United States Prevention, Pesticides EPA 738-R-09-308 

Environmental Protection and Toxic Substances May 2009 

 Agency (7508P) 

Amended Reregistration Eligibility 

Decision (RED) for Chloropicrin 

Glossary of Terms and Abbreviations

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 

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 

3 
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 

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 

PVC Polyvinyl Chloride 

QPS Quarantine and Preshipment 

RED Reregistration Eligibility Decision 

REI Restricted Entry Interval 

RQ Risk Quotient 

4 
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 

5 
Table of Contents 

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

I. Introduction........................................................................................................................... 13 

II. Chemical Overview .......................................................................................................... 17 

A. Chemical Identity.............................................................................................................. 17 

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

C. Regulatory History .............................................................................................................. 19 

III. Summary of Risk and Benefit Assessments and Links to Agency Documents...................... 20 

A. General Overview of Soil Fumigants.................................................................................. 20 

B. Human Health Risk from Chloropicrin............................................................................... 20 

C. Environmental Fate and Ecological Risks .......................................................................... 23 

D. Benefits ................................................................................................................................ 26 

 E. Impacts..................................................................................................28 

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

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

B. Public Comments and Responses ..................................................................................... 32 

C. Regulatory Position........................................................................................................... 34 

1. Regulatory Rationale .................................................................................................... 34 

a. Chloropicrin Pre-Plant Soil Uses.............................................................................. 34 

i. Human Health Risk Management......................................................................... 34 

1. Bystander Risk Mitigation ................................................................................ 35 

a. Buffer Zones ................................................................................................. 36 

i. General Buffer Zone Requirements............................................................ 36 

ii. Buffer Zone Reduction Credits.................................................................. 67 

 b. Restrictions for Difficult to Evacuate Sites..........................................74 

c. Posting.............................................................................................................. 75 

d. Use Prohibitions............................................................................................... 78 

2. Occupational Mitigation ................................................................................... 78 

a. Handler Definition ........................................................................................ 78 

b. Handler Requirements .................................................................................. 79 

c. Respiratory Protection .................................................................................. 80 

i. Respiratory Requirements........................................................................... 83 

d. Tarp Perforation and Removal...................................................................... 89 

e. Entry Restricted Period................................................................................. 92 

ii. Other Mitigation.................................................................................................... 97 

1. Good Agricultural Practices (GAPs) ................................................................ 97 

2. Fumigant Management Plans (FMPs) ............................................................ 106 

3. Site Specific Management and Response ....................................................... 113 

a. First Responder Education.......................................................................... 114 

b. Emergency Preparedness and Response ..................................................... 114 

4. Notice to State Lead Agencies........................................................................ 120 

5. Soil Fumigation Training for Applicators and Other Handlers ...................... 121 

a. Training for Applicators Supervising Fumigations .................................... 123 

b. Training Materials for Handlers.................................................................. 125 

6. Community Outreach and Education Programs ............................................. 126 

6 
iii. Environmental Risk Mitigation....................................................................... 131 

b. Residential Structure Warning Agent Use Mitigation............................................ 133 

i. Occupational Risk Mitigation............................................................................. 133 

1. Respiratory Requirements............................................................................... 133 

c. Chloropicrin Antimicrobial Use Mitigation............................................................ 133 

i. Bystander Risk Mitigation .................................................................................. 134 

ii. Occupational Risk Mitigation............................................................................. 134 

1. Air Concentration............................................................................................ 134 

2. Respiratory Requirements............................................................................... 134 

2. Endocrine Disruptor Effects ....................................................................................... 135 

3. Endangered Species Considerations ........................................................................... 135 

D. Conclusions..................................................................................................................... 135 

V. What Registrants Need to Do..........................................................................136 

A. Manufacturing Use Products............................................................................................. 137 

1. Additional Generic Data Requirements......................................................................... 137 

a. Data Requirements for Chloropicrin Soil Uses........................................................... 137 

i. Human Health........................................................................................................ 137 

1. Toxicity.............................................................................................................. 137 

2. Residue Chemistry............................................................................................. 137 

3. Occupational and Residential Exposure ............................................................ 137 

ii. Environmental Fate and Ecological Effects .......................................................... 138 

1. Environmental Fate............................................................................................ 138 

2. Ecological Effects .............................................................................................. 138 

iii. Other ..................................................................................................................... 140 

b. Chloropicrin Warning Agent Uses.............................................................................. 142 

c. Antimicrobial Uses...................................................................................................... 142 

2. Labeling for Manufacturing-Use Products .................................................................... 142 

B. End-Use Products............................................................................................................. 142 

1. Additional Product-Specific Data Requirements.......................................................... 142 

2. Labeling for End-Use Products..................................................................................... 143 

Appendix A................................................................................................................................. 174 

Appendix B ................................................................................................................................. 178 

Appendix C. ................................................................................................................................ 179 

Appendix D................................................................................................................................. 182 

Appendix E ................................................................................................................................. 185 

7 
Chloropicrin Reregistration Eligibility Decision Team

Office of Pesticide Programs: 

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 

William Phillips, II, Ph.D., Agronomist 

Tara Chandgoyal, Ph.D., Plant Pathologist 

Jin Kim, Ph.D., Economist 

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 

Health Effects Risk Assessment

Elissa Reaves, Ph.D., Toxicologist/Risk Assessor 

Charles Smith, Environmental Scientist/Risk Assessor 

Yvonne Barnes, Chemist 

Ruth Allen, MPH, Epidemiologist 

Monica Hawkins, MPH, Environmental Health Scientist 

Antimicrobial Risk Assessment Team

Heather Garvie, Chemical Review Manager 

Diane Isbell, Reregistration Team Leader 

Timothy Leighton, Environmental Scientist 

Cassi Walls, Ph.D., Chemist 

Timothy Dole, Industrial Hygienist 

8 
Chloropicrin Reregistration Eligibility Decision Team, cont. 

Registration Support

Mary Waller, Product Manager 

Tamue Gibson, Product Manager 

Kathy Monk, Senior Advisor 

Risk Management

Andrea Carone, Chemical Review Manager 

Steven Weiss, Industrial Hygienist, Chemical Review Manager 

Susan Bartow, Chemical Review Manager 

Dirk Helder, Chemical Review Manager 

Karen Santora, Chemical Review Manager 

Dana Friedman, Chemical Review Manager 

Cathryn O’Connell, Team Leader 

Eric Olson, Team Leader 

John Leahy, Senior Advisor 

Office of General Council: 

Andrea Medici 

Office of Enforcement and Compliance: 

David Stangel 

9 
Abstract 

 This document presents the U.S. Environmental Protection Agency’s (hereafter EPA or 

the Agency) amended decision regarding the reregistration eligibility of the registered uses of the 

active ingredient chloropicrin (trichloronitromethane). 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 chloropicrin have not changed. In 

addition, all measures established in the July 2008 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 

chloropicrin are eligible for reregistration provided that: (1) current data gaps are addressed; (2) 

the risk mitigation measures identified in this document are adopted; and (3) labels are amended 

to implement these measures. 

