, and procedures for tarp removal. 

 Weather conditions 

The Agency is concerned with off gassing occurring during temperature inversion. In 

many reported incidents, a temperature inversion is often given as a potential contributing factor. 

To address this concern in the July 2008 RED, the Agency prohibited applications during periods 

of temperature inversion, or when the wind speed is less than 2 mph, which can sometimes be an 

indication an inversion is occurring. In addition, the Agency provided additional information on 

the label as guidance to applicators in determining if an inversion exists. 

The Agency received many comments related to the inversion label language including 

concern that some of the characteristics of inversion conditions (like misty conditions or clear 

skies at night) do not always indicate the presence of an inversion; relying on a weather forecast 

to predict inversions is unreliable and not enforceable; and that prohibiting application during 

inversions does not address concerns of inversions during the off-gassing period. 

Based on these comments the Agency has revised the weather conditions section of the 

GAPs that relates to temperature inversions to clarify that parts of the weather conditions that are 

requirements and those that are included to help guide the applicator to identify temperature 

inversions. The measures have also been updated to prohibit application only if temperature 

inversion conditions are forecasted to persist for more than 18 of the 48 hours after the start of 

the application since this will filter out conditions when diurnal temperature inversions may 

occur, though even diurnal temperature inversions could contribute to exposures to fumigant 

concentrations outside buffers. As such, EPA believes that the measures described below in the 

emergency preparedness and response section of this document are important to address 

potential risks associated with shorter-term diurnal inversions. The Agency is also changing the 

wind speed requirement so winds may either be 2 mph at the start of application or be forecasted 

to reach 5 mph during the application. These changes are designed to prevent applications when 

inversion conditions are predicted to occur after the application has begun, since this is the time 
92 

when the peak off-gassing is expected to occur. In summary, EPA has determined that 

applicators must (1) check the weather forecast and make a decision whether to proceed with a 

planned fumigation, based on conditions that are predicted, (2) only begin a fumigant application 

if wind speed is a minimum of 2 mph at the start of the application or forecasted to reach at least 

5 mph during the application, and (3) not fumigate if there will be a persistent low-level local 

inversion or an air stagnation advisory is in effect. EPA believes advisory language providing 

more detailed information on how to identify inversions and adverse weather conditions will 

increase the likelihood that applicators will proceed with applications only when weather 

conditions are or are forecast to be favorable for safe fumigations. See below and the label table 

in Section V of this document for label statements. 

Stakeholders also questioned where the inversion conditions must exist and to what 

extent the temperature inversion must exist that would prevent an application. The Agency has 

provided additional temperature inversion details and has added a prohibition for application 

during an air-stagnation advisory. Air-stagnation advisories are issued through the National 

Weather Service and usually capture long periods of air stillness that may remain in an area from 

one to several days. EPA has determined that these modifications achieve the same goals as the 

July 2008 RED since they provide additional clarity that will enhance users’ ability to practically 

comply with the requirements. The revised statements are stated below. 

Prior to fumigation the weather forecast for the day of the application and the 48-hour 

period following the fumigation must be checked to determine if unfavorable weather 

conditions exist or are predicted and whether fumigation should proceed. 

Wind speed at the application site must be a minimum of 2 mph at the start of the 

application or forecasted to reach at least 5 mph during the application. 

Do not apply if a shallow, compressed (low-level) temperature inversion is forecast to 

persist for more than 18 consecutive hours for the 48-hour period after the start of 

application, or if there is an air-stagnation advisory in effect for the area in which the 

fumigation is planned. 

Detailed local forecasts for weather conditions, wind speed, and air stagnation 

advisories may be obtained on-line at: http://www.nws.noaa.gov. For further 

guidance, contact your local National Weather Service Forecasting Office. 

Unfavorable Weather Conditions 

Unfavorable weather conditions block upward movement of air, which results in 

trapping fumigant vapors near the ground. The resulting air mass can move off-site 

in unpredictable directions and cause injury to humans, animals or property. These 

conditions typically exist prior to sunset and continue past sunrise and persist as late 

as noontime. Unfavorable conditions are common on nights with limited cloud cover 

and light to no wind and their presence can be indicated by ground fog or smog and 

can also be identified by smoke from a ground source that flattens out below a ceiling 

layer and moves laterally in a concentrated cloud.” 
93 

 Soil temperature 

• The maximum soil temperature at the depth of injection shall not exceed 90 degrees F at the 

beginning of the application. 

o If air temperatures have been above 100 degrees F in any of the three days prior to 

application, then soil temperature shall be measured and recorded in the FMP. 

 Soil moisture 

• The soil must be moist 9 inches below the surface. The amount of moisture needed in this 

zone will vary according to soil type and shall be determined using the USDA Feel and 

Appearance Method for testing (see below). Surface soil generally dries rapidly and must 

not be considered in this determination. 

• If there is insufficient moisture 9 inches below the surface, the soil moisture must be 

adjusted. If irrigation is not available and there is adequate soil moisture below 9 inches, soil 

moisture can be adjusted by discing or plowing before fumigant injection. To conserve 

existing soil moisture, pretreatment irrigation or pretreatment tillage should be done as close 

to the time of application as possible. 

• Measure soil moisture at a depth of 9 inches at either end of the field, no more than 48 hours 

prior to application. 

Soil moisture determination 

The soil shall contain at the time of application enough moisture at 9 inches below the surface to 

meet the following criteria defined in the USDA Feel and Appearance method for estimating soil 

moisture as appropriate for the soil texture. 

• For coarse textured soils (fine sand and loamy fine sand), the soil is moist enough (50 to 75 

percent available soil water moisture) to form a weak ball with loose and clustered sand 

grains on fingers, darkened color, moderate water staining on fingers, will not ribbon. 

• For moderately coarse textured soils (sandy loam and fine sandy loam), the soil is moist 

enough (50 to 75 percent available soil water moisture) to form a ball with defined finger 

marks, very light soil/water staining on fingers, darkened color will not stick. 

• For medium textured soils (sandy clay loam, loam, and silt loam), the soil is moist enough 

(50 to 75 percent available soil water moisture) to form a ball, very light staining on fingers, 

darkened color, pliable, and forms a weak ribbon between the thumb and forefinger. 

• For fine textured soils (clay, clay loam, and silty clay loam), the soil is moist enough (50 to 

75 percent available soil water moisture) to form a smooth ball with defined finger marks, 

light soil/water staining on fingers, ribbons between thumb and forefinger. 

• For fields with more than one soil texture, soil moisture content in the lightest textured 

(most sandy) areas must comply with this soil moisture requirement. Whenever possible, the 

field should be divided into areas of similar soil texture and the soil moisture of each area 
94 

should be adjusted as needed. Coarser textured soils can be fumigated under conditions of 

higher soil moisture than finer textured soils; however, if the soil moisture is too high, 

fumigant movement will be retarded and effectiveness of the treatment will be reduced. 

Previous and/or local experience with the soil to be treated or the crop to be planted can often 

serve as a guide to conditions that will be acceptable. If there is uncertainty in determining 

the soil moisture content of the area to be treated, a local extension service or soil 

conservation service specialist or pest control advisor (agriculture consultant) should be 

consulted for assistance. 

 Soil preparation 

• Soil shall be properly prepared and at the surface generally be free of clods that are golf ball 

size or larger. The area to be fumigated shall be tilled to a depth of 5 to 8 inches. 

• Field trash must be properly managed. Residue from a previous crop must be worked into 

the soil to allow for decomposition prior to fumigation. Little or no crop residue shall be 

present on the soil surface. Crop residue that is present must not interfere with the soil seal. 

Removing the crop residue prior to fumigation is important to limit the natural “chimneys” 

that will occur in the soil when crop residue is present. These “chimneys” allow the soil 

fumigants to move through the soil quickly and escape into the atmosphere. This may create 

potentially harmful conditions for workers and bystanders and will limit the efficacy of the 

fumigant. However, crop residue on the field serves to prevent soil erosion from both wind 

and water and is an important consideration. To accommodate erosion control, fumigant 

efficacy, and human health protection, clear fields of crop residue as close to the timing of 

the fumigation as possible to limit the length of time that the soil would be exposed to 

potentially erosive weather conditions. 

 Soil sealing 

• For Broadcast Untarped Applications: Use a disc or similar equipment to uniformly mix the 

soil to at least a depth of 3 to 4 inches to eliminate the chisel or plow traces. Following 

elimination of the chisel trace, the soil surface must be compacted with a cultipacker, ring 

roller, and roller in combination with tillage equipment. 

• For Bedded Applications: Preformed beds shall be sealed by disruption of the chisel trace 

using press sealers, bed shapers, cultipackers, or by re-shaping (e.g., relisting, lifting, 

replacing) the beds immediately following injection. Beds formed at the time of application 

shall be sealed by disrupting the chisel trace using press sealers, or bed shapers. 

• Soil Sealing for Tarped Applications: The use of a tarp does not eliminate the need to 

minimize chisel traces prior to application of the tarp, such as by using a nobel plow or other 

injection shank equipment that disrupts the chisel traces. 

Methyl Bromide Bedded and Broadcast Shank Applications: Additional GAPs 

In addition to the GAPs required for all soil fumigation applications, the following GAPs apply 

for injection applications: 
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Tarps

• Tarps must be installed immediately after the fumigant is applied to the soil. 

Soil Preparation

• Trash pulled by the shanks to the ends of the field must be covered with tarp, or soil, 

depending on the application method before making the turn for the next pass. 

Application Depth

• For Tarped-Broadcast and Tarped-Bedded Applications: The injection point shall be a 

minimum of 8 inches from the nearest final soil/air interface. For tarped bedded applications 

the injection depth must not be deeper than the lowest point of the tarp (i.e., the lowest point 

of the tuck). 

• For Untarped-Bedded Applications: The injection point shall be a minimum of 12 inches 

from the nearest final soil/air interface. 

• For Untarped-Broadcast Applications (CA orchard replant only): The injection point shall 

be a minimum of 18 inches from the nearest final soil/air interface. 

Prevention of End Row Spillage

• Do not apply fumigant to, or allow fumigant to drain onto, the soil surface. For each 

injection line either a check valve must be located as close as possible to the final injection 

point, or equipment must drain/purge the line of any remaining fumigant prior to lifting 

injection shanks from the ground. 

• Do not lift injection shanks from the soil until the shut-off valve has been closed and the 

fumigant has been depressurized (passively drained) or purged (actively forced out via air 

compressor) from the system. 

Calibration, Set-up, Repair, and Maintenance for Application Rigs

• Brass, carbon steel or stainless steel fittings must be used throughout. Polyethylene tubing, 

polypropylene tubing, Teflon® tubing or Teflon® -lined steel braided tubing must be used 

for all low pressure lines, drain lines, and compressed gas or air pressure lines. All other 

tubing must be Teflon® -lined steel braided. 

• Galvanized, PVC, nylon or aluminum pipe fittings must not be used. 

• All rigs must include a filter to remove any particulates from the fumigant, and a check valve 

to prevent backflow of the fumigant into the pressurizing cylinder or the compressed air 

system. 

• Rigs must include a flowmeter or a constant pressure system with orifice plates to insure the 

proper amount of fumigant is applied. 

• To prevent the backflow of fumigant into the compressed gas cylinder (e.g., nitrogen, other 

inert gas or compressed air), if used, applicators must: 

o Ensure that positive pressure is maintained in the cylinder at not less than 200 psi 

during the entire time it is connected to the application rig, if a compressed gas 
96 

cylinder is used. (This is not required for a compressed air system that is part of the 

application rig because if the compressor system fails the application rig will not be 

operable) 

o Ensure that application rigs are equipped with properly functioning check valves 

between the compressed gas cylinder or compressed air system and the fumigant 

cylinder. The check valve is best placed on the outlet side of the pressure regulator, 

and is oriented to only allow compressed gas to flow out of the cylinder or 

compressed air out of the compressed air system. 

o Always pressurize the system with compressed gas or by use of a compressed air 

system before opening the fumigant cylinder valve. 

• Before using a fumigation rig for the first time, or when preparing it for use after storage, 

the operator must check the following items carefully: 

o Check the filter, and clean or replace the filter element as required. 

o Check all tubes and chisels to make sure they are free of debris and obstructions. 

o Check and clean the orifice plates and screen checks, if installed. 

o Pressurize the system with compressed gas or compressed air, and check all fittings, 

valves, and connections for leaks using soap solution. 

• Install the fumigant cylinder, and connect and secure all tubing. Slowly open the compressed 

gas or compressed air valve, and increase the pressure to the desired level. Slowly open the 

fumigant cylinder valve, always watching for leaks. 

• When the application is complete, close the fumigant cylinder valve and blow residual 

fumigant out of the fumigant lines into the soil using compressed gas or compressed air. At 

the end of the application, disconnect all fumigant cylinders from the application rig. At the 

end of the season, seal all tubing openings with tape to prevent the entry of insects and dirt. 

• Application equipment must be calibrated and all control systems must be working properly. 

Proper calibration is essential for application equipment to deliver the correct amount of 

fumigant uniformly to the soil. Refer to the manufacturer’s instructions on how to calibrate 

your equipment, usually the equipment manufacturer, fumigant dealer, or Cooperative 

Extension Service can provide assistance. 

Hot Gas Soil Applications (Greenhouse and Outdoor): Mandatory GAPs 

• All delivery tubes shall be placed under the tarp in such a way that they do not move during 

the application of methyl bromide. 

• The fumigant must be introduced from outside of the greenhouse/application block (see entry 

restrictions and respiratory protection sections for further details). 

• All fittings, connections, and valves must be checked for methyl bromide leaks prior to 

fumigation. If cylinders are replaced during the fumigation process, the connections and 

valves must be checked for leaks prior to continuing the job. 

Tree Replant Application: Mandatory GAPs 

In addition to the GAPs required for all soil fumigation applications, the following GAPs 

apply for tree replant applications. This application method is used when methyl bromide is 

applied to individual tree sites in an existing orchard where shank application are not possible: 
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Site Preparation

• Each individual tree-site must remove the tree stump and primary root system with a 

back-hoe or other similar equipment, for example an auger. 

• The hole must be backfilled with soil before application. 

Application Depth

• The fumigant must be injected at least 18 inches into the soil. 

System Flush

• Before removing the application wand from the soil the wand must be cleared using 

nitrogen or compressed air. 

Soil Sealing

• After the wand is cleared and removed from the soil, the injection hole must be either 

covered with soil and tamp or the soil must be compacted over the injection hole. 

ii. Fumigant Management Plans (FMPs) 

As noted elsewhere in this document, soil fumigation is a complex site-specific activity. 

Failure to adhere to label requirements and procedures for safe use has led to accidents affecting 

workers involved in fumigations as well as bystanders. Information from various sources shows 

that health and safety plans, FMPs in this context, typically reduce workplace injuries and 

accidents by prescribing a series of operational requirements and criteria. In fact, plans like 

these are widely implemented in a variety of industries and are recommended as standard 

approaches for occupational health and safety management by groups such as American 

Industrial Hygiene Association16 (i.e., through “Administrative” and “Workplace” controls). The 

Centers for Disease Control provides guidance for developing health and safety plans in 

agricultural settings.17 The effectiveness of similar plans has also been evaluated in the 

literature. Examples include “lookback” reviews conducted by the Occupational Safety and 

Health Administration (OSHA) which essentially implemented standards in various industries 

then reviewed their effectiveness in this process as they are required to determine whether the 

standards should be maintained without change, rescinded or modified. OSHA is required by 

Section 610 of the Regulatory Flexibility Act (5 U.S.C. 610) and Executive Order 12866 to 

conduct the “lookback” reviews. These reviews are conducted to make the subject final 

standards more effective or less burdensome in achieving their objectives, to bring them into 

better alignment with the objectives of Executive Order 12866, and to make them consistent with 

 

16 Ignacio and Bullock (2006) A Strategy For Assessing and Managing Occupational Exposures (Third Edition), 

American Industrial Hygiene Association, AIHA Press 2700 Prosperity Avenue, Suite 250 Fairfax VA 22031 (ISBN 

1-931504-69-5) 

17 Karsky (2002) Developing a Safety and Health Program to Reduce Injuries and Accident Losses, Centers For 

Disease Control National Ag Safety Database, available at http://www.cdc.gov/nasd/docs/d001501-

d001600/d001571/d001571.html 
98 

the objectives of the Regulatory Flexibility Act. Two examples of “lookback” reviews that 

support the use of FMPs for soil fumigant health and safety management include: ethylene oxide 

use as a fumigant/sterilant, and grain handling facilities requirements.18

In the July 2008 RED, EPA required FMPs to be completed before a fumigant 

application occurs. EPA concluded that FMPs will reduce potential risks to bystanders as well as 

handlers by requiring that applicators have carefully planned, in writing, each major element of 

the fumigation. In this context, an FMP is a set of performance criteria for each application, 

including how the fumigator intends to comply with label requirements. As added benefits, the 

Agency determined that FMPs would ensure directions on the product labels were followed and 

that the conditions under which fumigation occurred were documented. EPA also concluded that 

FMPs would help ensure an appropriate response by the applicator or others involved in the 

application should an incident occur since a proper and prompt response would reduce the 

potential risk to bystanders from potential high exposure situations (e.g., readily available first 

responder contact information could reduce response times to impacted bystanders and carefully 

thought out emergency response plans can help ensure appropriate actions are taken in case of 

unforeseen events). 

The July 2008 RED provided a list of each major element FMPs would need to address. 

These included general site and applicator information, application procedures, and a description 

of how the fumigator planned to comply with label requirements for GAPs, buffer zones, 

monitoring, worker protection, posting, and providing notification to the state or tribal lead 

agency. FMPs also were required to include plans for communication between the applicator 

and others involved in the fumigation, documentation, and handling emergency situation. 

Additionally, EPA required that applicators complete a post fumigation summary that described 

any deviations from the FMP, measurements taken to comply with GAPs, and information about 

any problems such as complaints or incidents that occurred as a result of the fumigation. The 

RED also specified requirements for record keeping and that FMPs must be provided, upon 

request, to enforcement officials and handlers involved in the fumigation. 

According to stakeholder comments in earlier comment periods, much of the information 

required for the site-specific FMP was already being documented by users, and most industry 

stakeholders supported mandatory FMPs provided they are not too restrictive or complex and do 

not result in an excessive administrative burden. 

During the post-RED comment period, EPA received several comments regarding FMPs. 

Several comments from industry and user stakeholders expressed concern that FMP 

requirements would increase paperwork burden without providing significant risk reduction, 

though others supported FMPs provided they did not result in an excessive administrative 

burden. A number of comments suggested that the level of detail EPA had required was too 

great and could result in voluminous, resource-intensive plans. Some of these comments 

suggested that a checklist format would be more efficient and far less burdensome. Some 

comments expressed reservations about the ability of FMPs to enhance compliance with label 

requirements. Some commenters were concerned about the feasibility of providing a copy of the 

 

18 United States Department of Labor, Occupational Safety and Health Administration (2008) Lookback Reviews 

available at http://www.osha.gov/dea/lookback.html
99 

FMP to on-site handlers or enforcement personnel, though others said that copies of the FMP 

should be provided to workers in areas adjacent to the application block. 

Following EPA’s review of the post-RED comments, the Agency still believes that 

FMPs will reduce potential risks to bystanders as well as handlers and are a key component of 

the package of measures to reduce risks. EPA believes that FMPs will also enhance 

compliance by requiring that applicators verify and document compliance with the label 

requirements during and after application events are completed. In cases where errors may 

have occurred, a post-application summary may also prevent similar problems from occurring 

during future applications. However, in response to comments, the Agency has somewhat 

modified the list of elements that must be addressed in the FMP (as described below) to make 

it more streamlined and thus less burdensome to applicators and growers. In addition, the 

Agency has developed a sample template in which many of the elements are covered in 

checklist format, which fumigators have the option of downloading and modifying to meet the 

needs of their specific fumigation situations. See 

[http://www.epa.gov/pesticides/reregistration/soil_fumigants/]. EPA will also continue to 

work with stakeholders to refine the FMP template and potentially develop others so it is a 

more useful tool for ensuring the safe application of methyl bromide. 

The Agency estimates that, if a certified applicator decides not to use the FMP template 

and decides to prepare a narrative FMP, a carefully designed FMP could take several days to 

develop the first time. Subsequent FMPs should require substantially less time to develop 

because much of the information can be reused from the initial plan. In addition, an enterprise 

fumigating multiple application blocks as part of a larger fumigation may format their FMP in a 

manner whereby all of the information that is common to all the application blocks is captured 

once, and any information unique to a particular application block or blocks is captured in 

subsequent, separate sections. 

Amended FMP Requirements 

Consistent with the July 2008 RED, the Agency is not requiring FMPs to be submitted to 

state or local agencies. They must, however be maintained by the applicator and grower (if the 

grower is not the applicator) for a period of 2 years. 

The Agency agrees with comments that having both the applicator and the 

owner/operator provide copies of the FMP to handlers is unnecessarily duplicative and that 

providing each worker with a hardcopy of the FMP wastes paper. The Agency also agrees that it 

is not necessary for the FMP to be provided to the workers in areas adjacent to the application 

block. Workers in adjacent areas will be notified of the fumigation by buffer posting 

requirements and, in the case of neighbors whose land is part of a buffer zone, the adjoining 

neighbor has responsibility for workers in areas adjacent to the application for which permission 

was granted to use as part of a fumigation buffer. The Agency has revised the following 

requirement that was included in the 2008 RED, “Once the application begins, the certified 

applicator and owner/operator of the application block must provide a copy of the FMP to 

handlers involved in the fumigation, workers in adjacent areas to the application block, and 

federal/state/local enforcement personnel, upon request.” The RED Amendment requires the 
100 

certified applicator to make a copy of the FMP available for viewing by handlers involved in the 

fumigation. The certified applicator or the owner/operator of the application block must provide 

a copy of the FMP to any federal, state, tribal, or local enforcement personnel who request the 

FMP. In the case of an emergency, the FMP must be made available when requested by 

federal/state/local emergency response and enforcement personnel.

The Agency agrees with comments that the term “etc.” complicates enforcement 

activities and has removed that term from the label tables. 

Each site-specific FMP must contain the following elements: 

 Applicator information (name, phone number, license number, employer name, employer 

address, date of completing registrant methyl bromide training program) 

 General site information 

3⁄4 Application block location (e.g., address or global positioning system (GPS) coordinates) 

3⁄4 Name, address, and, phone number of owner/operator of the application block 

3⁄4 Map, aerial photo, or detailed sketch showing field location, dimensions, buffer zones, 

property lines, roads, rights-of-ways, sidewalks, permanent walking paths, bus stops, 

water bodies, wells, nearby application blocks, surrounding structures (occupied and nonoccupied), locations of posted signs for buffers, and sites requiring 1⁄4 or 1⁄8 mile buffer 

zones (e.g., schools, state licensed day care centers, nursing homes, assisted living 

facilities, hospitals, in-patient clinics, and prisons) with distances from the application site 

labeled 

 General application information (target application date/window, brand name of fumigant, 

EPA registration number) 

 Tarp information and procedures for repair, perforation and removal(if tarp is used) 

3⁄4 Brand name, lot number, thickness 

3⁄4 Name and phone number of person responsible for repairing tarps 

3⁄4 Schedule for checking tarps for damage, tears, and other problems 

3⁄4 Maximum time following notification of damage that the person(s) responsible for tarp 

repair will respond 

3⁄4 Minimum time following application that tarp will be repaired 

3⁄4 Minimum size of damage that will be repaired 

3⁄4 Other factors used to determine when tarp repair will be conducted 

3⁄4 Name and phone number of person responsible for cutting and/or removing tarps (if other 

that certified applicator) 

3⁄4 Equipment/methods used to cut tarps 

3⁄4 Schedule and target dates for cutting tarps 

3⁄4 Schedule and target dates for removing tarps 

 Soil conditions (description of soil texture in application block, method used to determine 

soil moisture) 

 Weather conditions (summary of forecasted conditions for the day of the application and the 

48-hour period following the fumigant application) 

3⁄4 Wind speed 

3⁄4 Inversion conditions (e.g., shallow, compressed (low-level) temperature inversion) 

3⁄4 Air stagnation advisory 
101 

 Buffer zones 

3⁄4 Application method 

3⁄4 Application rate from lookup table on the label (lb ai/A) 

3⁄4 Application block size from lookup table on the label (acres) 

3⁄4 Credits applied 

3⁄4 Buffer zone distance 

3⁄4 Description of areas in the buffer zone that are not under the control of the 

owner/operator of the application block 

 Respirators and other personal protective equipment (PPE) for handlers (handler task, 

protective clothing, respirator type, respirator cartridge type, respirator cartridge replacement 

schedule, eye protection, gloves, other PPE) 

 Emergency procedures (evacuation routes, locations of telephones, contact information for 

first responders, local/state/federal contacts, key personnel and emergency 

procedures/responsibilities in case of an incident, equipment/tarp/seal failure, complaints or 

elevated air concentration levels outside buffer zone suggesting potential problems, or other 

emergencies). 

 Posting procedures (person(s) who will post signs, location of posting signs, procedures for 

sign removal) 

 Site-specific response and management (if applicable) 

3⁄4 Fumigant site monitoring 

 Description of who, when, where, and procedures for monitoring buffer zone 

perimeter 

3⁄4 Response information for neighbors 

 List of residences, businesses, and neighboring property owners informed 

 Name and phone number of person doing notification 

 Method of providing the information 

 State and tribal lead agency notification (If state and/or tribal lead agency requires notice, 

provide a list of contacts that were notified and date notified.) 