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

risks and developed risk management decisions for four other soil fumigants: dazomet, methyl 

bromide, metam sodium/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 Reregistration Eligibility Document (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. 

Chloropicrin acts as a nonselective soil fumigant with fungicidal, herbicidal, insecticidal, 

and nematicidal properties. The supported uses of chloropicrin include: (1) pre-plant soil 

fumigations (e.g., agricultural and commercial greenhouse); (2) empty grain bins and empty 

potato storage house/cellar fumigations; (3) residential uses (warning agent for sulfuryl fluoride); 

and (4) other specialized fumigations (e.g., spot tree replant sites and remedial wood treatments). 

Of the supported uses, chloropicrin is mainly used as an agricultural pre-plant soil fumigant. The 

Agency did not develop mitigation for the empty grain bin and empty potato storage/house cellar 

fumigations because the Agency received requests to voluntarily cancel these uses. A Federal 

Register notice was published on August 20, 2008 announcing the Agency’s receipt of these 

voluntary requests. EPA did not receive any comments on this notice and these uses must be 

deleted from the labels when revised labels are submitted to the Agency in 2009. 

Due to chloropicrin’s volatility there is no reasonable expectation that finite residues will 

be incurred in/on any raw agricultural commodity when these products are applied according to 

label directions. Therefore, this fumigant does not require food tolerances and there is no 

expectation of risk from dietary exposure. 

 The Agency has identified potential human health risks associated with the above 

supported uses of chloropicrin. Due to chloropicrin’s potential to move off-site, EPA is 

concerned with inhalation exposure to handlers, bystanders, and workers. To reduce inhalation 

10 
exposures and to address associated risks of concern for pre-plant soil fumigations, EPA is 

requiring a number of mitigation measures such as: 

• buffer zones, 

• buffer zone posting, 

• respiratory protections, 

• restrictions on the timing of tarp perforation and removal operations, 

• entry restrictions, 

• mandatory good agricultural practices (GAPs), 

• fumigant management plans (FMPs), 

• emergency preparedness and response, 

• notice to state-lead agencies, 

• training, and 

• community outreach and education programs. 

To address bystander and occupational risks for remedial wood treatments, the Agency is 

requiring a number of label statements and respiratory protection. 

 The Agency also has concerns regarding ecological and environmental risk when 

chloropicrin is used as a pre-plant soil fumigant. The Agency believes that many of the 

mitigation measures required above to address human health risk (e.g., buffer zones, timing of 

tarp perforation and removal, GAPs), will indirectly address ecological risk. The Agency is also 

requiring label statements to mitigate chloropicrin’s potential to leach into ground and/or surface 

water. 

Some chloropicrin end-use products are packaged as 100% chloropicrin, while other 

products contain mixtures of chloropicrin with methyl bromide, 1,3-D, and iodomethane. In 

these combination products the percent active ingredient for chloropicrin ranges from 20-67% 

when combined with methyl bromide, 15-60% when combined with 1,3-D, and 2-75% when 

combined with iodomethane. In addition, chloropicrin is used solely as a warning agent to 

indicate possible hazardous concentrations of methyl bromide1

 (chloropicrin is formulated at 2% 

or less by weight for pre-plant soil fumigations) and sulfuryl fluoride (chloropicrin is introduced 

into residential structures prior to the sulfuryl fluoride fumigation). 

Separate RED documents have been completed for methyl bromide (July 2008, and an 

amendment will be published concurrently with chloropicrin), sulfuryl fluoride (1993), and 1,3-

D (1998). Iodomethane was granted a one year time-limited registration in October 2007 while 

chloropicrin, methyl bromide, metam sodium/potassium, and dazomet were going through 

reregistration. In April 2009, EPA extended the registration of iodomethane maintaining 

appropriate provisions governing its use and maintaining the conditional registration with the 

same conditions but removing the time limitation on the registration. The conditions of 

registration were to ensure that the iodomethane registrant makes all changes to the iodomethane 

labels that are appropriate to ensure that all the fumigants are regulated in a consistent manner. 

 

1

 Current labels reflect use of chloropicrin as a warning agent for methyl bromide during structural fumigations. 

The use of methyl bromide for structural fumigations is not eligible for reregistration. As a result, the warning agent 

use for chloropicrin formulations with methyl bromide for structural fumigations was not evaluated. 

11 
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. 

12 
I. Introduction 

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

Chloropicrin,” published by the U.S. Environmental Protection Agency 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 FIFRA. 

EPA received requests to extend the comment period from the Methyl Bromide Industry Panel 

(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 chloropicrin at www.regulations.gov, docket EPA-HQ-OPP-2007-0350. 

EPA has determined that the modifications described herein will achieve the same protection 

goals for persons potentially exposed to chloropicrin but with a greater likelihood of compliance, 

fewer impacts on the benefits of chloropicrin use, and with less uncertainty regarding the 

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

Table 1. Modifications from 2008 to 2009 Amended Chloropicrin RED 

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 

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 

Monitoring with devices before 

reentry 

Monitor for sensory irritation before 

reentry 

Restrictions around 

difficult to evacuate 

1⁄4 mile restriction around hard to 

evacuate areas including daycare 

Maintain 1⁄4 mile restriction but allow a 

reduced restricted area of 1⁄8 mile for 

13 
Mitigation 2008 REDs 2009 Amended REDs 

sites centers, nursing homes, and schools; 

was to be in effect for the duration of 

the buffer zone period 

applications with smaller buffers (300 feet 

or less); is to be in effect during the 

application and for 36 hours following 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 where 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 chloropicrin’s sensory irritation 

properties to trigger additional measures 

Monitoring with devices is still required to 

remove respirators 

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 

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 

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 chloropicrin in lieu 

of devices 

14 
Mitigation 2008 REDs 2009 Amended REDs 

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 & 

education programs along with 

information for first responder in 

high fumigant use 

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 

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. The table 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 ○ ●

15 
Risk Mitigation Measure Currently 2010 2011 

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 

The Federal Insecticide, Fungicide, and Rodenticide Act (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 a review of all submitted data by the EPA. 

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 amended reregistration eligibility decision for the 

supported soil (agricultural, greenhouse, and tree replant), warning agent, and antimicrobial 

wood preservative uses of chloropicrin. The document consists of five sections. Section I 

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

July 2008 RED. Section II provides chloropicrin’s use and usage profile. Section III provides a 

general fumigant overview and also summarizes chloropicrin’s human health and ecological risk 

assessments, as well as benefit and impact assessments. Section IV presents the Agency’s 

amended reregistration eligibility and risk management decisions. Section V summarizes label 

changes necessary to implement the risk mitigation measures outlined in Section IV. The 

revised risk assessment documents and related addenda are not included in this document, but 

are available in the chloropicrin docket EPA-HQ-OPP-2007-0350 at 

https://www.regulations.gov. Unless otherwise noted, all Agency documents are available for 

review in the chloropicrin docket. Documents published during Phases 1-4 are available at 

https://www.regulations.gov, docket number EPA-HQ-OPP-2006-0661. 

16 
II. Chemical Overview 

A. Chemical Identity 

Chemical Structure: 

Cl N

Cl

Cl

O

O

Empirical Formula: CCl3NO2

Common Name: Chloropicrin 

CAS Registry Number: 76-06-2 

OPP Chemical Code: 081501 

Case Number: 0040 

Technical Registrants: Niklor Chemical Company, Inc., Arysta Life Sciences North 

America Corporation, ASHTA Chemicals, Inc., and Trinity 

Manufacturing, Inc. All 4 companies are part of the Chloropicrin 

Manufacturers’ Task Force (CMTF). 

B. Use and Usage Profile: 

Pesticide Type: Chloropicrin is a broad spectrum fumigant with fungicidal, 

herbicidal, insecticidal, and nematicidal properties. Chloropicrin 

supported uses include: pre-plant soil fumigant use at agricultural 

sites, tree replant sites, and greenhouses; a warning agent use in 

residential structures before sulfuryl fluoride fumigations; and an 

antimicrobial remedial wood treatment use. Chloropicrin is 

currently labeled for use in empty grain bins and empty potato 

storage/house cellars, but these uses have been voluntarily 

cancelled and must be removed from labels. 

Target Pests: When used as a pre-plant soil fumigant in agricultural settings and 

in greenhouses, chloropicrin is used to control weeds, nematodes, 

insects, and various soil borne pathogens. 

 

In existing orchards chloropicrin is used to treat small areas to 

control weeds, nematodes, insects, and various soil borne 

pathogens.

17 
Chloropicrin is also used to control internal wood decay caused by 

fungi and insects in wood poles, timbers, pilings, and gluelaminated beams. 

Formulations: Chloropicrin can be formulated as a soluble concentrate/liquid, 

pressurized gas, pressurized liquid, emulsifiable concentrate, and a 

ready-to-use product. All chloropicrin 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: As a pre-plant soil fumigant chloropicrin is either injected (e.g., by 

shank) into the soil or applied via drip irrigation. These 

applications can either be tarped or untarped. 

Chloropicrin is used in existing orchards for tree replant purposes. 

Tree site applications take place in small treated areas (10’ x 10’) 

where chloropicrin is injected at least 18 inches into the soil using 

a replant wand. 

When used as a warning agent prior to sulfuryl fluoride residential 

structure fumigations, a tent must first be put up around the 

structure. Chloropicrin is then placed in the center of the structure 

in either a shallow pan or onto absorbent material. A fan is then 

placed to direct the air stream over the pan or absorbent material to 

accelerate the chloropicrin’s evaporation. Chloropicrin should be 

applied 5-10 minutes before sulfuryl fluoride is introduced into the 

structure. 

For remedial wood treatment, chloropicrin is either poured/injected 

or applied with encapsulated vials into pre-drilled holes. For 

utility pole treatment, holes are drilled at a 45 degree angle and 

chloropicrin is poured/injected or applied with encapsulated vials 

into all of the holes. After the chloropicrin has been applied, the 

holes are immediately plugged. 

Application Rates: For pre-plant soil fumigation use the following are the supported 

maximum application rates: 

o 350 lbs active ingredient (ai) per acre for tarped, shank 

injection applications; 

o 175 lbs ai per acre for untarped, shank injection 

applications; 

o 350 lb ai per acre for deep (at least 18 inches) untarped, 

shank injection applications; 

18 
o 300 lbs ai per acre for drip irrigation applications 

(including greenhouses); 

o 500 lbs ai per acre for tree hole replant applications, this is 

equivalent to 1 lb of chloropicrin per 100 square feet. 

When used as a warning agent prior to sulfuryl fluoride residential 

fumigations 1 fluid ounce ai of chloropicrin is used per 10,000-

15,000 cubic feet. 

Labels indicate that the amount of chloropicrin used for remedial 

wood treatment is based on the size of the pole. Pole applications 

range from 4 ounces ai up to 1 1⁄4 pints ai for larger poles. 

Annual U.S. Usage: According to 2007 Agency use information, about 10 million 

pounds of chloropicrin are used annually for pre-plant soil 

fumigations. This amount may differ from what has been 

presented in the Agency’s revised risk assessments since that data 

reflected usage data from 2002-2004. 

 C. Regulatory History 

• First registered in the U.S. in 1975. 

• A registration standard was issued in 1982. 

• Data Call-In’s (DCIs) issued in September 1990 and October 1995. 

• Reregistration Eligibility Decision (RED) for Chloropicrin, July 2008. 

19 
III. Summary of Risk and Benefit Assessments and Links to 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 the application (handlers), workers who re-enter fumigated fields 

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

 

B. Human Health Risk from Chloropicrin 

 

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

uses of chloropicrin is from acute inhalation exposure as a result of fumigant off-gassing. The 

term handler refers to persons involved in the application of chloropicrin. For soil applications, 

handlers also include persons involved in tarp perforation and removal. The term worker in this 

document refers to persons performing non-handler tasks (e.g., planting) within the application 

block, after the fumigation process has been completed. The term bystander refers to any person 

who lives or works in the vicinity of a fumigation site. 

In addition to the soil uses of chloropicrin, there are other uses that the Agency has 

assessed and included in the July 2008 RED. Chloropicrin’s use as a warning agent was also 

evaluated in the Agency’s revised human health risk assessment. Chloropicrin is also used as an 

antimicrobial to control internal wood decay in wood poles, timbers, pilings, and glue-laminated 

beams. These uses were assessed in a different document than the pre-plant soil and warning 

agent uses. 

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 

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 emission rate from treated fields. 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. 

Chloropicrin can cause eye, nose, throat, and upper respiratory irritation. Results from a 

chloropicrin human sensory irritation study indicate that eye irritation is the most sensitive effect. 

20 
The Agency selected a reversible acute endpoint from the human study. EPA used this study to 

determine a bench mark concentration level (BMCL10) of 0.073 parts per million (ppm). At this 

level EPA does not expect eye or nose irritation, or upper respiratory changes. Most of the study 

participants detected chloropicrin within 20-30 minutes at 0.15 ppm. This level corresponds to 

mild irritation without leading to more severe irritation and respiratory effects. In addition, the 

human study shows that persons exposed to 0.15 ppm of chloropicrin did not experience 

irritation effects 1 hour after the exposure ended, and also no irritation effects were seen the 

following day. 