 Plan describing how communication will take place between applicator, land owner/operator, 

and other on-site handlers (e.g., tarp cutters/removers, irrigators) for complying with label 

requirements (e.g., buffer zone location, buffer zone start/stop times, timing of tarp cutting 

and removal, PPE). 

3⁄4 Name and phone number of persons contacted 

3⁄4 Date contacted 

 Authorized on-site personnel 

3⁄4 Names, addresses and phone numbers of all handlers 

3⁄4 Employer name, addresses, and phone numbers for all handlers 

3⁄4 Tasks that each handler is authorized and trained to perform 

3⁄4 Date of PPE training for each handler 

3⁄4 For handlers designated to wear respirators respiratory protection is required (minimum 

of 2 handlers), date of medical qualification to wear a respirator and date of fit testing for 

respirator. 

 Air monitoring plan 

3⁄4 For buffer zone monitoring: 

 Name, address, and, phone number of handler to perform monitoring activities 

 Location and timing of monitoring for the buffer zone 
102 

3⁄4 For handlers without respiratory protection: 

 If sensory irritation is experienced, indicate whether operations will be ceased or 

operations will continue with respiratory protection 

 If intend to cease operations when sensory irritation is experienced, provide the name, 

address, and phone number of the handler that will perform monitoring activities 

prior to operations resuming 

3⁄4 For handlers with respiratory protection: 

 Representative handler tasks to be monitored 

 Monitoring equipment to be used and timing of monitoring 

3⁄4 For buffer zone monitoring when using methyl bromide formulations with < 20% 

chloropicrin: 

 Name, address, and phone number of person(s) to perform sampling 

 Identify areas or structures to be monitored before reentry is permitted 

 Monitoring equipment to be used and timing of the monitoring 

3⁄4 For monitoring the breathing zone when using methyl bromide formulations with 

< 20% chloropicrin: 

 Representative handler tasks to be monitored 

 Monitoring equipment to be used and timing of the monitoring 

 Good Agricultural Practices (GAPs) 

3⁄4 Description of applicable mandatory GAPs (registrants may also include optional GAPs) 

3⁄4 Measurements and documentation to ensure GAPs are achieved (e.g., measurement of 

soil and other site conditions) 

 Description of hazard communication. (The buffer zone around the application block has 

been posted in accordance with the label. Pesticide product labels and material safety data 

sheets are on-site and readily available for employees to review.) 

 Record-keeping procedures (the owner/operator of the application block, as well as the 

certified applicator, must keep a signed copy of the site-specific FMP and the post 

application summary for 2 years from the date of application). 

For situations where an initial FMP is developed and certain elements do not change for 

multiple fumigation sites (e.g., applicator information, authorized on-site personnel, record 

keeping procedures, emergency procedures) only elements that have changed need to be updated 

in the site-specific FMP provided the following: 

• The certified applicator supervising the application has verified that those elements are 

current and applicable to the application block before it is fumigated and has documented 

the verification in the site-specific FMP. 

• Recordkeeping requirements are followed for the entire FMP (including elements that do 

not change). 

Once the application begins, the certified applicator must make a copy of the FMP 

available for viewing by handlers involved in the fumigation. The certified applicator or the 

owner/operator of the application block must provide a copy of the FMP to any federal, state, 

tribal, or local enforcement personnel who request the FMP. In the case of an emergency, the 
103 

FMP must be made available when requested by federal/state/local emergency response and 

enforcement personnel. 

Within 30 days of completing the application portion of the fumigation process, the 

certified applicator supervising the application must complete a post fumigation application 

summary that describes any deviations from the FMP that have occurred, measurements taken to 

comply with GAPs as well as any complaints and/or incidents that have been reported to 

him/her. 

Specifically the Post-Application Summary must contain the following elements: 

 Actual date of the application, application rate, and size of application block fumigated 

 Summary of weather conditions on the day of the application and during the 48-hour period 

following the fumigant application 

 Soil temperature measurement (if air temperatures were above 100 degrees F in any of the 3 

days prior to the application) 

 Tarp damage and repair information (if applicable) 

3⁄4 Location and size of tarp damage 

3⁄4 Description of tarp/tarp seal/tarp equipment failure 

3⁄4 Date and time of tarp repair 

 Tarp removal details (if applicable) 

3⁄4 Description of tarp removal (if different than in the FMP) 

3⁄4 Date tarps were cut 

3⁄4 Date tarps were removed 

 Complaint details (if applicable) 

3⁄4 Person filing a complaint (e.g., on-site handler, person off-site) 

3⁄4 If off-site person, name, address, and phone number of person filing a complaint 

3⁄4 Description of control measures or emergency procedures followed after a complaint 

 Description of incidents, equipment failure, or other emergency and emergency procedures 

followed (if applicable) 

 Details of elevated air concentrations monitored on-site or outside the buffer zone (if 

applicable) 

3⁄4 Location of elevated air concentration levels 

3⁄4 Description of control measures or emergency procedures followed 

3⁄4 Air monitoring results 

 When sensory irritation experienced: 

• Date and time of sensory irritation 

• Handler task/activity 

• Handler location where irritation was observed 

• Resulting action (e.g., cease operations, continue operations with respiratory 

protection) 

 When using a direct read instrument: 

• Type of sample (e.g., area, breathing zone, structure) 

• Sample date and time 

• Handler task/activity (if applicable) 
104 

• Handler location or structure location 

• Air concentration 

• Sampling method 

 Date of buffer zone sign removal 

 Any deviations from the FMP 

In addition to recordkeeping requirements from 7 CFR part 110 “Recordkeeping 

Requirements for Certified Applicators of Federally Restricted Use Pesticides,” this decision 

requires that both the applicator and owner/operator of the application block keep a signed copy 

of the site-specific FMPs and the post-application summary record for 2 years from the date of 

application.

Applicators and other stakeholders have the flexibility to use EPA’s template, prepare 

their own FMPs templates, or use other commercially available software with certain elements 

listed above in check-list and/or fill in the blank format. Below are examples of other FMP 

templates available on the internet for structural fumigations that may be useful to users when 

developing FMPs for methyl bromide soil applications: 

• http://www.cardinalproproducts.com/Misc/FMP%20Version%203.pdf

• http://www.pestcon.com/techlibrary/fum_mgmt_plan.doc

• http://www.agr.state.ne.us/division/bpi/pes/fumigation_plan.pdf

• http://www.agr.state.ne.us/division/bpi/pes/fumigation_plan2.pdf

• http://nmdaweb.nmsu.edu/pesticides/Management%20Plans%20Required%20for%20Fu

migations.html

iii. Site Specific Response and Management 

EPA believes measures for ensuring preparedness for situations when accidents or 

emergencies occur are an important part of the suite of measures necessary to address risks posed 

by fumigants. Therefore, EPA is requiring such measures at the community level in the form of 

educational materials for first responders, and measures for specific sites to ensure early 

detection and quick and appropriate response to situations as they arise. 

Although EPA believes buffers and other mitigation will prevent many future incidents, it 

is likely that some incidents will still occur due to accidents, errors, and/or unforeseen weather 

conditions such as diurnal inversions. Early detection and appropriate response to accidental 

chemical releases is an effective means of reducing risk, as well as addressing the source of the 

release. Reducing risks associated with incidents that may occur in the future is a key part of 

EPA’s soil fumigant decisions. By combining buffers with GAPs, FMPs, and effective 

emergency response, EPA is able to reach a “no unreasonable adverse effects” finding under 

FIFRA. 

To ensure that appropriate response mechanisms are in place in the event of a fumigant 

exposure incident, EPA is requiring that registrants provide training information, in the context 

of their community outreach and education programs to first responders in high-fumigant use 

areas and areas with significant interface between communities and fumigated fields. In 
105 

addition, for situations in which people, homes, or other structures are in close proximity to 

buffer zones, applicators must either monitor buffer zone perimeters or, alternatively, provide 

emergency response information directly to neighbors. Each element is discussed in more detail 

below. 

First Responder Education 

EPA is requiring registrants through their community outreach and education programs 

(see the Community Outreach and Education section), to ensure that emergency responders have 

the training and information that they need to effectively identify and respond to fumigant 

exposure incidents. EPA believes this will help ensure, in the case of a fumigant accident or 

incident that first responders recognize the exposure as fumigant related and respond 

appropriately. Additional details are included in the Community Outreach and Education section 

of this document. 

Emergency Preparedness and Response Considerations for the 2008 RED 

Prior to the July 2008 RED the EPA received comments from many stakeholders about 

the Agency’s emergency preparedness and response option. Users have commented that 

notification is burdensome and that it is unnecessary if buffer zones are also required. However, 

community groups have commented on the importance of bystanders being informed when 

fumigations are occurring, since this group of pesticides, compared to other pesticides, has a 

greater potential to move off site and affect people not involved in the application. State 

regulators have different views on this requirement. Some support the sharing of information 

with neighbors, and some states have notification requirements for fumigations with certain 

products or for certain application methods. In addition, some states require notification to 

chemically sensitive individuals in proximity to pesticide applications. Others also had concerns 

about the enforceability of this type of measure and the possible burden on the states to enforce a 

notification requirement. 

California currently requires notification of persons within 300 feet of a methyl bromide 

buffer zone. California strawberry growers consider the 300 foot notification area for methyl 

bromide applications to be an extension of the buffer zone. In areas where a large number of 

people would need to be notified about a planned methyl bromide application, strawberry 

growers indicated that they would rather not use methyl bromide because some communities 

could mobilize to prevent the fumigation from taking place. Some stakeholders also commented 

that it would be protective and less burdensome if EPA required the user to monitor fumigant air 

concentrations at the edge of the buffer for 24 hours after the application to ensure the fumigant 

does not move beyond the buffer at concentrations that exceed EPA’s level of concern. If 

concentrations of concern were detected, the user would be required to implement the emergency 

response measures specified in the fumigant management plan. 

EPA has concluded that bystanders could take steps to protect themselves if they had 

basic information about fumigations and the appropriate steps to take if they experienced 

symptoms of exposure. In a number of fumigant incidents that have occurred, the magnitude and 

severity of the incident could have been significantly reduced if people had such information. 
106 

Similarly, having on-site monitoring will enable site managers to take remedial action (i.e., 

activate the control plan in the FMP) to lower emissions sooner, also resulting in fewer and less 

severe exposures. And, if necessary, site managers would activate the emergency response 

elements of the FMP. 

Providing communities with information about local chemical releases is an important 

part of emergency preparedness programs and is recognized as an effective means of addressing 

risk at the local level. Some states, like Florida and Wisconsin, have requirements for providing 

information to chemically-sensitive individuals about chemicals used nearby so they can take 

steps to protect themselves from potentially harmful exposures (see http://edis.ifas.ufl.edu/pi004

and http://www.legis.state.wi.us/rsb/code/atcp/atcp029.pdf). The requirements in Florida do not 

apply to agricultural chemical applications. Wisconsin also requires fumigators applying metam 

sodium products through chemigation to provide written notice to the county public health 

agency and to every individual or household within 1⁄4 miles of the chemigation application site 

(see http://www.legis.state.wi.us/rsb/code/atcp/atcp030.pdf). EPA agrees that information about 

how to recognize and address exposures can help citizens reduce potential risk. 

EPA understands that difficult challenges exist when agricultural land borders urban or 

suburban communities. While EPA’s decisions for the fumigants will not alleviate challenges 

that already exist, EPA is allowing options for ensuring emergency preparedness in an effort to 

lessen potential impact on growers, while maintaining the Agency’s protection goals. 

EPA is not requiring a specific method of providing the information to neighbors, but 

rather that it be done in a way that effectively communicates, in a manner the recipients will 

understand. Some methods may not result in documentation that would be retained. To address 

concerns about enforcement, EPA is requiring that information on how and when the emergency 

response information was delivered, and to whom, be included in the FMP. 

Emergency Preparedness and Response Revisions 

To reduce risks to people who may be near a buffer zone (e.g., at their home, working in 

a nearby field) in the July 2008 RED, EPA required applicators to either monitor buffer zone 

perimeters or, alternatively, provide emergency response information directly to neighbors. This 

measure is intended to ensure protection in places people may be found. Whether measures are 

required depends on the size of the buffer zone and how close land, not within the control of the 

owner/operator of the application block (e.g., residential properties), may be to the buffer zone. 

The Agency received many comments about the Emergency Preparedness and Response 

requirements that suggested the requirements were too complex and confusing. To address these 

concerns, EPA has revised the structure and content of the requirements in the RED Amendment 

to improve clarity. As was outlined in the 2008 RED, it is important to note that site-specific 

Emergency Preparedness and Response measures are only required if there are people, homes or 

businesses within a specified distance from the edge of the buffer zone. 

Some comments were received that questioned the rationale behind scaling the 

Emergency Preparedness and Response measures. EPA believes that scaling the size of the 
107 

Emergency Preparedness and Response area will be protective. Generally the larger the buffer 

distance the higher the application rate or the size of the treated area translates to a greater total 

amount of fumigant being applied and potentially higher exposure in the area surrounding the 

application block. The buffer distances for triggering the Emergency Preparedness and 

Response requirements are scaled to allow the amount of fumigant used (a surrogate for potential 

exposure) to determine the applicable distance for implementing this requirement. When the 

area is scaled to the size of the buffer, small buffers which result from applications to small 

areas, at low application rates, and/or using low-emission application techniques, will have small 

or no areas to monitor or inform, while larger applications will have larger areas to monitor or 

inform. In addition, to create additional incentive to achieve the smallest buffer possible, EPA 

has included an exception for application blocks with the smallest required buffer (25 feet) which 

would not be subject to this requirement, since they are most likely using lower application rates, 

applying to smaller areas, and/or using lower emission application methods. Based on changes 

to the buffer zone section regarding overlapping buffer zones, any buffer zone that overlaps with 

another buffer zone must use the maximum distance in the Emergency Preparedness and 

Response measures to determine if monitoring or providing information to neighbors is needed. 

None of the other distances have changed. 

Many stakeholders also expressed concern over the potential burden the July 2008 RED 

requirements may have on applicators and growers. Specifically, the frequency and cost of 

monitoring using sampling devices such as colorimetric tubes were of concern. Several of these 

comments noted concerns with the reliability of such devices at low concentration. Stakeholders 

felt the inherent warning properties of chloropicrin and MITC (i.e., eye irritation) were better 

indicators of exposure than available devices. Additionally, several stakeholders indicated that 

monitoring is most appropriate and effective at dawn and dusk, the times of day when off-site 

movement of concentrations is most likely. Based on these comments, the Agency has revised 

the requirement so monitoring is required during those periods when risk of high concentrations 

of fumigant moving beyond buffers is greatest (i.e., at dawn and dusk). As a precaution, 

monitoring is also required once during the night and during the day. 

Additionally, as noted in the Respiratory Protection section of this document, due to 

limitations on currently available technology for monitoring, use of sampling devices such as 

colorimetric tubes will not be required at this time unless methyl bromide constitutes more than 

80% of the product. EPA believes that currently available devices are likely to be more reliable 

at fumigant concentrations which exceed EPA’s action level concentrations. In fact, some of 

these action levels are at or near the detection limits for the devices available for some 

fumigants. Additionally, colorimetric devices provide snapshot measurements. In conditions 

that are likely to be more static (e.g., monitoring an indoor fumigation such as a grain mill or 

warehouse) it is likely that minute to minute changes in conditions would not be as great as those 

anticipated for the more dynamic conditions characteristic of outdoor field fumigation where 

exposure concentrations could shift because of weather changes or stratification in soil 

conditions across a single field. 

The Agency is modifying the procedures for monitoring buffer zones because there are 

technological limitations of currently available MITC and chloropicrin monitoring devices such 

that these devices are neither practical nor reliable for field use. However, the Agency does 
108 

believe that quantitative air monitoring would enhance safety if the appropriate technology were 

available as it is for methyl bromide. Some equipment manufacturers have indicated interest in 

developing devices that would be more functional and reliable for field fumigation applications 

(e.g., badge-type monitors). EPA encourages such efforts and plans to stay abreast of 

developments and improvements in monitoring devices and will consider this issue again in 

Registration Review or sooner should such monitors become available in the short term. In the 

interim, buffer monitoring for chloropicrin and the MITC generating chemicals will rely on 

sensory indicators (e.g., eye and/or nose irritation) to trigger a response instead of using tubes. 

Monitoring tubes are still required for measuring products that contain more than 80 % methyl 

bromide. 

Finally some comments provided suggestions to increase flexibility in how a grower may 

comply with these measures as well as the effectiveness of the option to provide information to 

neighbors. EPA agrees with the importance of users being able to comply with these measures 

and has modified some aspects of the requirements for this option to reduce the number of 

notices an applicator may need to provide to a given neighbor. Also, to enhance the 

effectiveness of the information neighbors would receive, EPA is requiring that the information 

is provided close to when the application is planned to take place and early enough for neighbors 

to make use of the information. EPA believes these modifications will enhance compliance and 

effectiveness of the information if the emergency response criteria are met and applicators 

exercise this option. 

Emergency Preparedness and Response Requirements 

When are Emergency Preparedness and Response Measures Needed?

If the buffer zone is: AND There is land (e.g., residential properties 

and businesses) NOT in the control of 

the property operator within this 

distance 

from the edge of the buffer zone: 

25 feet < Buffer ≤ 100 feet 50 feet 

100 feet < Buffer ≤ 200 feet 100 feet 

200 feet < Buffer ≤ 300 feet 200 feet 

Buffer > 300 feet or buffer zones 

overlap 

 300 feet 

Then either monitoring of the buffer zone perimeter or providing emergency response 

information to neighbors is required. 

If the buffer zone is 25 feet, the minimal buffer zone size, then the Emergency 

Preparedness and Response requirements are not applicable. Also, if all of the land within 300 

feet of the edge of the buffer zone is under the control of the property operator, then no site 

monitoring or informing neighbors would be required regardless of the size of the buffer zone. 
109 

Fumigation Site Monitoring 

EPA has determined that monitoring of the buffer zone perimeter for fumigants moving 

beyond buffers is an effective approach to protecting bystanders. Under this approach, if the 

person monitoring the buffer perimeter experiences eye or nasal irritation, an early sign of 

exposure to concentrations that exceed the Agency’s action level, then the emergency response 

plan specified in the FMP must be implemented. If other problems occur, such as a tarp coming 

loose, then the appropriate control plan must be activated. Because data indicate that peak 

concentrations sometimes occur on the second day following applications, and the greatest 

potential for concentrations outside buffers may be observed at dawn and dusk, EPA has decided 

that this monitoring must be done at least four times per day during the full buffer zone period at 

dawn, dusk, and once during the night and during the day, to ensure concentrations do not 

exceed the action level which will be specified on product labels. 

Specific requirements include: 

• Monitoring must take place beginning on the day the application begins until the buffer zone 

period expires. 

• Monitoring must be conducted by a certified applicator or someone under his/her supervision. 

• Monitoring for air concentrations above the action level for the fumigant, as determined by 

sensory irritation, must take place in areas between the buffer zone perimeter and residences 

or other occupied areas that trigger this requirement. Air concentrations of methyl bromide 

must be measured using a direct-read instrument if the methyl bromide product applied 

contains less than 20% chloropicrin. 

• The persons monitoring for perceptible levels must start monitoring approximately 1 hour 

before sunset of the day the application begins and continue once during the night, once at 1 

hour after sunrise, and once during the day until the end of the buffer zone period. 

• If at any time the person monitoring the air concentrations experiences sensory irritation, 

then the emergency response plan stated in the FMP must be immediately implemented. 

• If other problems occur, such as a tarp coming loose, then the appropriate control plan must 

be activated. 

• The location and results of the air monitoring must be recorded in the FMP. 

While protective, this site monitoring might be burdensome for users fumigating in areas 

with few people. Therefore, EPA is allowing users the alternative option of providing 

emergency response information directly to neighbors.

Response Information for Neighbors 

As an alternative to on-site monitoring, the certified applicator supervising the fumigation 

(or someone under his/her direct supervision) would need to ensure that residences, businesses, 

or other sites that meet the criteria outlined below have been provided the required information at 

least one week prior to the fumigant application in a specified field. If after four weeks, the 

fumigation has not yet taken place, the information must be delivered again. 

• Information that must be provided includes: 

o The general location of the application block, 
110 

o Fumigant(s) applied including the active ingredient, name of the fumigant 

products(s), and the EPA Registration number, 

o Contact information for the applicator and property owner/operator, 

o Time period in which the fumigation is planned to take place (must not range 

more than 4 weeks), 

o Early signs and symptoms of exposure to the fumigant(s) applied, what to do, and 

what emergency responder phone number to call (911 in most cases), and 

o How to find additional information about fumigants. 

The method for distributing information to neighbors must be described in the FMP and 

may be accomplished through mail, telephone, door hangers, or through other methods that can 

be reasonably expected to effectively inform people at residences and businesses within the 

required distance from the edge of the buffer zone. 

To clarify this measure, the following example is provided (see Figure G): 

• If the buffer zone is 125 feet, then these requirements apply to residences within 100 feet 

of the buffer zone. Either the applicator must monitor the area between the dotted house 

and the buffer zone or residents of the dotted house must be provided emergency 

response information. 

• The location of the cross-hatched house would not prompt any action. 

 If there are no residences or other occupied structures within 300 feet of the edge of the 

buffer zone, or if the buffer distance is the minimum of 25 feet, neither site monitoring nor 

providing information to neighbors is required. 

Figure G. Example Site Map for Informing Neighbors 

Treated field 

Buffer zone 

45 ft 

288 ft 

125 ft 

100 ft 
111 

iv. Notice to State Lead Agencies 

Ensuring fumigant users understand and comply with the new label requirements is an 

important component of the fumigant risk mitigation package since these requirements are 

designed to mitigate risks of concern for bystanders, handlers, and workers. Knowledge of the 

location and timing of fumigant applications allows enforcement officials to focus their 

compliance assistance and inspection efforts around periods when, and places where, 

fumigations are expected to occur. Therefore, in the July 2008 RED, the Agency required 

written notification of the appropriate state or tribal lead agency prior to fumigant applications. 

Following publication of the July 2008 REDs, the Agency received feedback from some 

states that were interested in receiving the notice because it would enhance their ability to 

provide technical assistance and assure compliance. However, the Agency also received 

comments from states that were concerned about the notification requirement largely due to 

resource constraints. Some states also indicated that they are already well-informed about when 

and where fumigations take place, and receiving specific notice of applications would create a 

paperwork burden rather than aid their compliance assistance and assurance programs. Some 

states recommended that, in lieu of receiving notice of fumigations, states could modify their 

cooperative agreements with EPA to incorporate specific strategies for assuring compliance with 

the new fumigant labels. States also suggested that rather than providing notice directly to states, 

fumigators could enter application information into a registrant-developed and maintained 

database. They suggested this would be an appropriate mechanism because it would standardize 

and streamline the process for applicators to provide the required information, and states could 

access and utilize information more quickly, with greater ease, and using fewer state resources. 

Based on consideration of public comments, the Agency still believes that compliance 

assistance and assurance is a critical component of the soil fumigant mitigation. EPA agrees that 

some states already have mechanisms in place to provide them with information needed to assist 

and assure compliance with new fumigant requirements, but other states are in need of additional 

information to accomplish this objective. The Agency also believes that all states in which 

fumigants are used will need to modify their cooperative agreements, to some extent, to 

incorporate strategies for compliance assistance and assurance to aid the transition from current 

labels to labels that reflect the new mitigation. 

While the Agency will continue to work with all state and tribal lead agencies on efficient 

ways to obtain the information needed to plan and implement compliance assistance and 

assurance activities, the Agency is currently retaining the notification requirement only for state 

and tribal lead agencies that choose to be notified of fumigant applications. The Agency plans to 

provide a website listing these state and tribal lead agencies and how and when these agencies 

want applicators to provide to them the following information: 

o Applicator and property owner/operator contact information (name, telephone 

number, and applicator license number) 

o Location of the application block(s) 

o Name of fumigant(s) products(s) applied including EPA Registration number 

o Time period in which fumigation may occur 
112 

The Agency will work with all states to amend their cooperative agreements to include 

strategies for compliance assistance and assurance, which will be particularly important over the 

next several years as the new mitigation measures are implemented. For states that do not 

choose to be notified of fumigant applications, modification of their cooperative agreements 

must include the methods these agencies will use to survey fumigation application periods and 

locations. 

v. Soil Fumigation Training for Applicators and Training Information 

for Other Handlers 

Soil fumigation is an inherently complex activity involving specialized equipment and 

application techniques. Additionally, the mitigation measures required as part of these decisions 

will introduce new requirements in the form of more detailed instructions and restrictions on soil 

fumigations. Failure to adequately manage fumigant applications increases risks to handlers 

involved in the fumigation, nearby workers, and other bystanders. Incident data show that a 

number of fumigant incidents are the result of misapplications, failure to follow label 

requirements and other safety precautions, and other errors on the part of fumigant applicators. 

Although states have certification programs, some of which include a specific category or 

subcategory for soil fumigation, there currently is not a consistent standard across states and 

regions where soil fumigation is done. Additionally, the federal certification program currently 

has no category for soil fumigation, and while EPA is considering the development of a category 

for soil fumigation, the potential changes to the federal certification program and worker safety 

regulations to include a soil fumigation category are not anticipated in the near future. 