 Based on the human study, a margin of exposure (MOE) of 1 defines the Agency’s level 

of concern (LOC) for acute inhalation exposure. The uncertainty factors have been removed due 

to a) chloropicrin's mode of action (MOA) of sensory irritation,2 and b) evaluation of the most 

sensitive human subpopulation to sensory irritants (young adults, average age 23).3

The Agency has high quality data that shows at 0.15 ppm (which corresponds to an MOE 

of 0.50) humans begin to sense chloropicrin without leading to more serious effects. While there 

are uncertainties about the effects of chloropicrin at higher concentrations and at exposure 

durations longer than 1 hour, data do suggest that effects would not become more severe unless 

the concentration of chloropicrin increases. Therefore, the Agency is confident that the human 

study provides high quality information regarding the dose-response in humans at the levels that 

lead to minor, reversible effects. 

In assessing risks from chloropicrin, 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 chloropicrin 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 chloropicrin 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 chloropicrin 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. 

 

• 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 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, then 

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

 

2

 For details on guidance documents and framework the Agency used to determine chloropicrin's see, EPA-HQOPP-2007-0350-0172. “MOA Mode of Action, Eye Irritation, and the Intra-Species Factor: Comparison of 

Chloropicrin and MITC.” June 25, 2008. (DP Barcode 293356) 

3

 For a more detailed explanation of the study see, “Chloropicrin: Third Revision of the HED Human Health Risk 

Assessment. April 30, 2009. (DP Barcode D348637).” 

21 
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. 

Bystander incidents have occurred both close to fumigated 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 chloropicrin 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 chloropicrin fumigations occur have the potential to exceed the Agency’s LOC without 

additional mitigation measures. There are also risks of concern for occupational handlers 

involved in chloropicrin applications and tarp perforation/removal activities, and for workers 

who may re-enter treated areas shortly after fumigation or tarp perforation has been completed. 

The Agency does not have risk concerns for bystanders when chloropicrin is used prior to 

sulfuryl fluoride residential structure fumigations. When chloropicrin is used to treat wood 

decay, the Agency has identified potential acute inhalation risks to bystanders and handlers. The 

Agency’s concern for acute inhalation exposure to bystanders and handlers is based on the same 

data described above. The Agency also does not have a risk concern for dietary exposure 

(including drinking water exposure). 

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

analyses, refer to the documents listed below: 

• Chloropicrin: Third Revision of the HED Human Health Risk Assessment. April 30, 

2009 (DP Barcode 348637). 

• 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. 

• EPA-HQ-OPP-2007-0350-0172, MOA Mode of Action, Eye Irritation, and the IntraSpecies Factor: Comparison of Chloropicrin and MITC. June 25, 2008. DP Barcode 

293356. 

22 
• EPA-HQ-OPP-2007-0350-0173, Factors Which Impact Soil Fumigant Emissions - 

Evaluation For Use In Soil Fumigant Buffer Zone Credit Factor Approach. June 9, 2008. 

(DP Barcode 306857) 

• EPA-HQ-OPP-2007-0350-0009, Review of Fumigants Group Incident Reports. 

• EPA-HQ-OPP-2007-0350-0010, Summary Fumigants Group Incident Reports. 

• EPA-HQ-OPP-2007-0350-0011, Summary Fumigants Group Incidents DP Barcode 

D326938. 

For more information on the antimicrobial use of chloropicrin please see the following 

documents: 

• EPA-HQ-OPP-2007-0350-0165, Revised Occupational and Residential/Bystander 

Assessment of the Antimicrobial Use (Remedial Wood Treatment) of Chloropicrin for 

the Reregistration Eligibility Decision (RED) Document (Phase 3 Comment Period). PC 

Code 081501, DP Barcode D314399. February 14, 2008. 

• EPA-HQ-OPP-2007-0350-0167, Updated Label Language for the Antimicrobial Uses of 

Chloropicrin (PC Code 081501) for the Reregistration Eligibility Decision Document. 

May 13, 2008. 

C. Environmental Fate and Ecological Risks 

The Agency’s environmental fate and ecological effects risk assessment indicates that 

there are some concerns for non-target organisms that may be exposed to fumigants. 

Since chloropicrin is highly volatile and is a gas at room temperature and standard 

pressure, inhalation is the major exposure pathway for non-target terrestrial animals. For aquatic 

organisms, exposure in surface water could result from runoff with dissolved chloropicrin from 

fumigated fields. 

The Agency evaluated the potential exposure of birds and mammals through inhalation 

exposure to chloropicrin using air monitoring data and values derived from exposure modeling. 

The Agency has not established LOCs for inhalation risk in animals; standard dietary LOCs were 

used. Comparison of modeled exposure concentrations to acute mammalian inhalation toxicity 

data did not exceed the endangered species LOC when exposure concentrations from PERFUM 

were used. Chronic exposure to chloropicrin from treatment of individual fields is not expected. 

The potential for inhalation risk to birds was not quantified, because avian inhalation 

toxicity data were not available. The potential risk to non-target terrestrial plants was also not 

evaluated due to lack of toxicity data. 

Exposure to aquatic animals and plants was simulated using the Pesticide Root Zone 

Model (PRZM) and Exposure Analysis Modeling System (EXAMS), although there is some 

uncertainty in their ability to fully account for the transport of chemicals as volatile as 

chloropicrin. Risk quotients exceeded the acute LOC for fish for two of six modeled scenarios 

(FL strawberry and FL tomato) and the endangered species LOC for all six scenarios modeled. 

The acute LOCs for aquatic invertebrates (endangered species and non-endangered species 

23 
LOCs) were exceeded for two of six scenarios (FL strawberry and FL tomato) although the lack 

of a definitive toxicity endpoint means that risk could not be completely discounted from the 

other four scenarios modeled. Chronic risk to aquatic animals was not evaluated due to lack of 

data, but volatilization of chloropicrin from surface water would greatly reduce residues of 

chloropicrin over time. 

1. Hazard 

Based on limited data, chloropicrin is considered very highly toxic to both fish (lowest 

LC50 = 5.14 ppb) and aquatic invertebrates (lowest LC50 < 71 ppb). Chloropicrin is also 

considered highly toxic to mammals. The acute mammal inhalation LD50 is 0.114 mg/L (male 

rats) and the developmental NOAEL in rabbits is 0.003 mg/L (LOAEL 0.008 mg/L, based on 

abortions and decreased fetal weights). The mammal acute oral LD50 value (used in a 

preliminary analysis) is 37.5 mg/kg (highly toxic). The Agency does not have avian inhalation, 

terrestrial/aquatic plant, or estuarine/marine aquatic life data. 

2. Exposure 

a. Environmental Fate 

The high vapor pressure (23.8 mm @ 25○

C), high Henry’s Law Constant (2.05 X 10-3

atm M3/mole), and low soil adsorption coefficient (Koc 36.05 L kg-1) of chloropicrin suggest that 

volatilization is the most important environmental route of dissipation. Direct photolytic 

degradation (t1/2 <8 hrs) of chloropicrin is the primary route of dissipation in the atmosphere, 

which suggest it is not a significant threat to deplete stratosphere ozone layer. Due to the fact 

that volatilization is significant and occurs rapidly, the importance of other competing processes 

such as leaching, biotic and abiotic degradation, and adsorption to the soil particles will certainly 

depend on chloropicrin’s emission rate from fumigated fields. This is because the emission rate 

determines the amount of chloropicrin left for other processes and its residence time in the soil 

system. However, if chloropicrin remains in soil, it also degrades with half-lives ranging from 

3.7 to 4.5 days with CO2 being the terminal breakdown product. Since chloropicrin is highly 

soluble in water and has low adsorption in soil, it can potentially leach into groundwater and to 

surface water through runoff under a flooded condition. The low octanol/water partition 

coefficient of chloropicrin also indicates that it is not likely to be bioconcentrated in tissues of 

aquatic organisms. 

 

b. Terrestrial Exposure 

The Industrial Source Complex Short Term Version 3 (ISCST3) model was used to 

calculate potential air concentrations to which terrestrial animals might be exposed via 

inhalation. Air concentrations at the field edge and at distances away from a 40-acre field edge 

were simulated, considering various application rates and methods, including if tarps were used. 

The highest air concentration of 0.019 mg/L was estimated. The values used for this assessment 

yield conservative air concentration estimates because considering a constant flux rate does not 

allow for diurnal/nocturnal changes that may occur, which when coupled with the appropriate 

wind speed and stability category, can result in lower concentrations. The meteorological inputs 

24 
also will provide a conservative estimate of exposure because the wind direction is considered to 

be perpendicular (pointed downwind) to the treated field for the entire 24 hours represented in 

the calculation. This is not a normal situation in the atmosphere for most locations. 

PERFUM was used to refine the potential risks to terrestrial organisms. Twelve different 

application scenarios (e.g., broadcast, bedded, tarped, untarped, drip irrigation, 

Bakersfield/Ventura sites, application rates up to 350 lb ai/A) were modeled. The highest 90th

percentile air residue across these scenarios is 0.004219 mg/ m3, for 40 acres, broadcast, 

untarped, 0 – 5 meters radius from the field edge, 8 – 12 hours after application at 175 lb ai/A. 

This value is significantly less than the greatest value simulated using the ISCST3 model. 

Available ambient monitoring data for chloropicrin indicates a maximum ambient air 

concentration of 0.000014 mg/L. Although it is possible that birds and mammals could be 

exposed to chloropicrin repeatedly by ranging between treated fields, the historical ambient air 

concentration was considered to determine the potential for chronic inhalation exposure. 

 c. Aquatic Exposure 

Aquatic exposure was simulated using the combined PRZM and EXAMS surface water 

models. Estimated environmental concentrations (EECs) resulting from application of 350 lb 

ai/A and 175 lb ai/A were simulated for six crop scenarios (CA tomatoes, CA onions, FL 

tomatoes, FL strawberries, NC sweet potatoes, and NC tobacco). The calculated EECs were on 

the order of 1.0 μg/L or less for the California and North Carolina scenarios, but were on the 

order of 70 μg/L for the Florida scenarios. 

There is an uncertainty in estimating chloropicrin exposure in water bodies due to postapplication tarping of the treated area. If tarping is used to minimize the volatilization of 

chloropicrin, the loading of the chemical through runoff will be limited until the tarp is 

perforated or removed from the field. The present version of the PRZM model and the selected 

crop scenarios have limited capabilities in capturing the load of applied chemical under a postapplication tarp scenario. Therefore, the estimated concentrations of chloropicrin in water bodies 

may be upper bound for tarped scenarios since the load of chloropicrin from runoff is considered 

in the PRZM/EXAMS simulation. 

Because chloropicrin is highly soluble in water and has low adsorption in soil, residual 

chloropicrin in soil can potentially leach into groundwater under continuous irrigation and/or 

high rainfall events. However, consideration of the potential for groundwater contamination 

must take into account the fact that irrigation is applied with the intent of keeping chloropicrin 

within a small depth range around the root zone (and not below to groundwater). In addition, 

degradation of chloropicrin under a tarped field, and limited dissipation of material though a tarp 

would reduce the amount of residues which might be transported to groundwater by a potential 

heavy rainfall soon after the tarp is removed. 

3. Risk 

a. Terrestrial Risk 

25 
A risk quotient derived from the maximum EEC from the ISCST3 model and acute 

mammalian toxicity data was 0.17. Although the Agency has not set LOCs for inhalation risk to 

terrestrial animals, this value exceeds the standard endangered species LOC used in ecological 

dietary risk assessments. The maximum EEC from the refined PERFUM model, however, 

results in a maximum RQ below the endangered species LOC. Comparison of ambient 

chloropicrin concentrations in air from historical monitoring data to chronic rabbit inhalation 

toxicity data resulted in a RQ below the standard chronic LOC of 1.0. 

Risk to birds from inhalation exposure to chloropicrin could not be assessed using the 

ISCST3 or PERFUM exposure estimates because avian inhalation toxicity data were not 

available. The potential for risk to non-target terrestrial plants was also not evaluated due to lack 

of toxicity data. 

b. Aquatic Risk 

Risk quotients exceeded the acute LOC for fish for two of six modeled scenarios (FL 

strawberry and FL tomato), and the endangered species LOC for all six scenarios. The acute 

LOCs for aquatic invertebrates (endangered species and non-endangered species) were exceeded 

for two of six scenarios (FL strawberry and FL tomato), although the lack of a definitive toxicity 

endpoint means that risk could not be completely discounted from the other four scenarios 

modeled. Chronic risk to aquatic animals was not evaluated due to a lack of data, but 

volatilization of chloropicrin from surface water would greatly reduce residues of chloropicrin 

over time. 

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

environmental fate and ecological risks, refer to the following document: 

• EPA-HQ-OPP-2007-0350-0175, Revised Screening Ecological Risk Assessment for the 

Reregistration of Chloropicrin. DP Barcode 348669. April 16, 2008. 

D. 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 domestically yearround 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. 

Since chloropicrin is often used in combination with other fumigants, it is difficult to 

estimate an exact benefit for chloropicrin alone. Agency assessments (e.g., chloropicrin’s use in 

26 
pepper production) indicate that if chloropicrin were no longer available, growers could 

experience large yield losses. These losses combined with increases in production costs that are 

higher than revenue could cause growers to stop pepper production. 

Other benefits of chloropicrin include its use as a methyl bromide alternative and 

chloropicrin’s role as a warning agent which makes people aware of potential exposures to other 

fumigants such as methyl bromide. 

 

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

estimate the value of fumigants to various industries. Below is a list of the specific benefit 

assessments that include chloropicrin. 

• EPA-HQ-OPP-2007-0350-0017, Summary of the Benefits of Soil Fumigation with 

Chloropicrin in Crop Production. 

• EPA-HQ-OPP-2007-0350-0018, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam Sodium in Cucurbit Production. 