EPA believes that training is an effective way to increase applicators’ skill and 

knowledge so they are better prepared to effectively manage the complexities and risks 

associated with soil fumigation. Further, training is a means of ensuring fumigators are able to 

understand and comply with revised fumigant labeling. Therefore, EPA determined that training 

designed to establish a national baseline for safe fumigant use, developed and implemented by 

registrants, will help enhance fumigators’ ability to adequately manage the complexities of soil 

fumigation and enhance compliance with fumigant product labeling. EPA also determined that 

providing additional safety information to other fumigant handlers will help them understand and 

adhere to practices that will help handlers protect themselves from risks of exposure. 

Soil Fumigation Training Considerations 

In comments on fumigant risk management options, stakeholders were broadly 

supportive of additional training for applicators and handlers. During the Phase 5 and post-RED 

comment periods, the majority of stakeholders, including growers, community groups, farm 

workers, states, and registrants expressed strong support for increased training for applicators 

and other handlers. Several comments noted that fumigant incidents affecting both fumigant 

workers and bystanders could have been prevented or mitigated if applicators had better training 

about correct practices and procedures. 

The Agency agrees that additional training for fumigant applicators and handlers will 

help educate and inform these workers, thus decreasing the likelihood of both incidents and 
113 

noncompliance. EPA believes fumigant-specific training for applicators and additional training 

information for handlers also will help reduce the magnitude and frequency of exposure 

incidents and, coupled with the other mitigation measures described in this decision, will address 

risks of unreasonable adverse effects from the use of soil fumigants. 

It is important to note that training developed and provided by registrants as required by 

this RED is separate and distinct from state certification programs. EPA encourages registrants, 

in developing their training proposals, to work with states where their products are used to 

identify opportunities to build on and complement state programs. However, the training 

programs required as part of this decision are intended to be separate from the state certification 

process and will be developed and administered by registrants. Individual state regulatory 

agencies have the option of working with registrants on these activities, but are not required to 

do so. It is important to note that some fumigant registrants have already developed soil 

fumigant training programs that will serve as a good basis for this expanded effort. 

As noted above, several states have high-quality certification programs for fumigators 

that include exams to test the competency of fumigators. EPA recognized that for applicators to 

become certified in those states, they must acquire the knowledge and skill necessary to pass the 

exam. But several stakeholders commented that training opportunities are varied across the 

country, and the scope and detail of information provided in available training is not consistent. 

EPA is also concerned that information in existing programs will need to be substantially 

updated as a result of new requirements associated with this decision and the label changes 

which will implement it. Although EPA is considering revisions to the federal certification and 

training program in the future to include a soil fumigation category/subcategory, EPA believes 

that registrants have access to resources and materials to best develop and deliver training in the 

interim. 

EPA stresses that registrant training programs will be separate from the state certification 

process and will be developed and administered by registrants in coordination with EPA. EPA 

will, however, work with state organizations and training experts to explore opportunities for the 

registrant programs to supplement any existing state programs to provide additional training 

resources for fumigators working in those states. EPA will also work with state lead agencies 

and extension programs to review training program proposals, the content for the programs and 

materials, and proposed vehicles for delivery. 

During the post-RED comment period, the Agency received comments from several 

states asking that the applicator training requirements be coordinated with existing state 

certification and training programs. The Agency agrees that for states that have existing soil 

fumigation certification programs that address the same training elements required of the 

registrant soil fumigant training programs, as outlined in this section of the RED addendum, 

applicators should be able to complete the state certification program in lieu of completing the 

registrant soil fumigation training. For the state soil fumigation certification program to qualify, 

both EPA and the state must agree that the program satisfies the applicator training elements 

required in the RED. 
114 

Pesticide labels will state that “Before applying the product, the certified applicator 

supervising that application must successfully complete a methyl bromide training program 

made available by the registrant within the last 36 months. The Fumigant Management Plan (see 

details elsewhere on this label) must document when and where the registrant-provided training 

program or state certification was completed. This requirement for registrant-provided 

applicator training does not supersede or fulfill state requirements, unless the state has expressly 

acknowledged that the registrant training may substitute for state requirements.” 

Training for Applicators Supervising Fumigations 

The July 2008 RED required registrants to develop and implement training programs for 

applicators in charge of soil fumigations on the proper use of and best management practices for 

soil fumigants. During the public comment period on the proposed mitigation measures and the 

post-RED comment period, stakeholders were broadly supportive of additional training for 

fumigators, but concerns were raised with regard to implementation of the training. The Agency 

also received comments from state representatives and pesticide applicator training 

organizations, such as the Association of American Pesticide Control Operators, Association of 

American Pesticide Safety Educators, and Certification & Training Assessment Group, 

expressing concern over EPA’s decision to implement the training via labeling and raising 

questions over compliance and state enforcement of such a requirement and the potential for 

conflict or redundancy with state certification and training programs. Various stakeholders 

recommended that, rather than a label-mandated training requirement, the Agency, instead, 

should require registrants to develop and implement training for soil fumigant applicators as a 

condition of registration. 

The Agency’s goal in requiring soil fumigation training for applicators is to ensure that 

all applicators in charge of soil fumigations understand the safe use of soil fumigants and in how 

to apply products in compliance with new product labeling, including provision required by the 

RED. Given the unique properties of soil fumigants and their application and safety procedures 

compared with other agricultural and non-agricultural pest control practices, the inherent 

complexities involved in soil fumigant applications, and the additional complexities that will 

arise with the implementation of the REDs, the Agency feels that additional training, beyond that 

available currently, will be needed. The states that currently have certification programs that 

include soil fumigation categories will not have requirements pertaining to the new mitigation 

and their programs will need to be modified. EPA agrees that making the required training 

programs a condition of registration is an important means of ensuring that such training is 

ultimately developed and implemented. However, it would not ensure that all individuals in 

charge of soil fumigant applications avail themselves of the training. The Agency believes that 

making successful completion of the training a condition of use is also important to achieve this 

goal. Therefore, EPA has decided that development and delivery of training will be included in 

the DCI that accompanies this RED and successful completion of the training will remain a 

condition of use. 

Each registrant must develop and implement training programs for applicators in charge 

of soil fumigations on the proper use of and best practices for soil fumigants. In addition, 

registrants will be required to submit proposals for these programs as data requirements that will 
115 

accompany this RED. EPA will review each program and determine whether it adequately 

addresses the requirements specified in the DCI. The proposal must address, among other 

elements, both the content and the format for delivering training. The Agency acknowledges the 

value of hands-on training in the field, but recognizes that may not be feasible in all instances. 

The Agency welcomes and is actively seeking participation from state lead agencies and 

extension programs in the evaluation of the registrant training proposals and materials that are 

submitted. 

The training programs must address, at a minimum, the following elements: (1) how to 

correctly apply the fumigant, including how to comply with new label requirements; (2) how to 

protect handlers and bystanders; (3) how to determine buffer zone distances; (4) how to develop 

a FMP and complete the post-fumigation application summary; (5) how to determine when 

weather and other site-specific factors are not favorable for fumigant application; and (6) how to 

comply with required GAPs and how to document compliance with GAPs in the FMP. In 

addition, based on comments received during the post-RED comment period, the Agency is 

adding a seventh training element—training programs must also include information on how to 

develop and implement emergency response plans—to ensure that applicators are prepared in the 

event that a problem develops during or shortly after the fumigant application. EPA is also 

requiring registrants to incorporate a mechanism for evaluating the effectiveness of their training 

programs at conveying the required information to participants and for determining whether 

participants have successfully completed the training program. 

To assist states in enforcing these training requirements, the registrants will be required to 

(1) develop a database to track which certified applicators have successfully completed the 

training, (2) make this database available to state and/or federal enforcement entities upon 

request, and (3) provide documentation (e.g., a card) to each training participant who 

successfully completes the training. This documentation shall include the applicator’s name, 

address, license number, and the date of completion. Applicators must provide to federal, state, 

or local enforcement personnel, upon request, this documentation that verifies successful 

completion of the appropriate training program(s). 

In the July 2008 RED, the Agency required applicators supervising fumigations to 

complete the training annually. During the post-RED public comment period, the Agency 

received comments from various stakeholders indicating that the substance and content of 

training would not change significantly from year to year, and that an annual training 

requirement for applicators would be excessive and burdensome to both applicators and 

registrants and was unnecessary. As a result of these comments, the Agency has decided to 

require applicators supervising fumigations to have successfully completed the program within 

the preceding 36 months and to document when and where the training program was completed 

in their FMPs. This may be accomplished, for example, by simply attaching a copy of the 

training documentation provided by the registrant to the FMP. The registrant also must be able 

to provide to federal, state, or local enforcement personnel, upon request, the names, addresses, 

and certified applicator license numbers of persons who successfully completed the training 

program, as well as the date of completion. 
116 

Based on questions received during the post-RED comment period, the Agency is 

clarifying that the applicator training requirements are active ingredient-specific rather than 

product-specific. That is, applicators who apply more than one of the soil fumigant active 

ingredients (i.e., methyl bromide, chloropicrin, metam sodium/potassium, or dazomet) will be 

required to complete training for each soil fumigant active ingredient they apply, but not for each 

different product containing the same active ingredient(s). Further, EPA encourages the soil 

fumigant registrants to jointly develop programs to reduce the redundancy of this training 

requirement. For example, a substantial portion of the required training is universal to all soil 

fumigants. Therefore modules addressing the information common to all could be generic and 

each fumigator would participate in those modules, while separate modules addressing active 

ingredient-specific content could be provided to those fumigators supervising applications with 

those active ingredients only. Documentation provided to trainees could indicate the active 

ingredient modules completed. While EPA sees efficiencies in such an approach, it will be the 

registrants’ choice as to how they will comply with the requirement to develop and implement 

training programs.

Training Materials for Handlers 

EPA is requiring registrants to prepare and disseminate training information and 

materials for other fumigant handlers, i.e., those working under the supervision of the certified 

applicator in charge of fumigations. The Agency is requiring registrants to submit proposals for 

these materials through the data call-ins that will accompany this RED. EPA will review these 

materials to determine whether they adequately address the requirements specified in the DCI. 

The Agency welcomes and is actively seeking participation from state lead agencies and 

extension programs in the evaluation of these handler training materials. 

 The training materials must address, at minimum, the following elements: (1) what 

fumigants are and how they work, (2) safe application and handling of soil fumigants, (3) air 

monitoring and respiratory protection requirements for handlers, (4) early signs and symptoms of 

exposure, (5) appropriate steps to take to mitigate exposures, (6) what to do in case of an 

emergency, and (7) how to report incidents. Registrants must provide this training information 

through channels open to the public (e.g., via a website). Pesticide labels will require that 

applicators supervising fumigations provide this training information to handlers under their 

supervision before they perform any fumigant handling task, or they must ensure that handlers 

have been provided the required information within the preceding 12 months. The label will also 

require that the training information be provided in a manner that the handler can understand. 

Applicators supervising fumigations must ensure the FMP includes how and when the required 

training information was provided to the handlers under their supervision. 

“The certified applicator must provide fumigant safe handling information to each 

handler involved in the application in a manner that they can understand prior to 

performing any fumigant handling task or confirm that each handler participating in 

the application has received fumigant safe handling information in the past 12 

months.” 
117 

During the post-RED comment period, no substantive comments were received that 

resulted in changes to the RED requirements for training materials for handlers, as a result, these 

requirements are identical to those published in the July 2008 RED. However, during the 

comment period, the Agency received comments indicating that there was some confusion about 

whether fumigant handlers working under the supervision of the certified applicator would be 

required to be trained, i.e., participate in a training program developed by the soil fumigant 

registrant(s), or whether handlers would need only to be provided with training information and 

materials. The Agency wishes to clarify that handler participation in a registrant training 

program, per se, is not required. As noted above, applicators supervising a soil fumigation will 

be required to provide the registrant-developed, EPA-approved training information to handlers 

in a manner that they can understand prior to performing any fumigant handling task, or 

applicators must ensure that the handler has been provided the required information within the 

proceeding 12 months. 

vi. Community Outreach and Education Programs 

EPA understands from public comments, site visits, and stakeholder meetings, conducted 

as part of the soil fumigant review, that there is often a fundamental lack of information and 

communication about soil fumigants within communities where soil fumigation occurs, which 

has raised health and safety concerns among community members. This lack of information and 

communication has led to inappropriate responses in cases where fumigants have moved off site 

and into communities. This also has led, in some cases, to unwarranted concern and anxiety 

among communities about the risks associated with the use of fumigants. The Agency believes 

that outreach and education to communities where soil fumigation occurs is an important 

component of the overall package of measures to address bystander risk. Community outreach 

will address the risk of acute bystander exposure by informing community members in high-use 

areas about buffer zones and their characteristics and purpose, the meaning of posted warning 

signs, the importance of not entering buffer zones, how to recognize early signs of fumigant 

exposure, and how to respond appropriately in case of an incident. 

In the July 2008 RED, the Agency required registrants to develop and implement 

community outreach and education programs to address these needs. At a minimum, these 

programs were to include the following elements: (1) what soil fumigants are and how they 

work, (2) what buffer zones are, (3) early signs and symptoms of exposure, (4) appropriate steps 

to take to mitigate exposures, (5) what to do in case of an emergency, and (6) how to report an 

incident as well as a plan for evaluating the effectiveness of these programs. Few details on how 

the programs would be implemented were provided in the RED. Rather, during the post-RED 

comment period, the Agency sought feedback from the registrants and other stakeholders on how 

best to design and target programs to community members in high-use areas. The Agency 

encouraged the registrants to work with existing community resources, such as community 

health networks, for disseminating information and implementing community outreach 

programs. 

During the post-RED comment period, the Agency received some comments from 

stakeholders that suggested that having registrants develop and implement a community outreach 

and education program is unnecessary and likely to needlessly raise heath and safety concerns 
118 

among community members, and such a requirement could draw scarce resources from other 

registrant stewardship efforts. As noted previously, the Agency believes that providing basic 

information about soil fumigants and buffer zones as well as information on what to do in the 

event that an incident occurs to communities in high fumigant use areas is an important 

component of the overall package of risk mitigation measures to address bystander risk. EPA’s 

community outreach requirements do not preclude other voluntary stewardship programs or 

activities targeted to community members or the applicator/grower community, but rather are 

meant to help ensure that community members in high fumigant usage areas are informed about 

soil fumigant safety and better able to respond appropriately if an incident were to occur. 

Few recommendations and no specific proposals for these programs were received during 

the post-RED comment period. Therefore, the Agency is identifying minimum requirements that 

each registrant must fulfill when developing its community outreach programs in response to a 

DCI that will be issued. The Agency remains open to considering additional registrant outreach 

program elements that address the same needs and goals as the program requirements described 

below in their response to the DCI. EPA notes that some stakeholders have suggested that 

programs focusing on specific target audiences may be more effective in providing useful 

information in a meaningful way than broadcast messages to entire communities. Registrants 

have indicated that they will provide proposals for such programs in late May 2009. EPA looks 

forward to these proposals and will consider the extent to which they contribute to meeting the 

goals of the community outreach programs required by the RED. 

In the absence of acceptable alternative proposals, registrants, will be required to provide 

information to communities in the form of monthly public service announcements (PSAs) 

distributed via local radio stations or newspapers in high-use fumigant areas during the 

fumigation season(s) in those areas. As per the requirements included in the July 2008 RED, at a 

minimum, registrants must include the following information in their community outreach 

messages: (1) what soil fumigants are and how they work, (2) what buffer zones are, (3) early 

signs and symptoms of exposure to methyl bromide, (4) appropriate steps to take to mitigate 

exposures to methyl bromide, (5) what to do in case of an emergency, and (6) how to report an 

incident as well as a plan for evaluating the effectiveness of these programs. Based on 

comments, EPA has decided that information on the meaning of posted warning signs is also 

important to help ensure the signs convey the needed information about the importance of 

staying out of buffer zones and treated areas. 

The Agency is requiring registrants to implement their outreach programs in communities 

located in areas where there is high soil fumigant use. For the purposes of the RED addendum, 

high-use areas are considered at the county level. To identify these areas, the Agency is 

proposing a process for identifying high-use areas in the subsection following the section on 

information for first responders. However, the Agency is willing to consider alternative 

proposals for identifying high soil fumigant-use areas, based on additional data sources and 

alternate approaches identified by the registrant(s) and other stakeholders. 
119 

Information for First Responders 

In the July 2008 RED, the Agency required registrants to ensure that first responders in 

areas with high fumigant usage have the training and information that they need to effectively 

identify and respond to fumigant exposure incidents. Specifically, the registrants were required 

to provide information and/or training to first responders, which at a minimum, included the 

following elements: (1) how to recognize the early signs and symptoms of fumigant exposure, 

(2) how to treat fumigant exposures, and (3) how fumigant exposure differs from other pesticide 

exposure. In addition, the registrants were required to provide material safety data sheets to first 

responders for the fumigant applied. Few details on how the education programs would be 

implemented were provided in the RED. Rather, during the post-RED comment period, the 

Agency sought feedback from the registrants and other stakeholders on how best to design and 

target programs to first responders in high-use areas. The Agency encouraged the registrants to 

work with state and local emergency response coordinators to identify needs and opportunities to 

supplement any information already included in state and local training for first responders about 

soil fumigants specifically. 

During the post-RED comment period, the Agency received comments from several 

registrants indicating that rather than requiring registrants to implement face-to-face training 

programs, the Agency should consider allowing the required first responder training information 

to be conveyed via written materials to state and local emergency response agencies, which 

would provide these agencies the ability to incorporate this information into their existing 

training programs. Other comments indicated that even if training programs were developed, it 

would be difficult to ensure participation of first responders. The Agency’s goal for the first 

responder training program is to ensure that first responders in high use fumigant areas have 

access to the information that they need to be able to quickly and effectively identify an exposure 

that is fumigant related and respond appropriately. The Agency agrees that this goal can be met 

by requiring the soil fumigant registrants to develop informational materials on the soil 

fumigants and distribute this information to first responders (i.e., police, fire, rescue, emergency 

medical services, and others who respond to “911” calls) in high soil fumigant-use areas. This 

would then provide the first responder entities the ability to incorporate this information into 

their existing first responder training programs as they best see fit. This recommendation has 

been incorporated into the RED amendments for the soil fumigants. 

The Agency is willing to consider additional registrant proposals so long as they address 

the same needs and achieve the same goals as the program requirements described below. At a 

minimum, registrants will be required to develop and disseminate chemical-specific soil 

fumigant training materials to first responders (i.e., police, fire, rescue, emergency medical 

services, and others who respond to “911” calls) operating in high fumigant-use areas. As a data 

requirement in the DCIs that will accompany the REDs, registrants must submit proposals 

detailing how they will (1) identify the firstresponder entities in high soil fumigant-use areas to 

which they will disseminate the training materials, and (2) provide materials to the first 

responders in these areas. Additionally registrants must provide draft copies of the training 

materials for EPA review and approval. As per the requirements included in the July 2008 RED, 

at a minimum, the materials must convey the following information to first responders: (1) how 

to recognize the early signs and symptoms of methyl bromide fumigant exposure, (2) how to 
120 

treat methyl bromide fumigant exposures, and (3) how methyl bromide fumigant exposures 

differ from other pesticide exposures as well as (4) copies of material safety data sheet(s) for the 

fumigant applied as well as for the active compound generated, if applicable. Training materials 

can take a number of forms (e.g., brochures, fact sheets, CDs, videos, web-based training 

materials) as long as these materials incorporate, at a minimum, the information requirements 

identified above. 

The Agency is requiring registrants to target their first responder training information to 

those communities located in high soil fumigant-use areas. For the purposes of the RED, highuse areas are considered at the county level. To identify these areas, the Agency is proposing the 

following process. However, the Agency is willing to consider alternative proposals in the 

registrants’ response to the DCIs for identifying and targeting high-use soil fumigant areas, based 

on additional data sources and alternate approaches identified by the registrant(s). 

Process for Identifying High-Use Fumigant Areas: 

 Identifying high-use areas for methyl bromide is a two-step process because reliable 

fumigant use data is not available at the county level from either publicly available data sources 

or EPA proprietary data sources. First, the states with high use of methyl bromide have been 

identified by the Agency using EPA proprietary data. Second, the high-use counties for methyl 

bromide within those states must be identified. The second step, identifying high-use counties, 

will be the registrant’s responsibility, using the process defined below. 

• Step 1: Identifying States with High Use of Methyl Bromide: The Agency is defining 

states with high usage of methyl bromide as those states where, on average, more than 

100,000 lbs of methyl bromide or chloropicrin are applied annually. To determine those 

states where, on average, more than 100,000 lbs of methyl bromide or chloropicrin have 

been applied annually, the Agency obtained data on the average number of pounds of 

methyl bromide and chloropicrin applied in all states across a ten–year period (1999-

2008) using EPA proprietary data. To view the Agency’s analysis of this data, please see 

the Biological and Economic Analysis Division’s (05/14/09) memo, “Process for 

Defining High-Use Fumigation Areas at the State and County Levels (DP# 364647)” and 

supporting documentation located in the methyl bromide docket at EPA-HQ-OPP-2005-

0123. The states identified for methyl bromide and chloropicrin are Washington, 

Oregon, Idaho, South Carolina, Georgia, North Carolina, California, Florida, and 

Michigan. 

• Step 2: Identifying Counties with High Use of Methyl Bromide: For each of the high-use 

states that the Agency identified in Step 1, the registrants will be required to identify the 

counties where use of methyl bromide may be high. Because county-level fumigant 

usage data is not publicly available and EPA proprietary data are not appropriate for this 

level of specificity, crop acreage should be used as a surrogate indicator for fumigant 

usage. Crop acreage can be obtained for major use sites of methyl bromide from the 

publicly available 2007 USDA Census of Agriculture. Crop acreages for each of the 

major use sites for methyl bromide should be and then summed by county. All counties 

making up at least the top 90% of acreage in a state are considered high-use areas. 
121 

Registrants will be required to target each of these high-use counties for community 

outreach programs. 

For the purposes of this analysis, the Agency defines a “major use site” as any crop that 

has more than 5% crop treated annually or more than 100,000 lb of methyl bromide or 

chloropicrin applied annually. The crops identified for methyl bromide are cantaloupes, 

peppers, squash, strawberries, tomatoes, and watermelons. 

Example Identifying High-Use Fumigant Areas for Metam Sodium in California: 

 To help explain the process for identifying high-use fumigant areas for methyl bromide 

the Agency is providing the following example, which identifies the high-use counties for the 

soil fumigant, metam sodium, usage in California. 

• Step 1: Identify States with High Use of Metam Sodium:

o Based on its analysis of proprietary data, the Agency has identified the following 

high-use states for metam sodium: California, Washington, Idaho, Oregon, 

Wisconsin, Michigan, Florida, Minnesota, North Carolina, Virginia, Arizona, 

Nevada, Georgia, Colorado, and North Dakota. This example will focus only on 

identifying the counties in California with high use of metam sodium. The same 

process would be applied to other high-use states. 

• Step 2: Identify the Counties in California with High Use of Metam Sodium:

o EPA has identified the following as the major use sites of metam 

sodium/potassium: artichokes, cabbage, cantaloupes, carrots, onions, peanuts, 

peppers, potatoes, spinach, squash, tomatoes, and watermelons. 

o Using the 2007 USDA Census of Agriculture, registrants will need to obtain 

harvested crop acreage data for each of the 12 major use sites for metam sodium 

identified above for each county in California. (An example of this analysis is 

provided as a supporting document to the Biological and Economic Analysis 

Division’s (05/14/09) memo, “Process for Defining High-Use Fumigation Areas 

at the State and County Levels (DP# 364647),” which is located in the metam 

sodium docket at EPA-HQ-OPP-2005-0125. 

o Registrants will then need to sum the total number of combined crop acres for 

these major use sites for each county in California and then select all the counties 

that make up at least the top 90% of acreage in the county. [An example of this 

analysis is also provided as a supporting document to the Biological and 

Economic Analysis Division’s (05/14/09) memo, “Process for Defining High-Use 

Fumigation Areas at the State and County Levels (DP# 364647),” which is 

located in the metam sodium docket at EPA-HQ-OPP-2005-0125.] 

As with the training for fumigant applicators and handlers and the community outreach 

program that the Agency is requiring, the first responder training requirements are intended to be 

part of the registrants’ long-term product stewardship. The Agency encourages registrants to 

work with appropriate state emergency response entities in these areas to ensure that the 
122 

appropriate first responder entities are being targeted and that the information being provided to 

first responders is both useful and presented appropriately. 

c. Environmental Risk Management 

In the July 2008 RED, EPA addressed the concerns for both aquatic and terrestrial risks 

which are mentioned in Section III.D. The July 2008 RED also stated that EPA believed that 

mitigation measures detailed in the Human Health Risk Mitigation section would also reduce 

ecological risks. The Agency stated that although buffer zones and GAPs do not directly reduce 

the potential risk to ecological organisms, these mitigation measures do provide an incentive to 

reduce fumigant application rates and individual treatment areas which in turn will contribute to 

lower exposure and risks for non-target organisms. 