• EPA-HQ-OPP-2007-0350-0019, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam Sodium in Eggplant Production 

• EPA-HQ-OPP-2007-0350-0020, Assessment of the Benefits Soil Fumigants (Methyl 

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

Nurseries. 

• EPA-HQ-OPP-2007-0350-0021, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin, Dazomet, and Metam Sodium for Use in Raspberry 

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

California. 

• EPA-HQ-OPP-2007-0350-0022, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin and Metam-sodium in Onion Production. 

• EPA-HQ-OPP-2007-0350-0023, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin, and Metam Sodium in Grape Production. 

• EPA-HQ-OPP-2007-0350-0024, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin and Metam Sodium in Tree Nut Production. 

• EPA-HQ-OPP-2007-0350-0025, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin and Metam Sodium in Pome Fruits Production. 

• EPA-HQ-OPP-2007-0350-0026, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin, and Metam Sodium in Stone Fruit Production. 

• EPA-HQ-OPP-2007-0350-0027, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam Sodium in Bell Pepper Production. 

• EPA-HQ-OPP-2007-0350-0028, Assessment of the Benefits of Soil Fumigation with 

Metam Sodium in Potato Production. 

• EPA-HQ-OPP-2007-0350-0029, Assessment of Soil Fumigation with Chloropicrin, 

Methyl Bromide and Metam-sodium in Strawberry Production. 

• EPA-HQ-OPP-2007-0350-0030, Assessment of the Benefits of Chloropicrin, Methyl 

Bromide, Metam-sodium and Dazomet Use In Strawberry Nursery Runner Production. 

• EPA-HQ-OPP-2007-0350-0031, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam-sodium on Sweet Potato Production. 

27 
• EPA-HQ-OPP-2007-0350-0032, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin in Tobacco Production. 

• EPA-HQ-OPP-2007-0350-0033, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam Sodium in Tomato Production. 

• EPA-HQ-OPP-2007-0350-0034, Assessment of the Benefits of Soil Fumigation with 

Metam-Sodium in Carrot Production. 

• EPA-HQ-OPP-2007-0350-0035, Assessment of the Benefits of Soil Fumigation with 

Metam Sodium in Peanut Production. 

• EPA-HQ-OPP-2007-0350-0036, Assessment of the Benefits of Soil Fumigation with 

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

• EPA-HQ-OPP-2007-0350-0037, BEAD's Planned Impact Assessments on Agricultural 

Sites with Significant Use of Soil Fumigants (Chloropicrin, Dazomet, Methyl Bromide, 

Metam Potassium, and Metam Sodium. 

 

E. 2008 RED Mitigation Impacts 

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. 

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; please see the 

28 
following Agency document for more details, “Analysis of Soil Fumigant Risk Management 

Requirements using Geographic Information Systems: Case Studies Based on a Forest Seedling 

Nursery (DP # 363546)” May 13, 2009. 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 chloropicrin 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 chloropicrin. 

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 duration was estimated to impose the highest direct costs. The 

Agency estimates that the cost of sampling tubes alone could range from $1000 to over $3000 

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 

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. 

29 
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 

chloropicrin and additional buffer zone credits have been provided. Although many aspects of 

the RED mitigation will appear on labels in 2010, the Agency will not require buffers until the 

2011 growing season. 

30 
IV. Risk Management and Reregistration Decision 

 A. Determination of Reregistration Eligibility 

 Section 4(g)(2)(A) of 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 chloropicrin. 

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

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

active ingredient chloropicrin. Dietary (food) risks were not quantitatively assessed because 

there are no food/feed uses of chloropicrin. In addition to the risk assessments, the Agency 

completed benefit assessments on crops with significant chloropicrin usage.4 

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

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

is the list of mitigation options 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, 

• Fumigant management plans (FMPs), 

• FMP certification, 

• Responsible parties, 

• Record keeping/reporting/tracking, 

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

chloropicrin, since it is already a RUP), 

• Notification and posting, 

• Good agricultural practices (GAPs), 

• Fumigant manuals, and 

• Stewardship programs. 

The July 2008 RED determined based on a review of the chloropicrin data and public 

comments on the Agency’s assessments for the active ingredient chloropicrin, that the Agency 

had sufficient information on the human health and ecological effects as well as the benefits of 

 

4

 EPA-HQ-OPP-2007-0350-0037, BEAD’s Planned Impact Assessments on Agricultural Site with Significant Use 

of Soil Fumigants 

5

 EPA-HQ-OPP-2007-0350-0003, Risk Mitigation Options to Address Bystander and Occupational Exposures from 

Soil Fumigant Applications 

31 
chloropicrin to make a decision as part of the reregistration process under FIFRA. The Agency 

determined that the supported uses of chloropicrin would 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. This remains the case for the amended RED 

document. 

 Based on its evaluation of chloropicrin, the Agency has determined that chloropicrin 

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 chloropicrin. If all changes outlined in this document are incorporated 

into the product labels, then current risks for chloropicrin 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, to 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. 

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

include a comprehensive endangered species assessment. Once that endangered species 

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

B. Public Comments and Responses 

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

documents commenced November 29, 2006 and ended on February 28, 2007. The Agency 

documents and comments can be found in the chloropicrin docket, EPA-HQ-OPP-2006-0661. 

The Agency’s responses to comments received are available in the new chloropicrin docket, 

EPA-HQ-OPP-2007-0350. Both dockets can be found at www.regulations.gov. 

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 were highlighted in the July 2008 RED. The following documents include the 

EPA’s responses to comments. These documents are located in the chloropicrin docket, EPAHQ-OPP-2007-0350. 

• EPA-HQ-OPP-2007-0350-0170, RESPONSE TO PUBLIC COMMENTS. The Health 

Effects Division’s Response to Comments on the Agency’s April 12, 2007 document, 

32 
Chloropicrin: Revised HED Human Health Risk Assessment for Phase 5 (Docket EPAHQ-OPP-2007-0350). June 18, 2008. DP Barcode 348676. 

• EPA-HQ-OPP-2007-0350-0174, Response to Phase 5 Public Comments on the Phase 4 

Chloropicrin Reregistration Risk Assessment. April 16, 2008. DP Barcode 348669. 

• EPA-HQ-OPP-2007-0350-0168, 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. June 25, 2008. DP Barcode 353940. 

• EPA-HQ-OPP-2007-0350-0169, 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. 

• EPA-HQ-OPP-2007-0350-1066, Phase 6 Response to Substantive Public Comments on 

Antimicrobials Division’s Occupational and Residential Assessments for the 

Reregistration Eligibility Decision (RED) Documents for the following chemicals: 

Methylisothiocyanate (MITC), Metam Sodium, Dazomet, and Chloropicrin. February, 

14, 2008. 

• EPA-HQ-OPP-2007-0350-1077, SRRD’s Response to Phase 5 Public Comments for the 

Soil Fumigants, July 2008. 