In the July 2008 RED, EPA deviated from the Label Review Manual language because 

dissipation of methyl bromide in aquatic environments is predominately dependent on 

volatilization and to a lesser extent on leaching and degradation. In addition, as discussed in the 

Human Health Risk Mitigation section managing soil moisture is an important factor that may be 

used to reduce peak emissions. Due to the importance of adequate soil moisture as described in 

the GAP section and the knowledge that volatilization is methyl bromide’s most important route 

of dissipation, EPA required the following language in the July 2008 RED taking these factors 

into consideration , “While methyl bromide has certain properties and characteristics in common 

with chemicals that have been detected in groundwater (methyl bromide is highly soluble in 

water and has low adsorption to soil), volatilization is this chemical's most important route of 

dissipation.” 

 The Agency still believes that a deviation from the recommended language in the Label 

Review Manual is necessary due to the importance of soil moisture and methyl bromide’s 

volatility. While the Agency believes that volatilization is this chemical’s most important route 

of dissipation, it is being removed from the groundwater statement because volatilization is 

addressed in other areas of the mitigation package. The new language will state, “Methyl 

bromide has certain properties and characteristics in common with chemicals that have been 

detected in groundwater (methyl bromide is highly soluble in water and has low adsorption to 

soil).” 

 EPA also discussed, in the July 2008 RED, the potential for methyl bromide to leach into 

groundwater when tarps are used in broadcast applications: falling temperatures typically found 

in the late afternoon and evening would not promote dissipation of remaining methyl bromide 

under the perforated tarp and rainfall may cause remaining methyl bromide under the perforated 

tarp to leach into groundwater. For raised bed applications, rainfall is not a factor since planting 

occurs with the tarp in place and perforation and/or tarp removal occurs after methyl bromide has 

dissipated. In the 2008 RED, EPA required that tarps for broadcast applications must be 

perforated before noon and only when rainfall is not expected within 12 hours. The Agency is 

keeping this requirement in the amended RED. The language is included in the Tarp Perforation 

and Removal section of this document. 
123 

 The July 2008 RED also discussed the potential for methyl bromide to leach into 

groundwater and surface water if a rainfall event occurs after an untarped application. Methyl 

bromide may impact surface water quality due to runoff of rain water. This is especially true for 

poorly draining soils and soils with shallow ground water. 

 The Agency modified this language in the July 2008 RED due to the importance of soil 

moisture and methyl bromide’s volatility. The Agency required the following language in the 

July 2008 RED, “For untarped applications of methyl bromide, potential leaching into 

groundwater and runoff into surface water can be reduced by avoiding applications when heavy 

rainfall is forecasted to occur within 24 hours.” 

 During the post-RED comment period commenters stated that the above July 2008 RED 

language was not clear or enforceable. EPA would like to clarify that the statement was meant to 

be advisory and not mandatory. However in an effort to clarify the requirement the Agency has 

revised the July 2008 RED language as follows, “For untarped applications, leaching, and runoff 

may occur if there is heavy rainfall after soil fumigation.” This is more likely in areas with poor 

draining soils. The revised statement is based on information presented in a 2007 article by 

Zhang and Wang.19

In addition to the changes above, EPA is requiring several ecological fate and effect 

studies to address data gaps identified in the ecological risk assessment. See Section V of this 

document for details for revised label language and the studies. 

d. Stratospheric Ozone Depletion Risk Management 

 While a quantitative reduction of methyl bromide’s role in the depletion of stratospheric 

ozone resulting from the mitigation measures required by this decision can not be estimated, 

EPA believes that when looking at the mitigation as a whole, it can be qualitatively determined 

that a reduction will result. The following supports this conclusion: 

 

19 Zhang, Y. and Wang, D. 2007. Emission, distribution, and leaching of methyl isothiocyanate and chloropicrin 

under different surface containments. Chemosphere, 2007 Jun; 68(3): 445-454. 
124 

Required Mitigation 

Measure

Rationale for expecting a reduction of 

Stratospheric Ozone Depletion

• Removal of uses with low 

benefits and/or available 

alternatives (i.e., ineligibility 

for uses that do not qualify for 

exemptions from the Montreal 

Protocol) 

► While the Agency acknowledges that limiting use 

to only Group 1 uses may slow the drawdown of 

the pre-2005 stockpile, it is reasonable to expect 

that new production for exempted uses will also 

continue to decline as there will be more pre-2005 

stockpile material available for critical uses. The 

Agency believes that that this measure could 

contribute to the reduction of methyl bromide 

applied annually. 

• Reducing maximum application 

rates; 

► The Agency is limiting the labeled maximum 

application rates for CUE uses based rates from the 

most recent CUNs. Any reduction in application 

rate will result in less methyl bromide applied. 

• Limiting use of 98:2 

formulations to essential crops 

► When 98:2 formulations are used, the amount of 

methyl bromide applied is generally higher 

compared to amount applied for other 

formulations. Limiting the use of 98:2 

formulations to only essential crops will result in 

less methyl bromide applied. 

• Buffer zones ► To achieve manageable buffer zone distances, 

many growers will be required to change their 

current cultural practices, including lowering rates, 

using high barrier tarps, using more efficacious 

application methods, using alternatives, etc. 

Overall, these changes will result in lower 

application rates and less methyl bromide 

volatilizing into the atmosphere. 

• GAPs and FMPs ► GAPs and FMPs will both result in better planning 

of fumigations and increase the likelihood of a safe 

and effective application. The Agency believes 

that these measures will also, to some degree, 

result in less methyl bromide volatilizing into the 

atmosphere. 

2. Endocrine Disruptor Effects 

EPA is required under the FFDCA, as amended by FQPA, to develop a screening 

program to determine whether certain substances (including all pesticide active and other 

ingredients) “may have an effect in humans that is similar to an effect produced by a naturally 

occurring estrogen, or other such endocrine effects as the Administrator may designate.” 

Following the recommendations of its Endocrine Disruptor Screening and Testing Advisory 

Committee (EDSTAC), EPA determined that there were scientific bases for including, as part of 

the program, androgen and thyroid hormone systems, in addition to the estrogen hormone 
125 

system. EPA also adopted EDSTAC’s recommendation that the Program include evaluations of 

potential effects in wildlife. When the appropriate screening and/or testing protocols being 

considered under the Agency’s Endocrine Disrupter Screening Program (EDSP) have been 

developed and vetted, methyl bromide may be subjected to additional screening and/or testing to 

better characterize effects related to endocrine disruption. 

3. Endangered Species Considerations 

 The Agency has not conducted a risk assessment that supports a complete endangered 

species determination. The ecological risk assessment planned during registration review will 

allow the Agency to determine whether methyl bromide use has “no effect” or “may affect” 

federally listed threatened or endangered species (listed species) or their designated critical 

habitats. When an assessment concludes that a pesticide’s use “may affect” a listed species or its 

designated critical habitat, the Agency will consult with the U.S. Fish and Wildlife Service 

and/or National Marine Fisheries Services (the Services), as appropriate. 

D. Conclusions 

The Agency has determined that Group 1 uses of methyl bromide are eligible for 

reregistration as long as they have CUE or QPS status under the Montreal Protocol, and provided 

the risk mitigation measures outlined above are adopted and label amendments are made to 

reflect these measures. Where labeling revisions are warranted, specific language is set forth in 

the label table in Section V of this document. Any Group 1 uses that no longer qualify for CUE 

and QPS status should be canceled. Group 2 uses are not eligible for reregistration. 

V. What Registrants Need to Do 

EPA recognizes that the extent of the mitigation needed for methyl bromide and the other 

soil fumigants will require continued coordination among state regulatory agencies, EPA, 

registrants, growers and other stakeholders to ensure that all provisions of the RED are 

understood, that data are developed and evaluated expeditiously, and that bystander and worker 

protection measures are implemented as soon as practicable. 

When the soil fumigant REDs were issued in July, 2008, EPA specifically requested 

comment on the mechanisms and timing of implementing the provisions of the REDs. After 

considering stakeholder comments largely focused on the challenges of implementing many new 

measures simultaneously, EPA has developed the following schedule: 

July 2008 Methyl Bromide RED issued 

October 2008 Comment period closed 

May 2009 EPA responds to comments, amends RED as appropriate 

Mid 2009 EPA issues product and generic DCIs 

September 1, 2009 Registrants must submit revised labels to EPA, reflecting phase one of 

the mitigation measures as outlined in Table 2: restricted use, GAPs, rate 

reductions, limitations on use sites, new handler protection measures, tarp 

cutting and removal restrictions, extended worker re-entry restrictions, 
126 

training information for workers, and relevant portions of the FMP 

requirements. 

December, 2009 EPA reviews/approves new labeling for 2010 use season. 

During 2009-10 EPA works with registrants, states and stakeholders to develop and begin 

implementation of first responder and community outreach, applicator 

training, and compliance assistance and assurance measures. 

September 1, 2010 Registrants must submit revised labels to EPA reflecting all remaining 

mitigation measures outlined in Table 2 including: 

 applicator training, restrictions on applications near sensitive sites, buffer 

zones, buffer credits, buffer zone posting and buffer overlap prohibitions 

and exceptions, and the full FMP requirements. 

2009-2012 Registrants develop data per DCIs. 

2013 EPA begins Registration Review for methyl bromide and other fumigants. 

Labeling

Registrants must submit labeling reflecting phase one mitigation measures by September 

1, 2009. All measures will need to be reflected on labels submitted to EPA by September 1, 

2010. Because of the relatively large amounts of product shipped under a single label, e.g., 50 

gallon drums and railroad tank cars, changes to fumigant labeling can be adopted relatively 

quickly. Therefore, the Agency anticipates that labeling approved late in 2009 would begin to 

appear on products used for the 2010 fumigation season. 

A. Manufacturing Use Products 

1. Additional Generic Data Requirements 

The generic data base supporting the reregistration of methyl bromide’s preplant soil uses 

has been reviewed and determined to be substantially complete. However, the data listed below 

are necessary to confirm the reregistration eligibility decision documented in this RED. 

a. Human health risk 

Toxicity: none 

Dietary Exposure: none 

Occupational and Residential Exposure (ORE): 

The following data are needed on methyl bromide for human health risk assessment: 

• Field Emissions/Volatility: The current estimates of emissions which are critical in the 

calculation of modeling estimates used to define buffer zones are limited only to California 

OPPTS Guideline Number Data Requirement Study type 

OPPTS Guideline 835.8100 Field volatility from soil Field Emissions 
127 

and are not based on the most current cultural practices. These data will enable a more 

refined inhalation risk assessment to be completed for buffer zone determinations that will 

allow evaluations to be completed in all of the major use regions of the country and that are 

reflective of the most current cultural practices. It is believed that application practices have 

rapidly evolved over the last few years to account for the requirements of the Montreal 

Protocol implementation and phase out strategy for methyl bromide. 

b. Environmental fate and ecological risk 

Environmental fate: none 

Ecological effects: 

The following data are needed on methyl bromide (and the bromide ion, where indicated) for 

ecological risk assessment20.

• Avian acute inhalation. The current estimate of avian risk is based largely on the mammal 

assessment. This study will enable an inhalation risk assessment specific to birds. 

• Acute Fish Toxicity - bluegill trout. RQs for bluegill trout approach the EPA’s LOC. The 

risk assessment is currently relying on a Supplemental study for rainbow trout and various 

general literature toxicity values for other species. 

• Acute Marine/Estuarine Fish. Given the use patterns of methyl bromide, marine/estuarine 

species could be exposed. This study will enable a risk assessment specific for 

marine/estuarine species exposure. 

• Acute Marine/Estuarine Mollusk. Given the use patterns of methyl bromide, 

marine/estuarine species could be exposed. This study will enable a risk assessment specific 

for marine/estuarine species exposure. It will also improve certainty with the endangered 

species risk assessment, as this test species may be more representative of endangered 

freshwater mussels than the freshwater Daphnia. 

 

20 EPA-HQ-OPP-2005-0123-0038, Reregistration Environmental Risk Assessment for Methyl Bromide, June 8, 

2004, DP Barcode 304641 

OPPTS Guideline Number Data Requirement Study type 

Special Avian acute inhalation ECO 

850.1075 Acute Fish Toxicity - bluegill trout ECO 

850.1075 Acute Marine/Estuarine Fish ECO 

850.1025 Acute Marine/Estuarine Mollusk ECO 

850.1035 Acute Marine/Estuarine Shrimp ECO 

850.4225 Seedling Emergence – Tier II ECO 

850.4250 Vegetative Vigor – Tier II ECO 

850.4400 Aquatic Plant Growth – Tier II ECO 

850.3020 Honeybee Acute Contact ECO 
128 

• Acute Marine/Estuarine Shrimp. Given the use patterns of methyl bromide, marine/estuarine 

species could be exposed. This study will enable a risk assessment specific for 

marine/estuarine species exposure. 

• Seed Germination/Seedling Emergence - Tier II. Methyl bromide is used in part due to its 

phytotoxicity at the application site, and a wide range of open literature and other nonguideline studies indicate the potential for plant damage. This study will enable the 

assessment of risk to nontarget terrestrial plants off-site. 

• Vegetative Vigor - Tier II. Methyl bromide is used in part due to its phytotoxicity at the 

application site, and a wide range of open literature and other non-guideline studies indicate 

the potential for plant damage. This study will enable the assessment of risk to non-target 

terrestrial plants off-site. 

• Aquatic Plant Growth - Tier II. Methyl bromide is used in part due to its phytotoxicity at the 

application site, and a wide range of open literature and other non-guideline studies indicate 

the potential for plant damage. This study will enable the assessment of risk to non-target 

aquatic plants off-site. The current assessment used a non-guideline open literature toxicity 

value. 

• Honeybee Acute contact - This basic study is now being requested for virtually all outdoor 

uses, and will help determine the need for, and specifics of, bee hazard labeling. 

c. Other data requirements 

• Special Study - Community Outreach and Education Program

The Agency is requiring registrants to develop and implement community outreach 

programs, including programs for first responders, to address these needs. Community outreach 

programs must include the following elements, at minimum: (1) what soil fumigants are and 

how they work, (2) what buffer zones are, (3) early signs and symptoms of exposure, (4) 

appropriate steps to take to mitigate exposures, (5) what to do in case of an emergency, (6) how 

to report an incident, (7) information on how to develop and implement emergency response 

plans, and (8) a mechanism for evaluating the effectiveness of their training programs at 

conveying the required information to participants and for determining whether participants have 

successfully completed the training program. EPA expects registrants’ proposals for the first 

responder programs described in Section IV will also be designed to integrate with existing local 

first-response and emergency preparedness networks. 

OPPTS Guideline Number Data Requirement Study type 

Special Community Outreach and Education Program Special 

Special Training for Applicators Supervising 

Fumigations Special 

Special Training Materials for Handlers Special 
129 

• Special Study - Training for Applicators Supervising Fumigations

EPA has determined that training, developed and implemented by registrants to foster 

product stewardship, will help reduce potential risks associated with failure to adequately 

manage the complexities of fumigation, and failure to comply with fumigant product labeling. 

Additionally, EPA believes that providing safety information to other fumigant handlers will 

help them understand and adhere to practices that will help handlers protect themselves from 

risks of exposure. 

Registrants are required to develop and implement training programs for applicators in 

charge of soil fumigations on the proper use of and GAPs for soil fumigants. EPA is requiring 

registrants to submit proposals for these programs. The training programs must address, at 

minimum, the following elements: how to correctly apply the fumigant; how to protect handlers 

and bystanders; how to determine buffer zone distances; how to develop a FMP and complete the 

post fumigation application summary; how to determine when weather and other site-specific 

factors are not favorable for fumigant application; how to comply with required GAPs and 

document compliance in the FMP. The training program must be made available to applicators 

at least annually. The registrant shall provide documentation, such as a card or certificate, to 

each applicator who successfully completes the training. This documentation shall include the 

applicator’s name, address, license number, and the date of completion. The registrant must be 

able to provide to federal, state, or local enforcement personnel, upon request, the names, 

addresses, and certified applicator license numbers of persons who successfully completed the 

training program, as well as the date of completion. Applicators supervising fumigations must 

have successfully completed the program within the preceding 36 months and must document 

when and where the training program was completed in the FMP. The registrants will be 

required to (1) develop a database to track which certified applicators have successfully 

completed the training and (2) make this database available to state and/or federal enforcement 

entities upon request. In addition, the applicator must provide to Federal, State, or local 

enforcement personnel, upon request, documentation that verifies completion of the appropriate 

training program(s). 

• Special Study - Training Materials for Handlers

 EPA has determined that registrants must prepare and disseminate training information 

and materials for other fumigant handlers, i.e., those working under the supervision of the 

certified applicator in charge of fumigations. The training materials must address, at minimum, 

the following elements: (1) what fumigants are and how they work, (2) safe application and 

handling of soil fumigants, (3) air monitoring and respiratory protection requirements for 

handlers, (4) early signs and symptoms of exposure, (5) appropriate steps to take to mitigate 

exposures, (6) what to do in case of an emergency, and (7) how to report incidents. Registrants 

must provide this training information through channels open to the public (e.g., via a website). 

Pesticide labels will require that applicators supervising fumigations provide this training 

information to handlers under their supervision before they perform any fumigant handling task, 

or they must ensure that handlers have been provided the required information within the 

preceding 12 months. The label will also require that the training information be provided in a 

manner that the handler can understand. Applicators supervising fumigations must ensure the 
130 

FMP includes how and when the required training information was provided to the handlers 

under their supervision. 

Special Study – Buffer Zone Posting Signs

 EPA has determined that registrants must prepare and disseminate generic buffer zone 

posting signs which meet the following criteria: (1) signs must remain legible during the entire 

posting period, and (2) signs must meet the general standards outlined in the WPS for text size 

and legibility (see 40 CFR §170.120). The requirements for the contents of the sign are as 

follows: 

The treated area sign (currently required for 

fumigants) must state the following: 

-- Skull and crossbones symbol 

 

-- "DANGER/PELIGRO," 

-- "Area under fumigation, DO NOT 

ENTER/NO ENTRE," 

-- "Methyl Bromide fumigant in USE," 

-- the date and time of fumigation, 

-- the date and time entry prohibition is lifted 

-- Name of this product, and 

-- name, address, and telephone number of the 

certified applicator in charge of the fumigation. 

The buffer zone sign must include the 

following: 

-- Do not walk sign 

-- "DO NOT ENTER/NO ENTRE," 

-- “Methyl Bromide OR [Name of product] 

Fumigant BUFFER ZONE,” 

-- contact information for the certified 

applicator in charge of the fumigation 

Registrants must capture all of the information above, excluding the contact information 

for the certified applicator in charge of fumigating. However, registrants must provide 

appropriate space on the sign, and the sign must be made of material appropriate for applicators 

to write in this information on the buffer zone posting signs. Registrants must provide buffer 

zone posting signs at the point of sale for applicators to use. EPA is requiring registrants to 

submit proposals that must address their strategy for development and dissemination of the 

buffer zone posting signs. 

2. Labeling for Manufacturing-Use Products 

In order to be eligible for reregistration, amend all product labels to incorporate the risk 

mitigation measures outlined in Section IV. Also, various use and safety information will be 

required for labeling of all end-use products containing methyl bromide. 
131 

B. End-Use Products 

1. Additional Product-Specific Data Requirements 

 Section 4(g)(2)(B) of FIFRA calls for the Agency to obtain any needed product-specific 

data regarding the pesticide after a determination of eligibility has been made. The Registrant 

must review previous data submissions to ensure that they meet current EPA acceptance criteria 

and if not, commit to conduct new studies. If a registrant believes that previously submitted data 

meet current testing standards, then the study MRID numbers must be cited according to the 

instructions in the Requirement Status and Registrants Response Form provided for each 

product. The Agency intends to issue a separate product-specific data call-in (PDCI), outlining 

specific data requirements. 

2. Labeling for End-Use Products 

In order to be eligible for reregistration, amend all product labels to incorporate the risk 

mitigation measures outlined in Section IV. 
132 

Table 10. Summary of Generic Labeling Changes for Methyl Bromide

Description Amended Labeling Language Placement on 

Label 

Manufacturing Use Products 

For all 

Manufacturing Use 

Products 

 

“Only for formulation into a pre-plant soil fumigant for the following use-sites: Uses, 

users, and locations that qualify for exemptions under the Montreal Protocol (e.g., critical 

use exemption or Quarantine and preshipment exemption uses). All end use products that 

contain directions for use as for crops/use sites that do not qualify for exemptions under the 

Montreal Protocol must be changed to remove those crops/use sites. All structural/space 

uses have been cancelled.” 

“Methyl bromide formulated into end-use products containing 98% methyl bromide must 

contain directions for use only for the following uses: orchard replant, ornamentals (hot 

gas method only), forest seedlings, and quarantine uses. All other use sites and use 

patterns are prohibited and must be removed from the end-use product labeling.” 

“Methyl bromide cannot be formulated into end-use products labeled for pre-plant uses 

without the use of tarps with the exception of California orchard replant for CUE use using 

the deep broadcast application method.” 

“Methyl bromide cannot be formulated into end-use products labeled for pre-plant or pretransplant uses unless the registrant makes available to certified applicators who purchase 

or apply the end-use product a training program approved by EPA that provides 

information on how to correctly apply the fumigant including: how to protect themselves 

and other handlers and bystanders, how to determine buffer zone distances, how to develop 

a Fumigant Management Plan, how to determine when weather and other site-specific 

factors are not favorable for fumigant application, and how to develop an emergency 

response plan. The training program must be made available at least annually to the 

certified applicators. Certified applicators must take the training every 36 months. The 

registrant must be able to provide, upon request, the names, addresses, and certified 

applicator license number of persons who successfully complete the training program.” 

“Methyl bromide cannot be formulated into end-use products labeled for pre-plant or 

pre-transplant uses unless the registrant assures warning signs suitable for posting 

buffer zones are available to end-use product users at the point of sale. 

The buffer zone sign must meet the following standards: 

o Signs must remain legible during entire posting period. 

o The size and type of the buffer zone signs must follow the requirements 

in the Worker Protection Standard for Agricultural Pesticides for treated 

area posting. 

. 

Contents of Sign

-- "DO NOT ENTER/NO ENTRE," 

-- "Methyl Bromide [name of 

product] Fumigant BUFFER 

ZONE,” 

Directions for 

Use 
133 

-- space for contact information for 

the certified applicator in charge of 

the fumigation 

One of these 

statements may be 

added to a label to 

allow reformulation 

of the product for a 

specific use or all 

additional uses 

supported by a 

formulator or user. 

“This product may be used to formulate products for specific use(s) not listed on the MP 

label if the formulator, user group, or grower has complied with U.S. EPA submission 

requirements regarding support of such use(s).” 

“This product may be used to formulate products for any additional use(s) not listed on the 

MP label if the formulator, user group, or grower has complied with U.S. EPA submission 

requirements regarding support of such use(s).” 

Directions for 

Use 

Environmental 

Hazards Statements 

“This pesticide is toxic to mammals, birds, fish, and aquatic invertebrates. Do not 

discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or 

other waters unless in accordance with the requirements of a National Pollutant Discharge 

Elimination System (NPDES) permit and the permitting authority has been notified in 

writing prior to discharge. Do not discharge effluent containing this product to sewer 

systems without previously notifying the local sewage treatment plant authority. For 

guidance, contact your State Water Board or Regional Office of the EPA.” 

Precautionary 

Statements 

End Use Products 

Restricted Use 

Requirement for all 

products that contain 

soil use 

“Restricted Use Pesticide due to acute inhalation toxicity to humans. For retail sale to and 

use by certified applicators or persons under their direct supervision and only for those 

uses covered by the certified applicator’s certification.” 

Top of the 

front panel 

For pre-plant soil 

use. 

Certified applicator 

training program 

“The certified applicator supervising the application must successfully complete a methyl 

bromide training program made available by the registrant within the last 36 months. The 

Fumigant Management Plan (see details elsewhere on this label) must document when and 

where the training program was completed.” 

Directions for 

Use 

For pre-plant soil 

use. 

Fumigation Handlers 

“The following activities are prohibited from being performed in the fumigant application 

block or surrounding buffer zone during the buffer zone period by anyone other than 

persons who have been appropriately trained and equipped as handlers in accordance with 

the requirements in the Worker Protection Standard (40 CFR Part 170), from the start of 

the application until the entry-restricted period ends. Those activities include those 

persons: 

• Participating in the application as supervisors, loaders, drivers, tractor co-pilots, 

shovelers, cross ditchers, or as other direct application participants (the 

application starts when the fumigant is first introduced into the soil and ends after 

the fumigant has stopped being delivered/dispensed to the soil); 

• Using devices to take air samples to monitor fumigant air concentrations; 

• Persons cleaning up fumigant spills (this does not include emergency personnel 

not associated with the fumigation application); 

• Handling or disposing of fumigant containers; 

• Cleaning, handling, adjusting, or repairing the parts of fumigation equipment that 

In the 

Precautionary 

Use Section 
134 

may contain fumigant residues; 

• Installing, repairing, or operating irrigation equipment in the fumigant application 

block or surrounding buffer zone during the buffer zone period; 

• Entering the application site or surrounding buffer zone during the buffer zone 

period to perform scouting, crop advising, or monitoring tasks; 

• Installing, perforating (cutting, punching, slicing, poking), removing, repairing, or 

monitoring tarps: 

o until 14 days after application is complete if tarps are not perforated and 

removed during those 14 days, or 

o until tarp removal is complete if tarps are both perforated and removed 

less than 14 days after application; or 

o until 48 hours after tarps perforation is complete if they will not be 

removed within 14 days after application. 

NOTE: see Tarp Perforation and Removal section on this labeling for 

requirements about when tarps are allowed to be perforated.” 

• In addition, to the above, persons outside the perimeter of the buffer zone who 

monitor fumigant air concentrations must also be trained and equipped as 

handlers in accordance with the requirements in the WPS (40 CFR Part 170). 

For pre-plant soil 

use. 

Supervision of 

Handlers 

“For all applications: from the start of the application until the fumigant has stopped being 

delivered/dispensed into the soil, i.e., after the soil is sealed, the certified applicator must 

be at the fumigation site and must directly supervise all persons performing handling 

activities. 

For fumigant handling activities that take place after the fumigant has been 

delivered/dispensed into the soil until the entry restricted period expires, the certified 

applicator does not have to be on-site, but must have communicated in writing to the site 

owner/operator and handlers the information necessary to comply with the label and 

procedures described in the FMP (e.g., emergency response plans and procedures). 

IMPORTANT: this requirement does not override the requirements in the Worker 

Protection Standard for Agricultural Pesticides for information exchange between 

owners/operators of agricultural establishments and commercial pesticide applicators. 

The certified applicator must provide fumigant safe handling information to each handler 

involved in the application or confirm that each handler participating in the application has 

received fumigant safe handling information in the past 12 months. 

For all fumigant handling tasks at least two handlers trained under the provisions of the 

WPS 40 CFR 170.230 must be present.” 

Directions for 

Use 

Under the 

section 

“protection for 

handlers” 

For pre-plant soil 

use. 

Exclusion of Non 

Handlers from 

Application Block 

and Buffer Zone 

“The certified applicator supervising the application and the owner/operator of the 

establishment where the fumigation is taking place must make sure that all persons who 

are not trained and PPE-equipped and who are not performing one of the handling tasks 

defined in this labeling are: 

• excluded from application block during the entry-restricted period, and 

• excluded from the buffer zone during the buffer zone period.” 

Directions for 

Use 

Under the 

section 

“protection for 

handlers” 

For pre-plant soil use 

Providing, cleaning, 

and maintaining PPE 

“The employer of any fumigant handler (as stated in this label) must make sure that all 

handlers are provided and correctly wear the required PPE. The PPE must be cleaned and 

maintained as required by the Worker Protection Standard for Agricultural Pesticides.” 

Directions for 

Use 

Under the 

section 

“protection for 

handlers” 
135 

Air-rescue device 

availability for preplant soil uses. 

Pic and MeBr only 

“The fumigation handler employer must confirm and document in the FMP that at least 

one air rescue device (e.g., SCBA) is on-site and is ready for use in case of an emergency.” 

Directions for 

Use 

Under the 

section 

“protection for 

handlers” 

Respirator 

availability for preplant soil uses. 

“The fumigation handler employer must confirm and document in the FMP that an airpurifying respirator and appropriate cartridges of the type specified in the PPE section of 

this labeling are immediately available for each handler who will wear one. At a minimum 

two handlers have the appropriate respirator and cartridges available and that these 

handlers are fit-tested, trained, and medically examined.” 

PPE Requirements 

Established by the 

RED for all 

Formulations with 

80% or less methyl 

bromide. 

This will change 

based on chemical 

“Personal Protective Equipment (PPE) 

Some materials that are chemical-resistant to this product are [registrant inserts correct 

material(s)].” For more options, follow the instructions for category [insert A, B, C, D, E, 

F, G or H] on the chemical-resistance category selection chart. 

All fumigant handlers must wear: 

• Long-sleeved shirt and long pants, 

• Chemical-resistant footwear and socks when in the treated field, 

• Shoes and socks for all other handlers 

• Chemical-resistant gloves when handling liquid, 

• Chemical-resistant apron when handling liquid, and 

• Protective eyewear when handling liquid (Do NOT wear goggles) 

In addition, when a respirator is required, fumigant handlers must wear a: 

• NIOSH-approved full-face, or hood-style respirator with a cartridge or canister 

certified by the manufacturer for protection from exposure to methyl bromide at 

concentrations up to 5 ppm (e.g., a 3M air-purifying respirator equipped with 3M 

Model 60928 Organic Vapor/Acid Gas/P100 cartridges), 

IMPORTANT; an air-supplying respirator [i.e., a respirator connected directly to a clean 

air source or a self-contained breathing apparatus (SCBA)] is not permitted for routine 

fumigant handler tasks. Such respirators are only permitted in emergencies such as a spill 

or leak or when corrective action is needed to reduce air levels to acceptable levels.” 

Immediately 

following/belo

w 

Precautionary 

Statements: 

Hazards to 

Humans and 

Domestic 

Animals 

For pre-plant soil 

use. 

Respiratory 

Protection and Stop 

Work Triggers 

“Respiratory Protection and Stop Work Triggers: The following procedures 

must be followed for all formulations with 80 % or less methyl bromide:

• If at any time any handler experiences sensory irritation (tearing, burning of the 

eyes or nose) then either: 

o An air-purifying respirator (APR) must be worn by all handlers who 

remain in the application block and surrounding buffer zone, or 

o Operations must cease and handlers not wearing respiratory protection 

must leave the application block and surrounding buffer zone. 

• Handlers can remove respirators or resume operations if two consecutive 

breathing-zone samples taken at the handling site at least 15 minutes apart show 

that levels of methyl bromide have decreased to less than 1 ppm and levels of 

chloropicrin have decreased to less than 0.15 ppm, provided that handlers do not 

experience sensory irritation. Samples must be taken where the irritation is first 

experienced. 

• When respirators are worn, air monitoring samples must be collected at least 

every 2 hours in the breathing zone of a handler performing a representative 

handling task. 

Directions for 

Use 
136 

• If at any time: (1) a handler experiences any sensory irritation when wearing a 

respirator, or (2) a methyl bromide air sample is greater than 5 ppm or a 

chloropicrin air sample is greater than or equal to 1.5 ppm, then all handler 

activities must cease and handlers must be removed from the application block 

and surrounding buffer zone. If operations cease the emergency plan detailed in 

the FMP must be implemented. 

• Handlers can resume work activities without respiratory protection if two 

consecutive breathing-zone samples taken at the handling site at least 15 minutes 

apart show levels of methyl bromide have decreased to 1 ppm and levels of 

chloropicrin have decreased to less than 0.15 ppm, provided that handlers do not 

experience sensory irritation. 

• During the collection of air samples an air-purifying respirator must be worn by 

the handler taking the air samples. Samples must be taken where the irritation is 

first experienced. 

• Work activities may resume if the following conditions exist provided that the 

appropriate respiratory protection is worn: 

o two consecutive breathing zone samples for methyl bromide taken at the 

handling site at least 15 minutes apart must be less than 5 ppm, 

o two consecutive breathing zone samples for chloropicrin taken at the 

handling site at least 15 minutes apart must be less than 1.5 ppm, 

o handlers do not experience sensory irritation while wearing the APR, 

o cartridges have been changed, and 

o during the collection of air samples an air-purifying respirator must be 

worn by the handler taking the air samples. Samples must be taken 

where the irritation is first experienced. 

The following procedures must be followed for all formulations with more than 

80 % methyl bromide: 

If the fumigant applied contains greater than 80 percent methyl bromide (e.g., 98:2 

formulations), air purifying respirators must be worn during all handler tasks and the 

following air monitoring procedures must be followed to ensure that the upper protection 

limit of the respirator plus respirator cartridge is not exceeded (i.e., 5 ppm for methyl 

bromide and 1.5 ppm for chloropicrin): 

• Air monitoring samples for methyl bromide and chloropicrin must be collected at least 

every hour in the breathing zone of a handler performing a representative handling 

task. 

• If at any time (1) a handler experiences any sensory irritation while wearing a 

respirator, or (2) any air sample is greater than or equal to 5 ppm for methyl bromide, 

or (3) any air sample is greater than or equal to 1.5 ppm for chloropicrin, then all 

handler activities must cease and handlers must be removed from the application block 

and surrounding buffer zone. 

• In order to resume work activities: 

° Two consecutive air samples for methyl bromide and chloropicrin taken in the 

treatment area at least 15 minutes apart must be less than 5 ppm for methyl 

bromide and less than 1.5 ppm for chloropicrin. 

° During the collection of samples an air purifying respirator must be worn by the 

handler taking air samples. 

 Hot gas tarped applications 

Once the fumigation has started, if entry into the greenhouse enclosure or the 

outdoor treatment area is required to perform a function necessary for the application, a 

SCBA must be worn. Handlers must wear SCBA to reenter the greenhouse/treated areas 
137 

for a minimum of 48 hrs after the fumigant has stopped being delivered/dispensed to the 

soil. 

 Deep probe injection 

EPA is requiring that SCBA be worn when applying methyl bromide with 

handheld equipment. 

PPE Requirements 

Established by the 

RED1

For Formulations 

with > 80% methyl 

bromide (i.e., 98:2) 

(This is different 

from the 

formulations with 

80% or less methyl 

bromide because 

handlers must wear 

air-purifying 

respirators when 

performing handling 

tasks and the 

monitoring 

requirements are 

different.) 

“All handlers must wear: 

• Long-sleeved shirt and long pants, 

• Chemical-resistant footwear and socks when in the treated field, 

• Shoes and socks for all other handlers 

• Chemical-resistant gloves when handling liquid, 

• Chemical-resistant apron when handling liquid, and 

• Protective eyewear when handling liquid (Do NOT wear goggles) 

• NIOSH-approved half-face, full-face, or hood-style respirator with a cartridge or 

canister certified by the manufacturer for protection from exposure to methyl bromide 

at concentrations up to 5 ppm (e.g., a 3M air-purifying respirator equipped with 3M 

Model 60928 Organic Vapor/Acid Gas/P100 cartridges), and 

IMPORTANT: an air-supplying respirator (i.e., a respirator connected directly to a clean 

air source or a self-contained breathing apparatus (SCBA) is not permitted for routine 

fumigant handler tasks. Such respirators are only permitted in emergencies such as a spill 

or leak or when corrective action is needed to reduce air levels to acceptable levels. 

Immediately 

following/ 

below 

Precautionary 

Statements: 

Hazards to 

Humans and 

Domestic 

Animals 

Fumigant Air 

Monitoring for all 

Formulations with > 

80% methyl bromide 

(i.e., 98:2) 

“Fumigant Air Monitoring Requirements: The following air monitoring procedures 

must be followed to ensure that the upper protection limit of the respirator plus respirator 

cartridge or canister is not exceeded (i.e., 5 ppm for methyl bromide and 1.5 ppm for 

chloropicrin) 

• Air monitoring samples for methyl bromide and chloropicrin must be collected at least 

every hour in the breathing zone of a handler performing a representative handling 

task. 

• To monitor air concentration levels, a direct reading detection device, such as a 

Matheson-Kitagawa, Draeger, or Sensidyne device must be used. The devices must 

have sensitivity of at least 5 ppm for methyl bromide and 1.5 ppm for chloropicrin 

• If at any time (1) a handler experiences any sensory irritation while wearing a 

respirator, or (2) any air sample is greater than or equal to 5 ppm for methyl bromide, 

or (3) any air sample is greater than or equal to 1.5 ppm for chloropicrin, then all 

handler activities must cease and handlers must be removed from the application block 

and surrounding buffer zone until corrective action has been taken. 

• During the corrective actions if methyl bromide air concentrations are greater than or 

equal to 5 ppm or if chloropicrin air concentrations are greater than or equal to 1.5 

ppm, then a self-contained breathing apparatus (SCBA) must be worn. 

• In order to resume work activities: 

3⁄4 Two consecutive air samples for methyl bromide and chloropicrin taken in the 

treatment area at least 30 minutes apart, must be less than 5 ppm for methyl 

bromide and less than 1.5 ppm for chloropicrin. 

3⁄4 During the collection of samples an air purifying respirator must be worn by the 

handler taking air samples. 

Immediately 

following/belo

w 

Precautionary 

Statements: 

Hazards to 

Humans and 

Domestic 

Animals 

User Safety 

Requirements 

“Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions 

for washables exist, use detergent and hot water. Keep and wash PPE separately from 

Precautionary 

Statements: 
138 

 other laundry.” 

“Discard clothing and other absorbent materials that have been drenched or heavily 

contaminated with this product’s concentrate. Do not reuse them.” 

Hazards to 

Humans and 

Domestic 

Animals 

immediately 

following the 

PPE 

requirements 

PPE Requirements 

Established by the 

RED

For pre-plant soil 

uses. 

“Respirator fit testing, medical qualification, and training 

Employers must ensure that any handler that uses a respirator is: 

• Fit-tested and fit-checked using a program that conforms to OSHA’s requirements 

(see 29 CFR Part 1910.134) 

• Trained using a program that confirms to OSHA’s requirements (see 29 CFR Part 

1910.134) 

• Examined by a qualified medical practitioner to ensure physical ability to safely 

wear the style of respirator to be worn. A qualified medical practitioner is a physician or 

other licensed health care professional who will evaluate the ability of a worker to wear a 

respirator. The initial evaluation consists of a questionnaire that asks about medical 

conditions (such as a heart condition) that would be problematic for respirator use. If 

concerns are identified, then additional evaluations, such as a physical exam, might be 

necessary. The initial evaluation must be done before respirator use begins. Handlers 

must be reexamined by a qualified medical practitioner at least annually or if their health 

status or respirator style or use-conditions change.” 

Directions for 

Use Under the 

section 

“Protection for 

Handlers” 

For pre-plant soil 

use. 

Application 

Requirements, when 

tarps are used: Tarp 

Perforation and/or 

Removal 

“Tarp Perforation and/or Removal 

IMPORTANT: Persons perforating, repairing, removing, and/or monitoring tarps are 

defined, within certain time limitations, as fumigant handlers (see fumigant handlers as 

stated in this labeling) and must be provided the PPE and other protections for handlers as 

required on this labeling and in the Worker Protection Standard for Agricultural Pesticides. 

• Tarps must not be perforated until a minimum of 5 days (120 hours) have elapsed 

after the fumigant injection into the soil is complete (e.g., after injection of the 

fumigant product and tarps have been laid or after drip lines have been purged and 

tarps have been laid), unless a weather condition exists which necessitates the 

need for early perforation or removal See Early Tarp Removal for Broadcast 

Applications Only and Early Tarp Perforation for Flood Prevention sections. 

• If tarps will be removed before planting, tarp removal must not begin until at least 

2 hours after tarp perforation is complete and 2 air monitoring samples are less 

than 1 ppm methyl bromide. (If 2 air monitoring samples have methyl bromide 

levels between 1 ppm and 5 ppm, then respirator protection is required before tarp 

removal can begin.) 

• If tarps will not be removed before planting, planting or transplanting must not 

begin until at least 48 hours after the tarp perforation is complete. 

• If tarps are left intact for a minimum of 14 days after fumigant injection into the 

soil is complete, planting or transplanting may take place while the tarps are being 

perforated. 

• Each tarp panel used for broadcast fumigation must be perforated. 

• Tarps used for fumigations may be perforated manually ONLY for the following 

situations: 

o At the beginning of each row when a coulter blade (or other device 

which performs similarly) is used on a motorized vehicle such as an 

ATV. 

o In fields that are 1 acre or less. 

Directions For 

Use 
139 

o During flood prevention activities. 

• In all other instances tarps must be perforated (cut, punched, poked, or sliced) 

only by mechanical methods. 

• Tarp perforation for broadcast fumigations must be completed before noon. 

• For broadcast fumigations tarps must not be perforated if rainfall is expected 

within 12 hours. 

• Early Tarp Removal for Broadcast Applications Only: 

o Tarps may be removed before the required 5 days (120 hours) if adverse 

weather conditions have compromised the integrity of the tarp, provided 

that the compromised tarp poses a safety hazard. Adverse weather

includes high wind, hail, or storms that blow tarps off the field and create 

a hazard, e.g., tarps blowing into power lines and onto roads. A 

compromised tarp is a tarp that due to an adverse weather condition is no 

longer performing its intended function and is creating a hazard. 

o If tarps are removed before the required 5 days have elapsed due to 

adverse weather, the events must be documented in the post fumigation 

summary section of the FMP. 

• Early Tarp Perforation for Flood Prevention Activities 

o Tarp perforation is allowed before the 5 days (120 hours) have elapsed if 

rain necessitates field drainage. 

o Tarps must be immediately retucked and packed after soil removal. 

o Subsequent tarp perforations must not occur until the original 5 days 

have elapsed. 

o The events must be documented in the post fumigation summary section 

of the FMP.” 

Monitoring Air 

Concentration Levels 

“MONITORING AIR CONCENTRATION LEVELS

Monitoring Air Concentrations in the Buffer Zone Areas: When air concentration 

levels must be monitored (i.e., as specified in the general buffer zone requirements 

section), use a direct reading detection device, such as a Matheson-Kitagawa, Draeger, or 

Sensidyne device. The devices must have sensitivity of at least 1 ppm for methyl bromide 

and 0.15 ppm for chloropicrin.” 

Directions for 

Use under the 

heading 

“General 

Buffer Zone 

Requirements

”

Agriculture Use 

Requirements box 

Agricultural Use Requirements 

After the standard paragraphs for the Agricultural Use Requirements box, substitute the 

following text for the standard restricted-entry interval and double notification 

requirements: 

 

“For the entry restricted period and notification requirements, see the Application Block 

Entry Restricted Period and Notification section of this labeling.” 

Agricultural 

Use 

Requirements 

box 

For pre-plant soil 

use. 

Entry Restricted 

Period 

“Entry Restricted Period 

Entry (including early entry that would otherwise be permitted under the WPS) by any 

person – other than a correctly trained and PPE-equipped handler who is performing a 

handling task listed on this labeling – is PROHIBITED - from the start of the application 

until: 

• 5 days (120 hours) after the application is complete for untarped applications, or

• 5 days (120 hours) after application is complete if tarps are not perforated and 

removed for at least 14 days following application, or 

• 48 hours after tarp perforation is complete if they will not be removed for at least 

14 days following application, or 

• until tarp removal is completed if tarps are both perforated and removed less than 

Directions for 

Use under the 

heading 

“Entry 

Restricted 

Period and 

Notification” 
140 

14 days after application. 

NOTE: see Tarp Perforation and Removal section on this labeling for requirements about 

when tarps are allowed to be perforated.” 

For pre-plant soil 

use. 

Notification 

Requirement for the 

treated area 

“NOTIFICATION: Notify workers of the application by warning them orally and by 

posting fumigant warning signs. The signs must bear the skull and crossbones symbol and 

state: 

-- “DANGER/PELIGRO,” 

-- “Area under fumigation, DO NOT ENTER/NO ENTRE,” 

-- “Methyl Bromide Fumigant in USE,”

-- the date and time of fumigation, 

-- the date and time entry prohibition period is over, 

-- Name of this product, and 

-- Name, address, and telephone number of the certified applicator in charge of the 

fumigation. 

Post the fumigant warning sign instead of the WPS sign for this application but follow all 

WPS requirements pertaining to location, legibility, size, and timing of posting and 

removal. 

Post the fumigant warning signs at all entrances to the application block (i.e., the 

greenhouse or field or portion of a field treated with a fumigant in any 24-hour period)” 

Direction for 

Use under the 

heading 

“Entry 

Restricted 

Period and 

Notification” 

For pre-plant soil 

use. 

Mandatory Good 

Agricultural 

Practices for all 

formulations 

“Mandatory Good Agricultural Practices (GAPs) 

The following GAPs must be followed during all fumigant applications. All measurements 

and other documentation planned to ensure that the mandatory GAPs are achieved must be 

recorded in the FMP and/or the post-application summary report. 

Tarps (required for all applications except for deep shank orchard replant [California only] 

and hand held tree-hole applications) 

• Tarps must be installed prior to starting hot gas applications. 

• Tarps must be installed immediately after the fumigant is applied to the soil for 

bedded or broadcast applications. 

• A written plan for tarpping must be developed and included in the FMP that address 

the following: 

o schedule and procedures for checking tarps for damage, tears, and other problems 

o plans for determining when and how repairs to tarps will be made, and by whom 

o minimum time following injection that tarp will be repaired 

o minimum size of tarp damage that will be repaired 

o other factors used to determine how and when tarp repair will be conducted 

o schedule, equipment, and methods used to perforate tarps 

o aeration plans and procedures following perforation of tarp, but prior to tarp 

removal or planting/transplanting 

o schedule, equipment, and procedures for tarp removal. 

Weather Conditions 

• Prior to fumigation the weather forecast for the day of the application and the 48-hour 

period following the fumigation must be checked to determine if unfavorable weather 

conditions exist (see Identifying Unfavorable Weather Conditions section) or are 

predicted and whether fumigation should proceed. 

• Wind speed at the application site must be a minimum of 2 mph at the start of the 

application or forecasted to reach at least 5 mph during the application. 

Directions for 

Use under 

“Mandatory 

Good 

Agricultural 

Practices” 
141 

• Do not apply if a shallow, compressed (low-level) temperature inversion is forecast to 

persist for more than 18 consecutive hours for the 48-hour period after the start of 

application, or if there is an air-stagnation advisory in effect for the area in which the 

fumigation is planned. 

• Detailed local forecasts for weather conditions, wind speed, and air stagnation 

advisories may be obtained on-line at: http://www.nws.noaa.gov. For further 

guidance, contact your local National Weather Service Forecasting Office. 

Identifying Unfavorable Weather Conditions 

• Unfavorable weather conditions block upward movement of air which results in 

trapping fumigant vapors near the ground. The resulting air mass can move off-site 

in unpredictable directions and cause injury to humans, animals or property. These 

conditions typically exist prior to sunset and continue past sunrise and persist as late 

as noontime. Unfavorable conditions are common on nights with limited cloud cover 

and light to no wind and their presence can be indicated by ground fog or smog and 

can also be identified by smoke from a ground source that flattens out below a ceiling 

layer and moves laterally in a concentrated cloud. 

Soil Temperature 

• The maximum soil temperature at the depth of injection shall not exceed 90 degrees F 

at the beginning of the application. 

o If air temperatures have been above 100 degrees F in any of the three days prior to 

application, then soil temperature shall be measured and recorded in the FMP. 

Soil Moisture 

• The soil must be moist 9 inches below the surface. The amount of moisture needed in 

this zone will vary according to soil type and shall be determined using USDA Feel 

and Appearance Method for testing (see below). Surface soil generally dries rapidly 

and must not be considered in this determination. 

• If there is insufficient moisture 9 inches below the surface, the soil moisture must be 

adjusted. If irrigation is not available and there is adequate soil moisture below 9 

inches, soil moisture can be adjusted by discing or plowing before fumigant injection. 

To conserve existing soil moisture, pretreatment irrigation or pretreatment tillage 

should be done as close to the time of application as possible. 

• Measure soil moisture at a depth of 9 inches at either end of the field, no more than 48 

hours prior to application. 

Soil moisture determination 

The soil shall contain at the time of application enough moisture at the point of 

injection below the surface to meet the following criteria defined in the USDA Feel and 

Appearance method for estimating soil moisture as appropriate for the soil texture. 

• For coarse textured soils (fine sand and loamy fine sand), the soil is moist enough (50 

to 75 percent available soil water moisture) to form a weak ball with loose and 

clustered sand grains on fingers, darkened color, moderate water staining on fingers, 

will not ribbon. 

• For moderately coarse textured soils (sandy loam and fine sandy loam), the soil is 

moist enough (50 to 75 percent available soil water moisture) to form a ball with 

defined finger marks, very light soil/water staining on fingers, darkened color will not 

stick. 

• For medium textured soils (sandy clay loam, loam, and silt loam), the soil is moist 

enough (50 to 75 percent available soil water moisture) to form a ball, very light 
142 

staining on fingers, darkened color, pliable, and forms a weak ribbon between the 

thumb and forefinger. 

• For fine textured soils (clay, clay loam, and silty clay loam), the soil is moist enough 

(50 to 75 percent available soil water moisture) to form a smooth ball with defined 

finger marks, light soil/water staining on fingers, ribbons between thumb and 

forefinger. 

• For fields with more than one soil texture, soil moisture content in the lightest 

textured (most sandy) areas must comply with this soil moisture requirement. 

Whenever possible, the field should be divided into areas of similar soil texture and 

the soil moisture of each area should be adjusted as needed. Coarser textured soils can 

be fumigated under conditions of higher soil moisture than finer textured soils; 

however, if the soil moisture is too high, fumigant movement will be retarded and 

effectiveness of the treatment will be reduced. Previous and/or local experience with 

the soil to be treated or the crop to be planted can often serve as a guide to conditions 

that will be acceptable. If there is uncertainty in determining the soil moisture content 

of the area to be treated, local extension service or soil conservation service specialist 

or pest control advisor (agriculture consultant) should be consulted for assistance. 

Soil Preparation 

• Soil shall be properly prepared and at the surface generally be free of clods that are 

golf ball size or larger. The area to be fumigated shall be tilled to a depth of 5 to 8 

inches. 

• Field trash must be properly managed. Residue from a previous crop must be worked 

into the soil to allow for decomposition prior to fumigation. Little or no crop residue 

shall be present on the soil surface. Crop residue that is present must not interfere with 

the soil seal. Removing the crop residue prior to fumigation is important to limit the 

natural “chimneys” that will occur in the soil when crop residue is present. These 

“chimneys” allow the soil fumigants to move through the soil quickly and escape into 

the atmosphere. This may create potentially harmful conditions for workers and 

bystanders and will limit the efficacy of the fumigant. However, crop residue on the 

field serves to prevent soil erosion from both wind and water and is an important 

consideration. To accommodate erosion control, fumigant efficacy, and human health 

protection, clear fields of crop residue as close to the timing of the fumigation as 

possible to limit the length of time that the soil would be exposed to potentially 

erosive weather conditions. 