 The Agency opened a 60-day public comment period following the publication of the 

chloropicrin 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 July 2008 

chloropicrin RED which may be found in the chloropicrin docket: 

• Further Response to Public Comments on the 7/9/08 Completed Chloropicrin 

RED. (March 3, 2009) 

• Evaluation of “Probabilistic Modeling of Chloropicrin Exposure to Aquatic 

Nontarget Organisms” (March 3, 2009). 

• Response to Comments from Dow Agrochemicals Regarding EPA’s Review of the 

Chain-2D Model (March 3, 2009). 

• 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 (May 14, 

2009) 

• 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. 

• Analysis of Soil Fumigant Risk Management Requirements using Geographic 

Information Systems: Case Studies based on a Forest Seedling Nursery 

(DP#363546). May 13, 2009. 

33 
• 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 the supported uses of chloropicrin are eligible for 

reregistration provided the risk mitigation measures outlined in this document are adopted and 

label amendments are made to reflect these measures. 

a. Chloropicrin Pre-Plant Soil Uses 

As summarized in Section III, there are risks of concern to humans and the environment 

resulting from chloropicrin use. Understanding these risks, and also the benefits of chloropicrin 

(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: 

• exposure characteristics of bystander and other populations exposed to chloropicrin; 

• hazard characteristics of chloropicrin (the chloropicrin endpoint is based on a minor and 

reversible effect, eye irritation); 

• hazard characteristics of other fumigants that are combined with chloropicrin; 

• 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. 

Considering these factors, EPA has determined that the modifications to the measures 

outlined in the July 2008 RED, described herein, will achieve the same protection goals for 

persons potentially exposed to chloropicrin but with a greater likelihood of compliance, fewer 

impacts on the benefits of chloropicrin use, and with less uncertainty regarding the 

protectiveness of the required measures. The following is a summary of the rationale for 

managing risks associated with chloropicrin use. Where labeling revisions are warranted, 

specific language is set forth in the summary label table in Section V of this document. 

The following is a summary of the rationale for managing risks associated with the 

supported uses of chloropicrin. 

i. Human Health Risk Management 

The human health risk assessment indicates that inhalation exposures to bystanders, 

handlers, and workers who live and work near agricultural fields and greenhouses where 

chloropicrin fumigations occur have the potential to exceed the Agency’s level of concern 

without additional mitigation measures. To reduce the potential for chloropicrin exposure to 

34 
bystanders, handlers, and workers and to address associated risks of concern, EPA is requiring a 

number of mitigation measures which include: 

• buffer zones, 

• buffer zone posting, 

• respiratory protections, 

• restrictions on the timing of tarp perforation and removal operations, 

• entry restrictions, 

• mandatory good agricultural practices (GAPs), 

• fumigant management plans (FMPs), 

• emergency preparedness and response, 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 MOEs, others such as 

emergency preparedness and response and community outreach and 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. 

1. Bystander Risk Mitigation 

Bystanders are persons who live and/or work near fumigated fields and could be 

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 non35 
occupational bystander exposure is similar to dietary exposure in that people consuming foods or 

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 of emergency 

preparedness and response, notice to state lead agencies, training, and community outreach and 

education as well as labeling changes. 

a. Buffer Zones 

The human health risk assessments indicate bystanders may be exposed to chloropicrin 

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 

chloropicrin 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. 

i. General Buffer Zone Requirements 

General Requirements in the July 2008 RED 

The 2008 chloropicrin RED described general buffer zone requirements for chloropicrin 

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 1⁄4 mile of difficult to evacuate sites such as schools, state licensed daycare 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 

36 
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 commenters 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 commenters 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 commenters 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 chloropicrin, 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 

37 
and growers. However, field flux studies, monitoring data, modeling analyses, and information 

from incidents involving fumigants continue to support a conclusion that chloropicrin 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 chloropicrin. 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 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. 

Buffer Zone Proximity - Exception to Allow Buffer Zone Overlap

38 
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 from the start of the application until 48 hours after the application is 

complete, 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. 

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, 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 

39 
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 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. 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 these sites if concentrations were of concern. 

Therefore, monitoring of buildings and outdoor areas after termination of the buffer zone is not 

necessary and will no longer be required. 

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. 

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 

40 
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. 

Buffer zone distances - Requirements in the July 2008 RED

Based on several factors including the severity and reversibility of the effect and also the 

quality of the hazard database, the goal of the buffer zone distances in the July 2008 RED was to 

reach an air concentration of 0.073 ppm which equates to an MOE of 1. In the July 2008 RED if 

the target MOE was not reached, at minimum half of the target (MOE 0.5), which corresponds to 

minor, reversible effects, was achieved at high percentiles of the PERFUM model Version 2.1.4. 

PERFUM is one of the resources EPA used to help inform decisions regarding buffer zone 

distances. 

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 

hazard profile of chloropicrin, 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 Model6

). 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. 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 July 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 pre-plant soil emission profiles for the July 2008 RED, distances were determined for 

the maximum supported rates as well as increments less than the maximum rate with application 

 

6 http://www.epa.gov/scram001/dispersion_alt.htm#isc3

41 
block sizes of 1, 5, 10, 20, 30, 40, 50, 60, 80, 100, and 120 acres. 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 July 2008 RED buffer zone distances are characterized as 

follows: 

• Buffer zone distances are based on a reversible endpoint. 

• The buffer zone distances selected for agricultural field and greenhouse pre-plant soil 

fumigations generally reach the target MOE of 1 at high percentiles (>90%). 

• Buffers are protective of more severe effects. The MOEs at high percentiles (99th) of the 

whole field reach half of the target MOE. This MOE corresponds to the 0.15 ppm 

concentration of chloropicrin that can cause irritation without leading to more serious 

respiratory effects. 

• It was assumed that chloropicrin air concentrations inside homes and other occupied 

structures are equal to outside concentrations. These structures could act as a barrier 

which in some cases may 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 (see GAP and FMP sections). 

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 chloropicrin is used, buffers greater than 1⁄2 mile are not practical 

and difficult to enforce. These requirements have not changed since the July 2008 RED. 

“Greenhouse” Uses

In the July 2008 RED the Agency developed buffer zones for the different size structures 

(up to 50,000 ft2

) for greenhouse pre-plant soil fumigations. The Agency limited the maximum 

size of a greenhouse that can be fumigated to 50,000 ft2. In addition the 2008 RED stated that all 

pre-plant greenhouse fumigations must be tarped. These requirements have not changed since 

the July 2008 RED. 

The "greenhouse" industry sector is extremely varied because of the breadth 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 buffer zone distances for 

“greenhouses.” In common "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 

42 
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 

chloropicrin 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 lookup tables. 

The Agency has not changed the buffer zones for the “greenhouse” use since the July 2008 RED. 

The appropriate buffer zone table for this use is Table 17. 