Soil Sealing

• For Broadcast Untarped Applications: Use a disc or similar equipment to uniformly 

mix the soil to at least a depth of 3 to 4 inches to eliminate the chisel or plow traces. 

Following elimination of the chisel trace, the soil surface must be compacted with a 

cultipacker, ring roller, and roller in combination with tillage equipment. 

• For Bedded Applications: Performed beds shall be sealed by disruption the chisel 

trace using press sealers, bed shapers, cultipackers, or by re-shaping (relisting, lifting 

and replacing, etc.) the beds immediately following injection. Beds formed at the time 

of application shall be sealed by disrupting the chisel trace using press sealers, or bed 

shapers. 

• Soil Sealing for Tarped Applications: The use of a tarp does not eliminate the need to 

minimize chisel traces prior to application of the tarp, such as by using a nobel plow or 

other injection shank that disrupts the chisel traces. 

Bedded and Broadcast Shank Applications: Additional Mandatory GAPs

In addition to the GAPs required for all soil fumigation applications, the following GAPs 

apply for injection applications: 
143 

Tarps 

• Tarps must be installed immediately after the fumigant is applied to the soil. 

Soil Preparation 

• Trash pulled by the shanks to the ends of the field must be covered with tarp, or soil, 

depending on the application method before making the turn for the next pass. 

Application Depth 

• For Tarped-Broadcast and Tarped-Bedded Applications: The injection point shall be 

a minimum of 8 inches from the nearest final soil/air interface. For tarped bedded 

applications the injection depth must not be deeper than the lowest point of the tarp 

(i.e., the lowest point of the tuck). 

• For Untarped-Bedded Applications: The injection point shall be a minimum of 12 

inches from the nearest final soil/air interface. 

• For Untarped-Broadcast Applications (CA orchard replant only): The injection point 

shall be a minimum of 18 inches from the nearest final soil/air interface. 

Prevention of End Row Spillage 

• Do not apply or allow fumigant to drain onto the soil surface. For each injection line 

either have a check valve located as close as possible to the final injection point, or 

drain/purge the line of any remaining fumigant prior to lifting injection shanks from 

the ground. 

• Do not lift injection shanks from the soil until the shut-off valve has been closed and 

the fumigant has been depressurized (passively drained) or purged (actively forced out 

via air compressor) from the system. 

Calibration, Set-up, Repair, and Maintenance for Application Rigs 

• Brass, carbon steel or stainless steel fittings must be used throughout. 

Polyethylene tubing, polypropylene tubing, Teflon® tubing or Teflon® -lined 

steel braided tubing must be used for all low pressure lines, drain lines, and 

compressed gas or air pressure lines. All other tubing must be Teflon® -lined 

steel braided. 

• Galvanized, PVC, nylon or aluminum pipe fittings must not be used. 

• All rigs must include a filter to remove any particulates from the fumigant, and a 

check valve to prevent backflow of the fumigant into the pressurizing cylinder or 

the compressed air system. 

• Rigs must include a flowmeter or a constant pressure system with orifice plates to 

insure the proper amount of fumigant is applied. 

• To prevent the backflow of fumigant into the compressed gas cylinder (e.g. 

nitrogen, other inert gas or compressed air), if used, applicators must: 

o If a compressed gas cylinder is used, make sure that positive pressure is 

maintained in the cylinder at not less than 200 psi during the entire time 

it is connected to the application rig. (This is not required for a 

compressed air system that is part of the application rig because if the 

compressor system fails the application rig will not be operable) 

o Ensure that application rigs are equipped with properly functioning 

check valves between the compressed gas cylinder or compressed air 

system and the fumigant cylinder. The check valve is best placed on the 

outlet side of the pressure regulator, and is oriented to only allow 

compressed gas to flow out of the cylinder or compressed air out of the 

compressed air system. 

o Always pressurize the system with compressed gas or by use of a 

compressed air system before opening the fumigant cylinder valve. 

• Before using a fumigation rig for the first time, or when preparing it for use after 

storage, the operator must check the following items carefully: 
144 

o Check the filter, and clean or replace the filter element as required. 

o Check all tubes and chisels to make sure they are free of debris and 

obstructions. 

o Check and clean the orifice plates and screen checks, if installed. 

o Pressurize the system with compressed gas or compressed air, and check 

all fittings, valves, and connections for leaks using soap solution. 

• Install the fumigant cylinder, and connect and secure all tubing. Slowly open the 

compressed gas or compressed air valve, and increase the pressure to the desired 

level. Slowly open the fumigant cylinder valve, always watching for leaks. 

• When the application is complete, close the fumigant cylinder valve and blow 

residual fumigant out of the fumigant lines into the soil using compressed gas or 

compressed air. At the end of the application, disconnect all fumigant cylinders 

from the application rig. At the end of the season, seal all tubing openings with 

tape to prevent the entry of insects and dirt. 

• Application equipment must be calibrated and all control systems must be 

working properly. Proper calibration is essential for application equipment to 

deliver the correct amount of fumigant uniformly to the soil. Refer to the 

manufacturer's instructions on how to calibrate your equipment, usually the 

equipment manufacturer, fumigant dealer, or Cooperative Extension Service can 

provide assistance. 

Hot Gas Soil Applications (Greenhouse and Outdoor): Mandatory GAPs 

• All delivery tubes shall be placed under the tarp in such a way that they do not move 

during the application of methyl bromide. 

• The fumigant must be introduced from outside of the greenhouse/application block 

(see entry restrictions and respiratory protection sections for further details). 

• All fittings, connections, and valves must be checked for methyl bromide leaks prior to 

fumigation. If cylinders are replaced during the fumigation process, the connections 

and valves must be checked for leaks prior to continuing the job. 

Tree Replant Application: Mandatory GAPs 

In addition to the GAPs required for all soil fumigation applications, the following GAPs 

apply for tree replant applications. This application method is used when methyl bromide 

is applied to individual tree sites in an existing orchard where shank application are not 

possible: 

Site Preparation 

• Each individual tree-site must remove the tree stump and primary root system 

with a back-hoe or other similar equipment, for example an auger. 

• The hole must be backfilled with soil before application. 

Application Depth 

• The fumigant must be injected at least 18 inches into the soil. 

System Flush

• Before removing the application wand from the soil the wand must be cleared 

using nitrogen or compressed air. 

Soil Sealing 

• After the wand is cleared and removed from the soil, the injection hole must be 

either covered with soil and tamp or the soil must be compacted over the injection 

hole. 
145 

For pre-plant soil 

use. 

Site-Specific 

Fumigation 

Management Plans 

“Site-Specific Fumigation Management Plan (FMP) 

Prior to the start of fumigation, the certified applicator supervising the application must 

verify that a site-specific fumigation management plan (FMP) exists for each application 

block (i.e., a greenhouse or field or portion of a field treated with a fumigant in any 24-

hour period). In addition, a farm operation fumigating multiple application blocks may 

format the FMP in a manner whereby all of the information that is common to all the 

application blocks is captured once, and any information unique to a particular application 

block or blocks is captured in subsequent sections. The FMP may be prepared by the 

certified applicator, the site owner/operator, registrant, or other party. The certified 

applicator must verify in writing the site-specific FMPs reflects current site conditions 

before the start of fumigation. 

Each site specific FMP must contain the following elements: 

 Applicator information (name, phone number, license number, employer name, 

employer address, date of completing registrant methyl bromide training program) 

 General site information 

3⁄4 Application block location (e.g., address or global positioning system (GPS) 

coordinates) 

3⁄4 Name, address, and, phone number of owner/operator of the application block 

3⁄4 Map, aerial photo, or detailed sketch showing field location, dimensions, buffer 

zones, property lines, roads, rights-of-ways, sidewalks, permanent walking paths, 

bus stops, water bodies, wells, nearby application blocks, surrounding structures 

(occupied and non-occupied), locations of posted signs for buffers, and sites 

requiring 1⁄4 or 1⁄8 mile buffer zones (e.g., schools, state licensed day care centers, 

nursing homes, assisted living facilities, hospitals, in-patient clinics, and prisons) 

with distances from the application site labeled 

 General application information (target application date/window, brand name of 

fumigant, EPA registration number) 

 Tarp information and procedures for repair, perforation and removal(if tarp is used) 

3⁄4 Brand name, lot number, thickness 

3⁄4 Name and phone number of person responsible for repairing tarps 

3⁄4 Schedule for checking tarps for damage, tears, and other problems 

3⁄4 Maximum time following notification of damage that the person(s) responsible for 

tarp repair will respond 

3⁄4 Minimum time following application that tarp will be repaired 

3⁄4 Minimum size of damage that will be repaired 

3⁄4 Other factors used to determine when tarp repair will be conducted 

3⁄4 Name and phone number of person responsible for cutting and/or removing tarps 

(if other that certified applicator) 

3⁄4 Equipment/methods used to cut tarps 

3⁄4 Schedule and target dates for cutting tarps 

3⁄4 Schedule and target dates for removing tarps 

 Soil conditions (description of soil texture in application block, method used to 

determine soil moisture) 

 Weather conditions (summary of forecasted conditions for the day of the application 

and the 48-hour period following the fumigant application) 

3⁄4 Wind speed 

3⁄4 Inversion conditions (e.g., shallow, compressed (low-level) temperature inversion) 

3⁄4 Air stagnation advisory 

 Buffer zones 

3⁄4 Application method 

3⁄4 Application rate from lookup table on the label (lb ai/A) 

3⁄4 Application block size from lookup table on the label (acres) 

3⁄4 Credits applied 

3⁄4 Buffer zone distance 

3⁄4 Description of areas in the buffer zone that are not under the control of the 

In the 

Directions for 

Use for Preplant soil 

fumigation 

under the 

heading, “SiteSpecific 

Fumigation 

Management 

Plan (FMP)” 
146 

owner/operator of the application block 

 Respirators and other personal protective equipment (PPE) for handlers (handler task, 

protective clothing, respirator type, respirator cartridge type, respirator cartridge 

replacement schedule, eye protection, gloves, other PPE) 

 Emergency procedures (evacuation routes, locations of telephones, contact 

information for first responders, local/state/federal contacts, key personnel and 

emergency procedures/responsibilities in case of an incident, equipment/tarp/seal 

failure, complaints or elevated air concentration levels outside buffer zone suggesting 

potential problems, or other emergencies). 

 Posting procedures (person(s) who will post signs, location of posting signs, 

procedures for sign removal) 

 Site-specific response and management (if applicable) 

3⁄4 Fumigant site monitoring 

 Description of who, when, where, and procedures for monitoring buffer zone 

perimeter 

3⁄4 Response information for neighbors 

 List of residences, businesses, and neighboring property owners informed 

 Name and phone number of person doing notification 

 Method of providing the information 

 State and tribal lead agency notification (If state and/or tribal lead agency requires 

notice, provide a list of contacts that were notified and date notified.) 

 Plan describing how communication will take place between applicator, land 

owner/operator, and other on-site handlers (e.g., tarp cutters/removers, irrigators) for 

complying with label requirements (e.g., buffer zone location, buffer zone start/stop 

times, timing of tarp cutting and removal, PPE). 

3⁄4 Name and phone number of persons contacted 

3⁄4 Date contacted 

 Authorized on-site personnel 

3⁄4 Names, addresses and phone numbers of all handlers 

3⁄4 Employer name, addresses, and phone numbers for all handlers 

3⁄4 Tasks that each handler is authorized and trained to perform 

3⁄4 Date of PPE training for each handler 

3⁄4 For handlers designated to wear respirators respiratory protection is required 

(minimum of 2 handlers), date of medical qualification to wear a respirator and 

date of fit testing for respirator. 

 Air monitoring plan 

3⁄4 For buffer zone monitoring: 

 Name, address, and, phone number of handler to perform monitoring 

activities 

 Location and timing of monitoring for the buffer zone 

3⁄4 For handlers without respiratory protection: 

 If sensory irritation is experienced, indicate whether operations will be ceased 

or operations will continue with respiratory protection 

 If intend to cease operations when sensory irritation is experienced, provide 

the name, address, and phone number of the handler that will perform 

monitoring activities prior to operations resuming 

3⁄4 For handlers with respiratory protection: 

 Representative handler tasks to be monitored 

 Monitoring equipment to be used and timing of monitoring 

3⁄4 For buffer zone monitoring when using methyl bromide formulations with 

< 20% chloropicrin: 

 Name, address, and phone number of person(s) to perform sampling 

 Identify areas or structures to be monitored before reentry is permitted 

 Monitoring equipment to be used and timing of the monitoring 

3⁄4 For monitoring the breathing zone when using methyl bromide formulations 

with < 20% chloropicrin: 
147 

 Representative handler tasks to be monitored 

 Monitoring equipment to be used and timing of the monitoring 

 Good Agricultural Practices (GAPs) 

3⁄4 Description of applicable mandatory GAPs (registrants may also include optional 

GAPs) 

3⁄4 Measurements and documentation to ensure GAPs are achieved (e.g., 

measurement of soil and other site conditions) 

 Description of hazard communication. (The buffer zone around the application block 

has been posted in accordance with the label. Pesticide product labels and material 

safety data sheets are on-site and readily available for employees to review.) 

 Record-keeping procedures (the owner/operator of the application block, as well as the 

certified applicator, must keep a signed copy of the site-specific FMP and the post 

application summary for 2 years from the date of application). 

For situations where an initial FMP is developed and certain elements do not change for 

multiple fumigation sites (e.g., applicator information, authorized on-site personnel, record 

keeping procedures, emergency procedures) only elements that have changed need to be 

updated in the site-specific FMP provided the following: 

• The certified applicator supervising the application has verified that those 

elements are current and applicable to the application block before it is fumigated 

and has documented the verification in the site-specific FMP. 

• Recordkeeping requirements are followed for the entire FMP (including elements 

that do not change). 

Once the application begins, the certified applicator must make a copy of the FMP 

available for viewing by handlers involved in the fumigation. The certified applicator or 

the owner/operator of the application block must provide a copy of the FMP to any federal, 

state, tribal, or local enforcement personnel who request the FMP. In the case of an 

emergency, the FMP must be made available when requested by federal/state/local 

emergency response and enforcement personnel. 

Within 30 days of completing the application portion of the fumigation process, the 

certified applicator supervising the application must complete a post fumigation 

application summary that describes any deviations from the FMP that have occurred, 

measurements taken to comply with GAPs as well as any complaints and/or incidents that 

have been reported to him/her. 

Specifically the Post-Application Summary must contain the following elements: 

 Actual date of the application, application rate, and size of application block 

fumigated 

 Summary of weather conditions on the day of the application and during the 48-hour 

period following the fumigant application 

 Soil temperature measurement (if air temperatures were above 100 degrees F in any of 

the 3 days prior to the application) 

 Tarp damage and repair information (if applicable) 

3⁄4 Location and size of tarp damage 

3⁄4 Description of tarp/tarp seal/tarp equipment failure 

3⁄4 Date and time of tarp repair 

 Tarp perforation/removal details (if applicable) 

3⁄4 Description of tarp removal (if different than in the FMP) 

3⁄4 Date tarps were perforated 

3⁄4 Date tarps were removed 

 Complaint details (if applicable) 
148 

3⁄4 Person filing a complaint (e.g., on-site handler, person off-site) 

3⁄4 If off-site person, name, address, and phone number of person filing a complaint 

3⁄4 Description of control measures or emergency procedures followed after a 

complaint 

 Description of incidents, equipment failure, or other emergency and emergency 

procedures followed (if applicable) 

 Details of elevated air concentrations monitored on-site or outside the buffer zone (if 

applicable) 

3⁄4 Location of elevated air concentration levels 

3⁄4 Description of control measures or emergency procedures followed 

3⁄4 Air monitoring results 

 When sensory irritation experienced: 

• Date and time of sensory irritation 

• Handler task/activity 

• Handler location where irritation was observed 

• Resulting action (e.g., cease operations, continue operations with 

respiratory protection) 

 When using a direct read instrument: 

• Type of sample (e.g., area, breathing zone, structure) 

• Sample date and time 

• Handler task/activity (if applicable) 

• Handler location or structure location 

• Air concentration 

• Sampling method 

 Date of buffer zone sign removal 

 Any deviations from the FMP 

In addition to recordkeeping requirements from 7 CFR part 110 “Recordkeeping 

Requirements for Certified Applicators of Federally Restricted Use Pesticides,” this 

decision requires that both the applicator and owner/operator of the application block keep 

a signed copy of the site-specific FMPs and the post-application summary record for 2 

years from the date of application. 

For pre-plant soil 

use. 

General Buffer 

Zones requirements 

for all formulations 

“General Buffer Zone Requirements 

A “buffer zone” must be established for every fumigant application The following 

describes the general buffer zone requirements: 

• “Buffer zone” is an area established around the perimeter of each application block or 

greenhouse where a soil fumigant is applied. The buffer zone must extend from the 

edge of the application block perimeter equally in all directions. 

• All non-handlers including field workers, nearby residents, pedestrians, and other 

bystanders, must be excluded from the buffer zone during the buffer zone period 

except for certain persons in transit (see exemptions section). 

• An “application block” is a greenhouse or field or portion of a field treated with a 

fumigant in any 24-hour period (see Figures 1 and 2 above for further explanation). 

• The “buffer zone period” starts at the moment when any fumigant is 

delivered/dispensed to the soil within the application block and lasts for a minimum of 

48 hours after the fumigant has stopped being delivered/dispensed to the soil. 

Authorized entry to buffer zones

• Only authorized handlers who have been properly trained and equipped according to 

EPA’s Worker Protection Standard (WPS) and label requirements may be in the buffer 

zone during the buffer zone period. 

In the 

Directions for 

Use for Preplant soil 

fumigation 

under the 

heading 

“General 

Buffer Zone 

Requirements” 
149 

Buffer zone proximity

• Before the application begins, the certified applicator must determine whether the 

application block or its resulting buffer will overlap with a buffer that is already in 

effect. 

• A buffer zone may NOT overlap buffer zones from other application blocks which 

are already in effect UNLESS a minimum of 12 hours have elapsed from the time the 

first application ends until the second application begins. 

• Emergency preparedness and response measures have been implemented if there are 

homes, businesses, or property not within the control of the fumigator within 300 feet 

of each buffer zone. 

Exemptions for transit through buffer zones 

• Vehicular and bicycle traffic on public and private roadways through the buffer zone 

is permitted. "Roadway" means that portion of a street or highway improved, designed 

or ordinarily used for vehicular travel, exclusive of the sidewalk or shoulder even 

though such sidewalk or shoulder is used by persons riding bicycles. In the event a 

highway includes two or more separated roadways, the term "roadway" shall refer to 

any such roadway separately. 

• Bus stops or other locations where persons wait for public transit are not permitted 

within the buffer zone. 

• See posting section for additional requirements that may apply. 

Structures under the control of owner/operator of the application block 

• Buffer zones may not include buildings used for storage such as sheds, barns, garages, 

etc., UNLESS, 

1. The storage buildings are not occupied during the buffer zone period, and 

2. The storage buildings do not share a common wall with an occupied structure. 

• See posting section for additional requirements that may apply. 

Areas not under the control of owner/operator of the application block

• Buffer zones may not include residential areas (including employee housing, private 

property, buildings, commercial, industrial, and other areas that people may occupy or 

outdoor residential areas, such as lawns, gardens, or play areas, UNLESS,

1. The occupants provide written agreement that they will voluntarily vacate the 

buffer zone during the entire buffer zone period, and 

2. Reentry by occupants and other non-handlers must not occur until, 

° The buffer zone period has ended, and 

° For formulations with less than 80% methyl bromide, sensory irritation is not 

experienced. 

° For formulations with greater than 80% methyl bromide, the certified applicator 

or someone under his/her supervision has monitored the structures and has not 

experienced any sensory irritation. Entry by occupants and other non-handlers 

must not occur until, 

° Two consecutive air samples for methyl bromide have been taken in the 

structure at least 1 hour apart must indicate less than 1 ppm methyl bromide, 

and 

° Two consecutive air samples for chloropicrin have been taken in the structure 

at least 1 hour apart must indicate than less than 0.15 ppm chloropicrin is 

present. 

• Buffer zones may not include agricultural areas owned/operated by persons other than 

the owner/operator of the application block, UNLESS,

1. The owner/operator of the application block can ensure that the buffer zone will 

not overlap with a buffer zone from any adjacent property owner, and 

2. The owner/operator of the areas that are not under the control of the application 
150 

provides written agreement to the certified applicator supervising the fumigant 

application that they, their employees, and other persons will stay out of the buffer 

zone during the entire buffer zone period. 

• Buffer zones must not include roads and rights of way UNLESS, 

1. The area is not occupied during the buffer zone period, and 

2. Entry by non-handlers is prohibited during the buffer zone period. 

3. Applicators must comply with all local laws and regulations. 

• For all other publicly owned and/or operated areas such as parks, side walks, walking 

paths, playgrounds, and athletic fields, buffer zones must not include these areas 

UNLESS,

1. The area is not occupied during the buffer zone period, 

2. Entry by non-handlers is prohibited during the buffer zone period, and 

3. Written permission to include the public area in the buffer zone is granted by the 

appropriate state and/or local authorities responsible for management and operation of 

the area. 

4. Applicators must comply with all local laws and regulations. 

• See the Posting Section for additional requirements that may apply. 

Maximum 

Application Block 

Sizes for all 

formulations 

“Maximum Application Block Sizes 

The maximum application block sizes allowed for methyl bromide applications are: 

• 100 acres for tarped bedded and broadcast applications 

• 40 acres for untarped deep applications (i.e., California orchard replant)” 

Directions for 

Use 

(see next row 

for 98:2 

formulations) 

Maximum 

Application Block 

Sizes for Hot Gas 

Applications (98:2 

formulations only) 

“The maximum application block sizes allowed for methyl bromide hot gas applications 

are: 

• 10 acres for outdoor hot gas applications 

45,000 square feet for greenhouse hot gas applications”

Directions for 

Use 

immediately 

after above 

row 

Pre-plant 

Application 

Restrictions for all 

formulations 

“Maximum Application Rates for Critical Use Exemptions (CUEs) under the Montreal 

Protocol 

Maximum Application Rates for Pre-plant Soil Methyl Bromide CUEs

Crop Maximum Broadcast 

Equivalent Rates (lb ai/A) 

Eggplant 200 

Cucurbits (including muskmelons, 

cantaloupe, watermelon, cucumber, squash, 

pumpkin, and gourds) 

200 

Forest Nursery Seedlings 400 

Orchard Nursery Seedlings (raspberry, 

deciduous trees, roses) 

400 

Strawberry Nurseries 400 

Orchard Replant 1 (walnuts, almonds, stone 

fruit, table and raisin grapes, wine grapes) 

250 

Orchard Replant (grapes) 250 

Ornamentals 400 

Pepper, Bell 200 

Strawberry Fruit 235 

Sweet Potato Slips 200 

Tomato (grown for fresh market) 200 

In the 

Directions for 

Use for Preplant soil 

fumigation 

under the 

heading 

“Maximum 

Application 

Rates for 

Critical Use 

Exemptions 

under the 

Montreal 

Protocol” 

within its own 

box 

(see below 

row for 98:2 

formulations) 
151 

1 The maximum application rate when applying methyl bromide to individual tree holes 

using handheld equipment is 1.5 lb ai/100 ft2 

The maximum application rate for greenhouse hot gas applications is 1 lb ai/100 ft2 and 

the application block may not exceed 45,000 ft2.” 

Pre-plant 

Application 

Restrictions for 98:2 

formulations 

“The maximum application rate when applying methyl bromide to individual tree holes 

using handheld equipment is 1.5 lb ai/100 ft2 ” 

“The maximum application rate for greenhouse hot gas applications is 1 lb ai/100 ft2 and 

the application block may not exceed 45,000 ft2

” 

Directions for 

Use 

immediately 

after above 

row 

Pre-plant 

Application 

Restrictions 

“Quarantine Uses 

This product may be used as a soil fumigant as part of a quarantine program established by 

the United States Department of Agriculture-Animal and Plant Heath Inspection Service 

(USDA-APHIS) under the Plant Protection Act (7 U.S.C. 7701 et seq.). Limitations 

including but not limited to application rates and methods and crops and cropping practices 

shall be in accordance with those established by the USDA-APHIS quarantine program.” 

In the 

Directions for 

Use for Preplant soil 

fumigation 

under the 

heading 

“Maximum 

Application 

Rates for 

Quarantine 

Uses 

” within its 

own box 

For pre-plant soil 

use. 

Buffer Zone 

Distances 

“Buffer Zone Distances

Buffer zone distances must be calculated using the application rate and the size of the 

application block. 

 

Figure 1. Broadcast Application 

Figure 2. Bedded Application 

 

In Figures 1 and 2, the dashed line represents the perimeter of the field, the shaded area is 

the portion of the field that is treated, and the un-shaded area is the area of the field that is 

untreated. Assuming both fields are 10 acres, and only 50% of field in figure 2 is 

fumigated, the rate per treated acre is 400 lbs ai/A for both Figure 1 and 2. The broadcast 

rate for figure 1 is 400 lb ai/A but the effective broadcast equivalent rate for Figure 2 is 

200 lbs ai/A. The minimum buffer zone distances must be based on the broadcast or 

effective broadcast equivalent rates.” 

In the 

Directions for 

Use for Preplant soil 

fumigation 

under the 

heading “ 

Buffer Zone 

Distances” 
152 

Note to registrant: Labels may express rates as lbs per treated acre under the application 

instructions but they must identify buffer zone distances based on the broadcast or 

effective broadcast equivalent rates. 

Buffer zone distances

• Buffer zone distances must be based on look-up tables on product labels (25 feet is the 

smallest distance regardless of site-specific application parameters). 

• If the buffer zone, if after applying all applicable buffer zone credits, is greater than 1⁄2 

mile then the application is prohibited. 

• For selective replant fumigation in an orchard using hand held application methods 

(e.g., deep injection auger probes), the minimum buffer zone will be 25 feet measured 

from the center of each injection site (i.e., tree hole). 

“For selective replant fumigation in an orchard using hand-held application methods (e.g., 

deep injection auger probes), the minimum buffer zone will be 25 feet measured from the 

center of each injection site (i.e., tree hole). For all other applications, the amended RED 

tables must be used to determine the minimum buffer distances. Round-up to the nearest 

rate and block size, where applicable.” 

“Buffer Zone Look-up Table for Shank Bedded with Tarps” 

[See driver tables 11 and 12 for each formulation. If methyl bromide is the driver, insert 

Table 4 from Methyl Bromide RED. If chloropicrin is the driver, insert appropriate 

chloropicrin look-up table for shank bedded with tarps from chloropicrin RED.] 

“Buffer Zone Look-up Table for Shank Broadcast with Tarps” 

[See driver tables 11 and 12 for each formulation. If methyl bromide is the driver, insert 

Table 5 from Methyl Bromide RED. If chloropicrin is the driver, insert appropriate 

chloropicrin look-up table for shank broadcast with tarps from chloropicrin RED.] 

“Shank Broadcast without Tarps (CA orchard replant only)” 

[See driver tables 13 and 14 for each formulation. If methyl bromide is the driver, insert 

Table 6 from Methyl Bromide RED. If chloropicrin is the driver, insert appropriate 

chloropicrin look-up table for shank deep broadcast with tarps from chloropicrin RED.]

Buffer Zone 

Distances for Hot 

Gas Applications 

(98:2 formulations 

only) 

“Outdoor Hot Gas with Tarps” 

[insert from Table 7 from Methyl Bromide RED] 

“Greenhouse Hot Gas with Tarps” 

[insert from Table 8 from Methyl Bromide RED] 

In the 

Directions for 

Use for Preplant soil 

fumigation 

under the 

heading 

“Buffer Zone 

Distances” 

For pre-plant soil 

use. 

Buffer Zone Credits 

“Buffer Zone Credits 

The buffer zone distances for methyl bromide applications may be reduced by the 

percentages listed below. Credits may be added, but credits cannot exceed 80%. Also the 

minimum buffer zone distance is 25 feet regardless of buffer zone credits available. The 

maximum buffer zone is 0.5 mile (2,640 feet), with or without credits. 

• 30% reduction in buffer zone distance, IF using Canslit Heatstrip Silver and Canslit 

Metalized high-barrier tarps 

• 60% reduction in buffer zone distance, IF using Olefinas Embossed VIF, Klerks VIF, 

Pliant Blockade, Bromostop® (1.38 mil), Eval/Mitsui TIF (1.38 mil), Hytiblock 7 

Black (0.00125”), XL Black Blockade (0.00125”), Hytibar (1.5 mil), and IPM Clear 

VIF (1.38 mil) high barrier tarps 

In the 

Directions for 

Use for Preplant soil 

fumigation 

under the 

heading 

“Buffer Zone 

Credits” 
153 

• The tarp brand name, manufacturer, lot number, batch number, part number, and 

thickness must be recorded in the FMP. 

• 15% reduction in buffer zone distance, IF potassium thiosulfate (KTS) is applied with 

1⁄4 to 1⁄2 inch of water over a tarp 

• 10% reduction in buffer zone distance, IF the organic content of the soil in the 

application block is >1% - 2%; a 20% reduction is buffer zone distance, IF the organic 

content of the soil in the application block is >2% - 3%; and a 30% reduction in the 

buffer zone distance, IF the organic content of the soil in the application block is >3%. 

No credit will be given for soils with less than 1% organic matter. Record the 

measurements taken to verify the organic content in the FMP. 

• 10% reduction in buffer zone distance, IF the clay content of the soil in the application 

block is greater than 27%. Record the measurements taken to verify the clay content 

in the FMP. 

Example of Buffer Calculation if a Credit is Applicable

If the buffer zone distance for a 10 acre application block at a rate of 120 lbs ai/A is 185 

feet without any credits (see last row in Table 9). If the grower uses Bromostop® (1.38 

mil) high barrier tarp, the buffer zone can be reduced by 60%. The resulting buffer zone 

distance for this case is 74 feet. If the organic matter in the application block is two 

percent and Bromostop® (1.38 mil) high barrier tarp is used, the total credit would be 80% 

(60% for the tarp and 20% for organic content), and the resulting buffer zone distance 

would be 37 feet.” 

Application 

Restrictions 

“Restrictions for Schools and Other Difficult to Evacuate Sites 

• If the calculated buffer zone for a fumigant application is greater than 300 feet, then 

no fumigant applications will be permitted within 1/4 mile (1,320 feet) of schools 

(preschool to grade 12), state licensed day care centers, nursing homes, assisted living 

facilities, hospitals, in-patient clinics and prisons if occupied for a period of time that 

begins when the fumigant is first introduced into the soil and continues for 36 hours 

after delivery of the fumigant product has stopped. 

• If the calculated buffer zone for a fumigant application is 300 feet or less, then no 

fumigant applications will be permitted within 1/8 mile (660 feet) of schools 

(preschool to grade 12), state licensed day care centers, nursing homes, assisted living 

facilities, hospitals, in-patient clinics and prisons if occupied for a period of time that 

begins when fumigant is first introduced into the soil and continues for 36 hours after 

delivery of the fumigant product has stopped.” 

In the 

Directions for 

Use under the 

heading 

“Restrictions 

for Schools 

and Other 

Difficult to 

Evacuate 

Sites” 

For pre-plant soil 

use. 

Posting 

“Posting Fumigant Buffer Zones 

• Posting of a buffer zone is required unless there is a physical barrier that prevents 

bystander access to the buffer zone. 

• Buffer zone posting signs must: 

o Be placed at all usual points of entry and along likely routes of approach 

from areas where people not under the land operator’s control may approach 

the buffer zone. 

o Some examples of points of entry include, but are not limited to, roadways, 

sidewalks, paths, and bike trails. 

o Some examples of likely routes of approach are the area between a buffer 

zone and a roadway, or the area between a buffer zone and a housing 

development. 

• Buffer zone posted signs must meet the following criteria: 

o The printed side of the sign must face away from the treated area toward 

areas from which people could approach. 

In the 

Directions for 

Use for Preplant soil 

fumigation 

under the 

heading 

“Posting” 
154 

o Signs must remain legible during entire posting period and must meet the 

general standards outlined in the WPS for text size and legibility (see 40 CFR 

§170.120). 

o Signs must be posted before the application begins and remain posted until 

the buffer zone period has expired. 

o Signs must be removed within 3 days after the end of the buffer zone period. 

o Registrants must provide generic buffer zone posting signs which meet the 

criteria above at points of sale for applicators to use. 

Exception: If multiple contiguous blocks are fumigated within a 14-day period, the entire 

periphery of the contiguous blocks’ buffer zones may be posted. The signs must remain 

posted until the last buffer zone period expires and signs may remain posted until 3-days 

after the buffer zone period for the last block has expired. 

Additional requirements for treated area posting: 

• The treated area posted signs must remain posted for no less than the duration of 

the entry restricted period after treatment. 

• Treated area signs must be removed within 3 days after the end of the entryrestricted period. 

• Signs must meet the general standards in the WPS for placement, text size, and 

location (40 CFR §170.120).” 

Contents of Signs

The treated area sign must state the 

following: 

-- Skull and crossbones symbol 

 

-- "DANGER/PELIGRO," 

-- "Area under fumigation, DO NOT 

ENTER/NO ENTRE," 

-- "[Methyl bromide] Fumigant in USE," 

-- the date and time of fumigation, 

-- the date and time entry prohibition is 

lifted 

-- brand name of this product, and 

-- name, address, and telephone number of 

the certified applicator in charge of the 

fumigation. 

The buffer zone sign must state the 

following: 

-- Do not walk sign 

-- "DO NOT ENTER/NO ENTRE," 

-- "[Methyl Bromide] [Name of 

product] Fumigant BUFFER ZONE,” 

-- contact information for the certified 

applicator in charge of the fumigation

For pre-plant soil 

use. 

Site specific response 

and management 

“Emergency Preparedness and Response” 

• If the buffer zone is greater than 25 feet or less than or equal to 100 feet, and there are 

residences and businesses within 50 feet from the edge of the buffer zone 

• If the buffer zone is greater than 100 feet but less than or equal to 200 feet, and there 

are residences and businesses within 100 feet from the edge of the buffer zone 

• If the buffer zone is greater than 200 feet but less than or equal to 300 feet, and there 

are residences and businesses within 200 feet from the edge of the buffer zone 

• If the buffer zone is greater than 300 feet or the buffer zones overlap, and there are 

In the 

Directions for 

Use for Preplant soil 

fumigation 

under the 

heading 

“Emergency 

Preparedness 

and Response” 
155 

residences and businesses within 300 feet from the edge of the buffer zone 

Then the certified applicator must either follow the directions under the “fumigant site 

monitoring” section or follow the directions under the “response information for 

neighbors” section below. 

If the buffer zone is 25 feet then the Emergency Preparedness and Response requirements 

are not applicable. 

Fumigation Site Monitoring 

From the beginning of the fumigant application until the buffer zone period expires, a 

certified applicator or someone under his/her supervision must:. 

• Monitor for air concentrations of methyl bromide and chloropicrin in areas between 

the buffer zone perimeter and the areas (such as residences and businesses) that trigger 

this requirement. 

• Monitoring the air concentration levels must begin the evening on the day of 

application and continue until the buffer zone period expires with a minimum of at 

least 8 samples during the buffer zone period, including these periods: 

- once, 1 hour before sunset, 

- once, during the night, 

- once, 1 hour after sunrise, and 

- once, during the day. 

If at any time the person monitoring the air concentrations experiences sensory irritation, 

then the emergency response plan stated in the FMP must be immediately implemented. 

If other problems occur, such as a tarp coming loose, then the appropriate control plan 

must be activated. The location and results of the air monitoring must be recorded in the 

post application summary report. 

Response Information for Neighbors 

The certified applicator (or someone under his/her supervision) supervising the fumigation 

must ensure that residences and owners/operators of businesses that meet the criteria below 

have been provided the emergency response information at least 1 week before fumigation 

occurs. The information provided may include application dates that range for no more 

than 4 weeks. After 4 weeks, the information must be delivered again. 

Information that must be included: 

• The general location of the application block 

• Fumigant(s) applied including the active ingredient, name of the fumigant product(s), 

and the EPA Registration number 

• Contact information for the applicator and property owner/operator 

• Time period in which the fumigation is planned to take place (must not range more than 

4 weeks) 

• Early signs and symptoms of exposure to the fumigant(s) applied, what to do, and who 

to call if you believe you are being exposed (911 in most cases). 

• How to find additional information about fumigants. 

The method used to share the response information for neighbors must be described in the 

FMP and may be accomplished through mail, door hangers, or through other methods that 

will effectively inform people in residences and businesses within the required distance 

from the edge of the buffer zone.” 

Notice to State and “Notice to State and Tribal Lead Agencies Directions for 
156 

Tribal Lead Agencies 

If your state and/or tribal lead agency requires notice, information must be provided to the 

appropriate state or tribal lead agency prior to the application. Please refer to 

http://www.epa.gov/pesticides/reregistration/soil_fumigants/ for a list of states and tribal 

lead agencies that require notice and information on how to submit the information. 

The information that must be provided to state and trial lead agencies includes the 

following: 

o Location of the application blocks, 

o Fumigant(s) applied including EPA Registration #, 

o Applicator and property owner/operator contact information, 

o Time period that fumigation may occur.” 

Use under 

“Notice to 

State and 

Tribal Lead 

Agencies” 

Environmental 

Hazards 

“This pesticide is toxic to mammals and birds. Do not apply directly to water, or to areas 

where surface water is present or to intertidal areas below the mean high water mark. Do 

not contaminate water when disposing of equipment washwaters or rinsate. 

Methyl bromide has certain properties and characteristics in common with chemicals that 

have been detected in groundwater (methyl bromide is highly soluble in water and has low 

adsorption to soil), volatilization is this chemical's most important route of dissipation. 

For untarped applications of methyl bromide, leaching and runoff may occur if there is 

heavy rainfall after soil fumigation.” 

Precautionary 

Statements 

immediately 

following the 

User Safety 

Recommendat

ions 

General Application 

Restrictions 

“Do not apply this product in a way that will contact workers or other persons, either 

directly or through drift. Only protected handlers may be in the area during application.” 

Place in the 

Direction for 

Use directly 

above the 

Agricultural 

Use Box. 

BUFFER ZONE DRIVER TABLES 

Table 11. Standard Tarp (no credits) Buffer Zone Driver Table 

Formulation 

Application 

Method 

98:2 80:20 75:25 67:33 57:43 50:50 45:55 33:67 

Broadcast Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Chloropicrin 

Bed Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Table 12. Standard Tarp (no credits) Buffer Zone Driver Table 

Formulation 

Application 

Method 

98:2 80:20 75:25 67:33 57:43 50:50 45:55 33:67 

Broadcast Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Chloropicrin Chloropicrin Chloropicrin 

Bed Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Chloropicrin 
157 

Table 13. Deep (≥ 18 inches) Untarp Buffer Zone Driver Table 

Formulation 

Application 

Method 

98:2 80:20 75:25 67:33 57:43 50:50 45:55 33:67 

Broadcast Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Chloropicrin Chloropicrin 

Table 14. Deep (≥ 18 inches) Untarp Buffer Zone Driver Table 

Formulation 

Application 

Method 

98:2 80:20 75:25 67:33 57:43 50:50 45:55 33:67 

Broadcast Methyl 

Bromide 

Methyl 

Bromide 

Methyl 

Bromide 

Chloropicrin Chloropicrin Chloropicrin Chloropicrin Chloropicrin 
158 

APPENDIX A 

Methyl Bromide PC Code 053201 Pre-plant Soil Uses Eligible for Reregistration 
159 

Appendix A. Methyl Bromide PC Code 053201 Pre-plant Soil Uses Eligible for Reregistration 

Use Site Formulation 

Method of 

Application 

Maximum 

Application Rate 

Use 

Limitations 

Eggplant Pressurized gas with 80% or less 

methyl bromide 

Shank 

Injected 

170 lb ai/A 

Cucurbits (including 

muskmelons, 

cantaloupe, 

watermelon, cucumber, 

squash, pumpkin, and 

gourds) 

Pressurized gas with 80% or less 

methyl bromide 

Shank 

Injected 

200 lb ai/A 

Forest Nursery 

Seedlings 

Pressurized gas 

 (all methyl bromide: chloropicrin 

ratios including 98:2) 

Shank 

Injected 

260 lb ai/A 

Orchard Nursery 

Seedlings (raspberry, 

deciduous trees, roses) 

Pressurized gas with 80% or less 

methyl bromide 

Shank 

Injected 

200 lb ai/A 

Strawberry Nurseries Pressurized gas with 80% or less 

methyl bromide 

Shank 

Injected 

260 lb ai/A 

Orchard Replant 

(walnuts, almonds, 

stone fruit, table and 

raisin grapes, wine 

grapes) 

Pressurized gas (all methyl bromide: 

chloropicrin ratios including 98:2) 

Shank 

Injected 

200 lb ai/A 

Orchard Replant 

(grapes) 

Pressurized gas (all methyl bromide: 

chloropicrin ratios including 98:2) 

Shank 

Injected 

250 lb ai/A 

Orchard Replant 

(individual tree holes 

using) 

Pressurized gas (all methyl bromide: 

chloropicrin ratios including 98:2) 

handheld 

equipment 

1.5 lb ai/ 

100 ft2 

Ornamentals Pressurized gas with 80% or less 

methyl bromide 

Shank 

Injected 

360 lb ai/A 

Ornamentals Pressurized gas with 98% methyl 

bromide 

Hot Gas 360 lb ai/A 

Pepper, Bell Pressurized gas with 80% or less 

methyl bromide 

Shank 

Injected 

170 lb ai/A 

Strawberry Fruit Pressurized gas with 80% or less 

methyl bromide 

Shank 

Injected 

200 lb ai/A 

Sweet Potato Slips Pressurized gas with 80% or less 

methyl bromide 

Shank 

Injected 

200 lb ai/A 

Tomato (grown for 

fresh market) 

Pressurized gas with 80% or less 

methyl bromide 

Shank 

Injected 

160 lb ai/A 

Quarantine uses Pressurized gas (all methyl bromide: 

chloropicrin ratios including 98:2) 

Use sites defined as part of a 

quarantine program established by 

the United States Department of 

Agriculture-Animal and Plant Heath 

Inspection Service (USDA-APHIS) 

under the Plant Protection Act (7 

U.S.C. 7701 et seq.). Limitations 

including but not limited to 

application rates and methods and 

crops and cropping practices shall be 

in accordance with those established 

by the USDA-APHIS quarantine 

program. 

See applicable 

GAPs from 

label table 
160 

APPENDIX B 

PERFUM Model Inputs and Outputs 
161 

Appendix B. PERFUM Model Inputs and Outputs 

Inputs for PERFUM Model 

The major input parameters for the fumigant emission and dispersion modeling were: 

application rates, application block sizes, application method emission profiles, weather 

conditions, and the target air concentration (based on acute inhalation endpoint and uncertainty 

factors). 

 Rates 

The Agency modeled up to 430 lb ai/acre for broadcast applications and 250 lbs ai/acre 

effective broadcast rate for bedded applications in the July 2008 RED. Although labels permit 

higher broadcast equivalent rates, such values were not evaluated because the rates considered 

were found to be the upper bound of methyl bromide rates used. According to EPA proprietary 

data for 2004-2005, approximately 95% of methyl bromide was applied at a rate of 250 lb ai/acre 

or less. This is illustrated in the Agency’s benefits assessments by crop and region that include a 

more detailed analysis of use rates. These assessments are available for review in the methyl 

bromide docket (EPA-HQ-OPP-2005-0123) at www.Regulations.gov. Values assumed for rates 

were based largely on recent critical use nominations (CUNs) and applications by grower groups 

for critical use exemptions (CUEs).

Rates for bedded or strip applications (lb ai per treated area) were converted to broadcast 

equivalent application rates to determine the minimum buffer zone distance. In Figures 1 and 2 

(shown below), the dashed line represents the perimeter of the field, the shaded area is the 

portion of the field that is treated, and the un-shaded area is the area of the field that is untreated. 

Assuming that both fields are 10 acres, and only 50% of the field in Figure 2 is fumigated, the 

rate per treated acre is 400 lbs ai/A for both Figure 1 and 2. The broadcast rate for Figure 1 is 

400 lb ai/A but the effective broadcast equivalent rate for Figure 2 is 200 lbs ai/A. 

Labels may express rates as lbs per treated acre under the application instructions but 

they must identify buffer zone distances based on the broadcast or effective broadcast equivalent 

rates. [Note: In the risk assessment, a 60 percent value of field treated was used in the 

calculations.] 

 

 

Figure 1. Broadcast Application Figure 2. Bedded Application 
162 

 Block sizes 

The Agency had limited information available on the size of application blocks typically 

treated in a given day, but estimates that each crew or application rig treats less than 40 acres for 

most treatment methods. However, several commercial applicators have indicated they 

sometimes use multiple rigs and crews to treat blocks of more than 80 acres per day. 

The application block size pertains to size of the field and not the size of the area treated. 

The area inside the dashed lines in both Figures 1 and 2 is the application block. In this example 

the application block size for both figures is 10 acres. For both figures, 10 acres would be used 

to determine the buffer zone distance. 

 Emission profiles 

The Agency’s risk assessment for the July 2008 RED included modeling of 5 outdoor 

pre-plant soil application methods: (1) tarped broadcast, (2) tarped bedded, (3) shallow untarped 

broadcast, (4) deep untarped broadcast, and (5) tarped hot gas. The modeling performed by EPA 

was based on 5 emission profiles developed by the California Department of Pesticide 

Regulation (CDPR) derived from 17 studies conducted in California from 1992 to 1999. Buffer 

zone distances for other application methods were also derived by the EPA from these profiles 

(e.g., buffer zone distances for strip applications were derived from broadcast emission profile). 

It should be noted that the profiles modeled do not reflect the performance of today’s high barrier 

tarps. The profiles also may not be representative of some methods/equipment used outside 

California. In the U.S., tarped bedded and tarped broadcast are the most common methods, hot 

gas and deep untarped use is somewhat limited, while shallow untarped application is reportedly 

no longer used. Note that only tarped uses will be allowed henceforth except in limited 

circumstances as described in the Generic Risk Management sections above. 

In the July 2008 RED, the Agency modeled greenhouse pre-plant soil applications 

scenarios using a conservative estimate of the emission profile (see the June 2, 2008, addenda to 

April 10, 2007, Phase 5 Health Effects Division (HED) Human Health Risk Assessment For 

Soil, Greenhouse, and Residential/Structural in the methyl bromide docket). 

 Weather 

The largest methyl bromide use in the U.S. occurs in Florida and California followed by 

Michigan. Based on these high-use areas, five weather data sets were modeled in the 2008 RED 

(Ventura, California; Bakersfield, California; Bradenton, Florida; Tallahassee, Florida; and Flint, 

Michigan). The California and Florida locations are intended to represent inland and coastal 

weather conditions. Each modeling run used five years of weather Data (e.g., 1,825 potential 

application days) for each weather location. Generally, Ventura, and Bradenton weather data 

result in the largest buffer zone distances, followed by Bakersfield and Tallahassee. Flint, 

Michigan, data resulted in significantly smaller buffers compared to the other four locations. 

The methyl bromide RED addendum used the same weather data sets as inputs to the PERFUM 

model. 
163 

 Target air concentration 

As described in Section III, a non-reversible acute inhalation endpoint was selected from 

a developmental rabbit study with a LOAEL based on agenesis of the gall bladder and fused 

sternebrae. The human equivalent concentration is 10 ppm for a 24-hour TWA with uncertainty 

factor of 30 (i.e., target MOE of 30 and a target air concentration of 0.33 ppm). Based on several 

factors including the severity, irreversibility of the effect, and the quality of the hazard database, 

the buffer zone distances chosen focused on achieving an MOE of 30 at upper percentiles of both 

whole field and maximum distance distributions (these terms are described below) from 

PERFUM modeling outputs, as well as achieving an MOE of 30 or greater at the 99th percentile 

air concentration from PERFUM outputs. This endpoint and concentration was used in the 

methyl bromide RED addendum. 

PERFUM Model Outputs 

The PEFRUM model outputs are presented in percentiles for “whole field” and the 

“maximum distance” distributions. The model also provides outputs as distributions of air 

concentrations from which margins of exposure (MOEs) can be estimated. The following 

summarizes the key points for each of these output parameters. 

The maximum distance distribution is a compilation of the farthest predicted distances 

(i.e., the farthest downwind points) over 5 years of weather. The whole field distribution differs 

because it includes all points around the perimeter of the application block for the same period. 

Another way to consider the difference between the distributions is that maximum distance 

results are a subset of the whole field results and that maximum distances allow for more 

resolution at the upper percentiles of this distribution. Version 2.1.4 of PERFUM also allows for 

direct consideration of air concentrations at various distances around treated fields. These air 

concentrations and MOEs were also considered in the decision making process. 

An analysis based on a variety of PERFUM outputs was used in the buffer distance 

determinations. This involved consideration of the typical maximum and whole-field results, 

which are predictions of the distances where a target concentration of concern is achieved at 

varying percentiles of exposure. In addition, a complementary approach, which determined the 

percentiles of exposure for maximum and whole-field buffers at predetermined buffer distances, 

was employed. Air concentration data were also used to calculate risk estimates (i.e., MOEs) at 

predefined buffer distances and varied percentiles of exposure. 

This overall approach allowed the Agency to utilize more of the information available 

from PERFUM so that a more comprehensive view of the risks could be considered. Buffer 

distances indicated by this type of analysis along with information from monitoring studies and 

incidents were valuable in determining buffer distances to manage potential risks from methyl 

bromide use when coupled with other mitigation measures. 
164 

APPENDIX C 

FMP Template for Methyl Bromide Soil Applications
165 

FUMIGANT MANAGEMENT PLAN

Certified Applicator Supervising the Fumigation 

Name and phone number: License number: 

 Commercial applicator 

 Private applicator 

Employer name and address: Date of completing registrant 

training program: 

General Site Information 

Application block location, address, or global positioning system (GPS) coordinates: 

Name, address, and phone number of owner/operator of application block: 

General Application Information 

Target application date/window: Brand name of fumigant: EPA Registration Number: 

Tarps (check here if section is not applicable  )

Brand name: Lot #: Thickness: 

Name and phone number of contact person responsible for repairing tarps: 

Schedule for checking tarps for damage, tears, and other problems: 

Maximum time following notification of damage that the person(s) responsible for tarp repair will respond: 

Minimum time following application that tarp will be repaired: Minimum size of damage that will be repaired: 

Other factors used to determine when tarp repair will be conducted: 

Name and phone number of contact person responsible for cutting 

and/or removing tarps (if other than certified applicator): 

Equipment/methods used to cut tarps: 

Schedule and target dates for cutting tarps: Schedule and target dates for removing tarps: 

Soil Conditions 

Description of soil texture and moisture in application block: Description of method used to determine soil moisture level: 
166 

Weather Conditions 

Summary of the weather forecast for the day of the application and the 48-hour period following the fumigant application (may attach a copy 

of printed forecast to FMP): 

Buffer Zones 

Application method: 

  Bedded 

  Broadcast 

  Hot gas - outdoor 

  Hot gas - greenhouse 

  Hand held probes 

Rate from 

lookup table 

on label (lb 

ai/A): 

Block size 

from lookup 

table on label 

(acres): 

Credits applied: 

 high barrier film _____________ % 

 organic content _____________ % 

 clay content _____________ % 

 other: _____________ % 

Total credits _____________ % 

Buffer zone 

distance: 

__________ ft 

List and describe areas in the buffer zone that are not under the control of owner/operator of the application block: 

Personal Protective Equipment for Handlers 

Handler Task Clothing 

Respirator Type, Filter Cartridge 

Type and Change-out Schedule 

Eye 

Protection Gloves Other 

Emergency Response Plan 

Description of evacuation routes: 

Locations of telephones: 

Contact information for first responders: Local/state/federal contacts: Other contact information for emergencies: 

Emergency procedures/responsibilities in case of an incident, equipment/tarp/seal failure, complaints or elevated air concentration levels 

outside buffer zone suggesting potential problems, or other emergencies). 

Posting Signs 

Name and phone number of person that is doing posting: 

Location of posting signs: 

Procedures for posting and sign removal: 
167 

Site Specific Response and Management  Fumigation Site Monitoring or Response Information for Neighbors 

If Response Information for Neighbors has been selected, completed the following: 

If buffer zone is 25-100 ft:  Neighbors within 50 ft of buffer zone  No neighbors within 50 ft of buffer zone 

If buffer zone is 100-200 ft:  Neighbors within 100 ft of buffer zone  No neighbors within 100 ft of buffer zone 

If buffer zone is 200-300 ft:  Neighbors within 200 ft of buffer zone  No neighbors within 200 ft of buffer zone 

If buffer zone is > 300 ft:  Neighbors within 300 ft of buffer zone  No neighbors within 300 ft of buffer zone 

If buffer zones overlap  Neighbors within 300 ft of buffer zone  No neighbors within 300 ft of buffer zone

List of residences and businesses informed (neighboring property owners): 

Name, address, and phone number of person providing information: 

Method used to provide information: 

Notice to State Lead Tribal Agencies 

If your state and/or tribal lead agency requires notice, list contacts that were notified: Date notified: 

Communication Between Applicator, Land Owner/Operator, and Other On-site Handlers 

Plan for communicating to the land owner/operator and all on-site handlers (e.g., tarp cutters/removers, irrigators) requirements to comply 

with label including location and start/stop times of buffer zones; timing of tarp cutting/removal, and PPE: 

Names and phone numbers of persons contacted: Date contacted: 

Comments/notes: 
168 

Site Map 

Location of application block: _______________________________________________________________________________ 

Map Legend 

 Application block Buffer zone Property lines Roads Right-of-way Walkway, sidewalk, path 

B Bus stop WB Water body DC Daycare facility 

Sch

 School 

NAB

 Nearby application block 

 

IPC

 Inpatient clinic P Prison Well Nursing home 

ALF

 Assisted living facility

 NH
169 

Handler Information 

Handler Name, Address, and Phone 

Number 

Employer Name, Address, and Phone 

Number 

Tasks They are Trained and 

Authorized to Perform 

Date of PPE 

Training 

Qu
170 

Air Monitoring Plan 

For Buffer Zone Monitoring: (check here if section is not applicable  ) 

Name of handler 

performing monitoring 

activities Handler address 

Handler phone 

number Location of monitoring Timing 

For Handlers without Respiratory Protection: (check here if section is not applicable  ) 

If sensory irritation is experienced:  Intend to cease operations  Intend to continue operations with respiratory protection 

If intend to continue operations with respiratory protection, complete section for Handlers with Respiratory Protection below. 

If intend to cease operations - Name, address, and phone number of handler to perform monitoring 

activities prior to operations resuming: 

Monitoring equipment: 

For Handlers with Respiratory Protection: (check here if section is not applicable  ) 

Representative Handler Tasks to be Monitored Monitoring Equipment Timing 
171 

Air Monitoring Plan for Methyl Bromide Formulation with < 20% Chloropicrin 

For Buffer Zone Monitoring: (check here if section is not applicable  ) 

Name, address, and phone number of person(s) to perform sampling: 

Area or Structure to be Monitored Before Reentry is Permitted Monitoring Equipment Timing

For Handlers with Respiratory Protection: 

Representative Handler Tasks to be Monitored Monitoring Equipment Timing 
172 

Methyl Bromide FMP Check List

General Site Information 

A map, aerial photo, or detailed sketch is attached to this FMP that shows each of the following with distances from the application site 

labeled: field location, application block dimensions, buffer zones, property lines, roads, bus stops, water bodies, wells, rights-of-ways, 

nearby application blocks, surrounding structures, and sites requiring 1⁄8 and 1⁄4 mile buffer zones. 



Supervision of Handlers 

An on site certified applicator will directly supervise the handlers participating in the application starting when the fumigant is first 

introduced into the soil and ending after the fumigant has stopped being delivered/dispensed to the soil and the soil is sealed. 

After the application is complete, and before leaving the application block, the certified applicator has provided the owner/operator and 

handlers with written information necessary to comply with the label and procedures outlined in the FMP. 

Fumigant safe handling information has been provided to each handler involved in the application or confirm that each handler 

participating in the application has received fumigant safe handling information in the past 12 months. 

For all fumigation handling tasks, at least 2 WPS-trained handlers must be present. 

Weather Conditions 

Wind speed at the application site is a minimum of 2 mph at the start of the application or forecasted to reach at least 5 mph during the 

application. 

A shallow, compressed (low-level) temperature inversion is not forecast to persist for more than 18 consecutive hours during the 48-hour 

period after the application. 

An air-stagnation advisory is not in effect for the area where the application site is located. 

If air temperatures have been above 100 degrees F in any of the 3 days prior to application, then soil temperature will be measured and 

recorded in the post application summary report. 

Soil Conditions 

The soil has been properly prepared and the surface has been checked to ensure that it is free of clods that are golf ball size or larger. 

The area to be fumigated has been tilled to a depth of 5 to 8 inches. 

Field trash has been properly managed (e.g., residue from a previous crop has been worked into the soil to allow for decomposition prior 

to fumigation, little or no crop residue is present on the soil surface, and crop residue that is present does not interfere with the soil seal). 

The soil temperature at the depth of injection ≤ 90 degrees F at the beginning of the application. 

The soil moisture at 9 inches below the surface is sufficient (field capacity is 50 to 80 percent). 

Trash pulled by the shanks to the ends of the field will be covered with tarp or soil before making the turn for the next pass. 

Shank Applications (check here if section is not applicable  )

For tarped-broadcast and -bedded applications, injection points will be at least 8 inches from the nearest final soil/air interface. 

For tarped-bedded applications, the injection depth will not be as deep as the lowest point of the tarp (i.e., the lowest point of the tuck). 

For untarped-bedded applications, the injection points will be at least 12 inches from the nearest final soil/air interface. 

For untarped-broadcast applications, the injection points will be at least 18 inches from the nearest final soil/air interface. 

For broadcast untarped applications, a disc or similar equipment will be used to uniformly mix the soil to at least a depth of 3 to 4 inches 

to eliminate the chisel or plow traces and will following elimination of the chisel trace, the soil surface will be compacted with a 

cultipacker, ring roller, and roller in combination with tillage equipment. 



For performed bed applications, the soil will be sealed by disruption of the chisel trace using press sealers, bed shapers, cultipackers, or 

by re-shaping (e.g., relisting, lifting, replacing) the beds immediately following injection. 

For beds formed at the time of application, the soil will be sealed by disrupting the chisel trace using press sealers, or bed shapers. 

For shanked bedded and broadcast applications, tarps will be installed immediately after fumigant is injected into the soil. 

Applicators have been trained and instructed not to apply or allow fumigant to drain onto the soil surface. 

For each injection line a check valve been located as close as possible to the final injection point, or applicators will drain/purge the line 

of any remaining fumigant prior to lifting injection shanks from the ground. 

Applicators have been trained and instructed not to lift injection shanks from the soil until the shut-off valve has been closed and the 

fumigant has been depressurized (passively drained) or purged (actively forced out via air compressor) from the system. 

Brass, carbon steel, or stainless steel fittings must be used throughout application rigs. 

Polyethylene tubing, polypropylene tubing, Teflon® tubing or Teflon® -lined steel braided tubing have been used for all low pressure 

lines, drain lines, and compressed gas or air pressure lines and is all other tubing Teflon® -lined steel braided. 

Application equipment been inspected to ensure that application rigs do not contain galvanized, PVC, nylon, or aluminum pipe fittings. 

All rigs include a filter to remove any particulates from the fumigant, and a check valve to prevent backflow of the fumigant into the 

pressurizing cylinder or the compressed air system. 

All rigs include a flowmeter or a constant pressure system with orifice plates to insure the proper amount of fumigant is applied. 

Applicators have been trained and instructed to ensure that positive pressure is maintained in the cylinder at not less than 200 psi during 

the entire time it is connected to the application rig, if a compressed gas cylinder is used. (This is not required for a compressed air 

system that is part of the application rig because if the compressor system fails the application rig will not be operable). 



Application rigs are equipped with properly functioning check valves between the compressed gas cylinder or compressed air system and 

the fumigant cylinder. 

Applicators have been trained and instructed to always pressurize the system with compressed gas or by use of a compressed air system 

before opening the fumigant cylinder valve. 
173 

Before using a fumigation rig for the first time, or when preparing it for use after storage, applicators have been trained and instructed to: 

° Check the filter, and clean or replace the filter element as required. 

° Check all tubes and chisels to make sure they are free of debris and obstructions. 

° Check and clean the orifice plates and screen checks, if installed. 

° Pressurize the system with compressed gas or compressed air, and check all fittings, valves, and connections for leaks using soap 

solution. 



Applicators have been trained and instructed to: 

° Install the fumigant cylinder, and connect and secure all tubing. Slowly open the compressed gas or compressed air valve, and 

increase the pressure to the desired level. Slowly open the fumigant cylinder valve, always watching for leaks. 

° When the application is complete, close the fumigant cylinder valve and blow residual fumigant out of the fumigant lines into the 

soil using compressed gas or compressed air. At the end of the application, disconnect all fumigant cylinders from the application 

rig. At the end of the season, seal all tubing openings with tape to prevent the entry of insects and dirt. 

° Calibrate all application equipment and ensure that all control systems must be working properly. 



Hot Gas Applications (check here if section is not applicable  )

Tarps have been installed prior to starting the application. 

All delivery tubes have been placed under the tarp in such a way that they do not move during the application of methyl bromide. 

The fumigant will be introduced from outside of the greenhouse. 

All fittings, connections, and valves have been checked for leaks prior to fumigation and if cylinders are replaced during the fumigation 

process, the connections and valves were checked for leaks prior to continuing the job. 

Tree Replant (non-shank) Application (check here if section is not applicable  )

For each individual tree-site, the tree stump and primary root system have been removed and the tree hole has been backfilled with soil 

before application. 

The fumigant will be injected at a depth of at least 18 inches into the soil. 

The wand will be cleared using nitrogen or compressed air before removing it from the soil and after the wand is cleared and removed 

from the soil, the injection hole will be covered with soil and tamp or the soil will be compacted over the injection hole. 

Buffer Zones 

There are no difficult to evacuate sites within 1⁄4 (or 1⁄8) miles of the application block that will be occupied during the buffer zone period. 

There are no bus stops or other locations where persons wait for public transit within the buffer zone. 

There are no buildings used for storage such as sheds, barns, garages, within the buffer zone that are occupied or that share a common 

wall with an occupied structure. 

For areas in the buffer zone that are not under the control of owner/operator of the application block, written agreement has been 

obtained from occupants that they will voluntarily vacate the buffer zone during the entire buffer zone period. 

For nearby agricultural areas that are in the buffer zone the owner/operator of that property provided written agreement that they, their 

employees, or other persons will stay out of the buffer zone during the entire buffer zone period. 

For publicly owned and/or operated areas (e.g., parks, rights of way, side walks, walking paths, playgrounds, athletic fields) written 

permission has been given to include the public area in the buffer zone from the appropriate local and/or state officials. 

Buffer Zones Overlap (check here if section is not applicable  ) 

A minimum of 12 hours has elapsed from the time the 1st application ends until the 2nd application begins. 

If a structure exists within 300 feet of the buffer zone, appropriate emergency preparedness and response procedures are followed. 

Certified applicator has informed handlers of the overlapping buffers and associated health protection requirements. 

Personal Protective Equipment for Handlers

At least 1 air rescue device (e.g., SCBA) is on-site in case of an emergency. 

All of the handler’s PPE has been cleaned and maintained as required by the WPS for Agricultural Pesticides. 

Hazard Communication 

The application area buffer zone has been posted in accordance with the label. 

Pesticide product labels and material safety data sheets are on-site and readily available for employees to review. 

Recordkeeping 

The owner/operator of the application block has been informed that he/she as well as the certified applicator must keep a signed copy of 

the site-specific FMPs and the post-application summary record for 2 years from the date of application. 

I have verified that this site-specific FMP reflects current site conditions and product label directions before beginning the 

fumigation. 

_______________________________________________ ___________________________________ 

Signature of certified applicator supervising the fumigation Date
174 

Post-Application Summary

General Application Information 

Application date and time: Application rate: Size of application block: 

Weather Conditions 

Summary of the weather on the day of the application: 

Summary of the weather during the 48-hour period following the fumigant application: 

Soil Conditions (check here if section is not applicable  )

Soil temperature if air temperatures were above 100 degrees F in any of the 3 days prior to the application: 

Tarp Damage and Repair (check here if section is not applicable  )

Location and size of tarp damage: 

Description of tarp/tarp seal/tarp equipment failure: 

Date and time of tarp repair: 

Additional comments or other deviations from FMP (if applicable): 

Tarp Removal (check here if section is not applicable  )

Description of tarp removal (if different than in the FMP): 

Date tarps were cut: Date tarps were removed: 

Complaints (check here if section is not applicable  )

Person filing complaint: 

 On-site handler 

 Person off-site 

If off-site person, name, address, and phone number of person filing complaints: 

Description of control measures or emergency procedures followed after complaint: 

Additional comments: 
175 

Description of Incidents (check here if section is not applicable  )

Description of incident, equipment failure, or other emergency: Date and time: 

Description of emergency procedures followed: 

Additional comments: 

Elevated Air Concentration Levels (check here if section is not applicable  )

 On-site 

 Outside buffer zone 

Location of elevated air concentration levels: Date and time: 

Description of elevated air concentration levels: (provide air monitoring results on next page) 

Description of control measures or emergency procedures followed: 

Description of deviations from FMP (if applicable): 

Posting Signs 

Date of sign removal: 

Description of deviations from FMP (if applicable): 

Other 

Additional comments/notes: 
176 

Air Monitoring Results 

When Respiratory Protection is Not in Use – Sensory Irritation Experienced (check here if section is not applicable  )

Date and Time Handler Task/Activity 

Handler Location Where 

Irritation Was Observed Resulting Action Comments 

  Cease operations 

 Respiratory protection 

  Cease operations 

 Respiratory protection 

  Cease operations 

 Respiratory protection 

  Cease operations 

 Respiratory protection 

  Cease operations 

 Respiratory protection 

When Respiratory Protection is in Use – Direct Read Instrument Air Monitoring (check here if section is not applicable  )

Sample Type 

Sample 

Number 

Sample 

Date/Time 

Handler 

Task/Activity 

(not 

applicable for 

structural 

monitoring) 

Handler 

Location/ 

Structure 

Location 

Air 

Concentration 

Sampling 

Method 

Comments (e.g., 

sensory irritation 

experienced while 

wearing 

respirator) 

Area 

Breathing Zone 

Structure 

 

Area 

Breathing Zone 

Structure 

 

Area 

Breathing Zone 

Structure 

 

Area 

Breathing Zone 

Structure 

 

Area 

Breathing Zone 

Structure 

 

Area 

Breathing Zone 

Structure 

 

Area 

Breathing Zone 

Structure 

 

Area 

Breathing Zone 

Structure 

 

Area 

Breathing Zone 

Structure 

 

Area 

Breathing Zone 

Structure 

 

I have verified that this post application summary reflects the actual site conditions during the fumigation and an accurate 

description of deviations from the FMP (if applicable). 

_______________________________________________ ___________________________________ 

Signature of certified applicator supervising the fumigation Date
177 

APPENDIX D 

Technical Support Documents 
178 

Appendix D. Technical Support Documents 

Additional documentation in support of this RED is maintained in the OPP docket, 

located in room S-4400, One Potomac Yard (South Building), 2777 S. Crystal Drive, Arlington, 

VA 22202. It is open Monday through Friday, excluding legal holidays, from 8:30 am to 4 pm. 

 All documents, in hard copy form, may be viewed in the OPP docket room or 

downloaded or viewed via the Internet at the following site: http://www.regulations.gov. These 

documents include: 

Human Health 

1. EPA-HQ-OPP-2005-0123-0285, Methyl Bromide: Phase 5 Health Effects Division (HED) 

Human Health Risk Assessment for Soil, Greenhouse, and Residential/Structural Uses. 

2. June 2, 2008 addenda to April 10, 2007 Phase 5 Health Effects Division (HED) Human 

Health Risk Assessment For Soil, Greenhouse, and Residential/Structural (DP Barcode: 

D350818). 

3. June 9, 2008 memo, Factors Which Impact Soil Fumigant Emissions - Evaluation for Use in 

Soil Fumigant Buffer Zone Credit Factor Approach (DP Barcode: 306857). 

4. EPA-HQ-OPP-2005-0123-0317, Review of Fumigants Group Incident Reports. 

5. EPA-HQ-OPP-2005-0123-0318, Summary Fumigants Group Incident Reports. 

6. EPA-HQ-OPP-2005-0123-0319, Summary Fumigants Group Incidents. 

Stratospheric Ozone Depletion 

7. EPA-HQ-OPP-2005-0123-0165, Methyl Bromide: Science of Ozone Depletion and Health 

Effects Estimates. 

8. EPA-HQ-OPP-2005-0123-0166, Human Health Benefits Of Stratospheric Ozone Protection. 

9. EPA-HQ-OPP-2005-0123-0167, Regulatory Impact Analysis, Protecting Stratospheric 

Ozone: Process for Exempting Critical Uses from the Phaseout of Methyl Bromide. 

10. EPA-HQ-OPP-2005-0123-0168, OAP’s Economic Impact Analysis For Methyl Bromide 

Allocation In The United States. 

11. EPA-HQ-OPP-2005-0123-0169, OAP’s Benefits Analysis. 

Environmental Fate and Ecological Risk 

12. EPA-HQ-OPP-2005-0123-0029, Revised Draft Methyl Bromide Environmental Fate and 

Ecological Risk Assessment - Following the Review of 30-Day Error Correction Comments. 

13. EPA-HQ-OPP-2005-0123-0038, Reregistration Environmental Risk Assessment for Methyl 

Bromide. 

Benefits

14. EPA-HQ-OPP-2005-0123-0321, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Metam-Sodium, and Methyl Bromide in Eggplant Production. 

15. EPA-HQ-OPP-2005-0123-0322, Assessment of the Benefits Soil Fumigants (Methyl 

Bromide, Chloropicrin, Metam-Sodium, Dazomet) Used by Forest Tree Seedling Nurseries. 

16. EPA-HQ-OPP-2005-0123-0323, Assessment of the Benefits of Soil Fumigation with Methyl 

Bromide, Chloropicrin, Dazomet, Metam Potassium and Metam Sodium for Use in 
179 

Raspberry Nurseries, Fruit and Nut Deciduous Tree Nurseries, and Rose Bush Nurseries in 

California. 

17. EPA-HQ-OPP-2005-0123-0324, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin and Metam-sodium In Onion Production. 

18. EPA-HQ-OPP-2005-0123-0325, Assessment of the Benefits of Soil Fumigation with Methyl 

Bromide, Chloropicrin and Metam-sodium In Grape Production. 

19. EPA-HQ-OPP-2005-0123-0326, Assessment of the Benefits of Soil Fumigation with Methyl 

Bromide, Chloropicrin and Metam-sodium In Tree Nut Production. 

20. EPA-HQ-OPP-2005-0123-0327, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, and Methyl Bromide In Pome Fruit Production. 

21. EPA-HQ-OPP-2005-0123-0328, Assessment of the Benefits of Soil Fumigation with Methyl 

Bromide, Chloropicrin, and Metam Sodium In Stone Fruit Production. 

22. EPA-HQ-OPP-2005-0123-0329, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam-Sodium in Bell Pepper Production. 

23. EPA-HQ-OPP-2005-0123-0330, Assessment of the Benefits of Soil Fumigation with Metamsodium in Potato Production. 

24. EPA-HQ-OPP-2005-0123-0331, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam-sodium In Strawberry Production. 

25. EPA-HQ-OPP-2005-0123-0332, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, Metam-sodium, and Dazomet In Strawberry Nursery Runner 

Production. 

26. EPA-HQ-OPP-2005-0123-0333, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide and Metam-sodium In Sweet Potato Production. 

27. EPA-HQ-OPP-2005-0123-0334, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin In Tobacco Production. 

28. EPA-HQ-OPP-2005-0123-0335, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam-sodium in Tomato Production. 

29. EPA-HQ-OPP-2005-0123-0336, Assessment of the Benefits of Soil Fumigation with Metam 

Sodium in Carrot Production. 

30. EPA-HQ-OPP-2005-0123-0337, Assessment of the Benefits of Soil Fumigation with Metam 

Sodium in Peanut Production. 

31. EPA-HQ-OPP-2005-0123-0338, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, Metam Sodium and Dazomet in Ornamental Production. 

32. EPA-HQ-OPP-2005-0123-0339, Summary of the Benefits of Soil Fumigation with Methyl 

Bromide in Crop Production. 

33. EPA-HQ-OPP-2005-0123-0340, BEAD’s Planned Impact Assessments on Agricultural Sites 

with Significant Use of Soil Fumigants. 

Risk Management 

34. SRRD’s Response to Phase 5 Public Comments for the Soil Fumigants. Rice, M. and 

McNally, R.; July 2008. 

35. EPA-HQ-OPP-2005-0128-0031, Risk Mitigation Options to Address Bystander and 

Occupational Exposures from Soil Fumigant Applications. 

36. Analysis of Soil Fumigant Risk Management Requirements using Geographic Information 

Systems: Case Studies based on a Forest Seedling Nursery (DP#363546). May 13, 2009. 
180 

37. Process for Defining High-Use Fumigation Areas at the State and County Levels 

(DP#364647) May 14, 2009. 

38. Methyl Bromide (PC Code 053201), Chloropicrin (PC Code 081501), Dazomet (PC Code 

035602), Metam Sodium and Potassium (PC Codes 039003 &039002), MITC (PC Code 

068103), DP Barcode 362369, Updated Health Effects Division Recommendations for Good 

Agricultural Practices and Associated Buffer Credits. May 14, 2009. 

Response to Comments 

39. HED Component of Response To Comments Document On Methyl Bromide Phase 5 

Fumigant Risk Assessment (DP Barcode 353907). 

40. Review of Stakeholder Submitted Impact Assessments of Proposed Fumigant Buffers, 

Comments on Initial Buffer Zone Proposal, and Case Studies of the Impact of a Flexible 

Buffer System for Managing By-Stander Risks of Fumigants (DP Barcode 353940). 

41. Response to Phase 5 BEAD Related Public Comments Received on the Reregistration of 

Chloropicrin, Dazomet, Metam Potassium, Metam Sodium, and Methyl Bromide. June 25, 

2008. (DP Barcode 353940). 

42. SRRD’s Response to Phase 5 Public Comments for the Soil Fumigants (July 2008). 

43. BEAD Response to Stakeholder Comments on Non-CUE Uses of Methyl Bromide and 

Methyl Bromide Rate Reductions (DP# 363545) (May 7, 2009). 

44. Methyl Bromide, 1,3-Dichloropropene, Chloropicrin, Dazomet, Metam Sodium/Potassium, 

MITC: Health Effects Division (HED) Component of Agency Response To Comments On 

2008 Reregistration Eligibility Documents (Date May 14, 2009). 

45. Response to Public Comments on the 7/9/08 Completed Methyl Bromide RED. (Rothman, 

G. and Felkel, J. March 3, 2009). 

46. Response to BEAD Related Public Comments Received on the Reregistration Eligibility 

Decision for Chloropicrin, Dazomet, Metam Potassium, Metam Sodium, and Methyl 

Bromide (DP# 363545) May 14, 2009. 

47. SRRD’s Response to Post-RED Comments for the Soil Fumigants (May 27, 2009).