Distances for Combination Products 

As mentioned previously, products containing chloropicrin often include other active 

ingredients, for example methyl bromide, 1,3-D, and iodomethane. Buffer distances have also 

been developed for these fumigants. In accordance with Agency policy, when a pesticide 

product contains more than one active ingredient, the product shall bear labeling for the active 

ingredient with the more restrictive measures. When chloropicrin is formulated with methyl 

bromide, the buffers generally are based on the fumigant with the greater amount of active 

ingredient in the product; for example for products with 67% methyl bromide and 33% 

chloropicrin, the buffer zone is driven by the amount of methyl bromide. 

The July 2008 RED also provided detailed descriptions of the PERFUM model inputs 

and outputs. Most of these descriptions have not changed and are included in this Amended 

RED in Appendix D. As detailed below in the New Emission (Flux) Study section, the Agency 

received several new emission studies for the pre-plant soil uses. This information will be 

discussed in detail in the section below and not included in Appendix D. One additional change 

is that PERFUM outputs were calculated for up to 80 acres. In the July 2008 RED the outputs 

were calculated for up to 120 acres. 

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. 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 all of the agricultural field use 

scenarios. EPA believes this will help to better refine the buffer distances for these use 

scenarios, 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 in the revised buffer zone tables. 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. 

43 
New Flux (Emissions) Studies

The Agency’s Phase 5 risk assessment “Chloropicrin: Revised HED Human Health Risk 

Assessment for Phase 5; DP Barcode: D305336, PC Code 081501” (April 12, 2007) modeled the 

following emission studies in Table 3 for chloropicrin’s pre-plant agricultural field soil use. 

Table 3. Emission Studies Modeled in Phase 5 

MRID Location Application Method Weather Data Modeled 

Shank, bed, untarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL* 

Shank, bed, tarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

Shank, broadcast, untarp • Ventura, CA* 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

Phoenix, AZ* 

Shank, broadcast, tarp • Ventura, CA* 

• Bakersfield, CA 

• Flint, MI 

Yakima, WA Shank, broadcast, tarp • Yakima, WA 

• Flint, MI 

441492-01 

Bradenton, FL Shank, broadcast, tarp • Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

Salinas, CA* Drip irrigation, bed, ploy tarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA* 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

451129-01 

Salinas, CA Drip irrigation, bed, VIF tarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

451129-02 Douglas, GA Drip irrigation, bed, tarp • Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

44 
The asterisks (*) in Table 3 represent the emission studies and weather data that were 

used in the July 2008 RED to frame the buffer zone distances. At the time of the 2008 RED the 

emissions studies used were those that provided high-end emission and buffer estimates based on 

the Agency’s risk assessment, which used all of the valid and available emissions studies for 

chloropicrin, as well as weather data that are representative of regions of the country where 

chloropicrin is commonly used. The model used five years of weather data (i.e., 1825 potential 

application days) for each location. 

 In the July 2008 RED the Agency did not use the Salinas, CA drip irrigation with the 

VIF tarp; the Phoenix, AZ shank bed tarp; the Yakima, WA shank broadcast tarp; or the 

Bradenton, FL shank broadcast tarp emission studies as baselines for the buffers zones for those 

application methods. Although the human health risk assessment shows that PERFUM outputs 

are the largest for the Salinas, CA study with the VIF tarp, the Salinas, CA poly tarp study was 

used as the baseline instead. This is because poly tarps are much more commonly used; also, the 

VIF study was conducted in 2000, and the Agency does not believe that the study reflects current 

high barrier film technology. The Agency also did not use the Phoenix, AZ shank bed tarp study 

in the July 2008 RED because of the late start time of the study. Based on comments from 

CMTF, EPA did not believe that nighttime applications were typical. The Agency did not want 

to restrict chloropicrin applications to the daylight hours, and as a result the Agency did not use 

the study as the baseline. Instead the Agency required that the buffer zones for the shank bed 

tarp application increase 25% if the applications were made between one hour before sunset and 

one hour after sunrise. EPA did not use the Yakima, WA or the Bradenton, FL shank broadcast 

tarp studies in the July 2008 RED because as noted above the Agency used the most conservative 

study as the baseline for the buffers and this was the Phoenix, AZ study. The Agency 

understands that emission studies vary regionally and that more regionally representative 

emissions data would reduce uncertainty in determining buffer zone distances for different areas. 

However for the July 2008 RED, EPA did not use a site-specific approach because of data gaps 

for many of the application methods, the variation among regions, and the complexity of 

implementing and enforcing site-specific buffer zones. Instead, EPA addressed regional 

differences with buffer credits. Also in the July 2008 RED the Agency determined buffer zones 

for a deep (at least 18 inches) untarp broadcast application method using surrogate data from the 

Phoenix, AZ broadcast untarp emission study. 

 

 During the post-RED comment period EPA received numerous comments on the flux 

studies used to determine the buffer zones in the July 2008 RED. Specifically commenters 

indicated that: the Phoenix, AZ flux studies should not be used as the baseline because those 

studies did not reflect the July 2008 RED GAPs; the use of the surrogate study for the deep (at 

least 18 inches) shank untarped broadcast application was inappropriate because of the difference 

in application depth; and buffers for combination chloropicrin and 1,3-D products should be 

based on flux studies for those products. Commenters also expressed confusion regarding the 

25% buffer zone increase for the shank bed tarp buffers. 

 Regarding the request that EPA should use product specific flux data to determine the 

buffer zones, the Agency is willing to review the studies and take them into consideration. 

45 
Since the July 2008 RED EPA has received and reviewed additional flux studies, please 

see the Agency’s document, “Chloropicrin: Third Revision of the HED Human Health Risk 

Assessment” (April 30, 2009) for detailed analysis. Table 4 lists all of the emission studies 

currently reviewed by the Agency. The bolded studies indicate the studies EPA has received 

and reviewed since the July 2008 RED. The asterisks indicate the emissions studies and weather 

data used as the baseline in the amended RED buffer zone tables. 

Table 4. Emission Studies Reviewed by EPA as of May 2009 

MRID Location Application Method Weather Data Modeled 

Shank, bed, untarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

Shank, bed, tarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

Shank, broadcast, untarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

Phoenix, AZ 

Shank, broadcast, tarp • Ventura, CA 

• Bakersfield, CA 

• Flint, MI 

Yakima, WA Shank, broadcast, tarp • Yakima, WA 

• Flint, MI 

441492-01 

Bradenton, FL Shank, broadcast, tarp • Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

Salinas, CA* Drip irrigation, bed, ploy tarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA* 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

451129-01 

Salinas, CA Drip irrigation, bed, VIF tarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

46 
MRID Location Application Method Weather Data Modeled 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

451129-02 Douglas, GA Drip irrigation, bed, tarp • Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

472952-03 Bainbridge, 

GA 

Shank, bed, Hytiblock tarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

472952-02 Dover, FL Shank, bed, Metallized 

tarp 

• Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

472952-04 Hart, MI Shank, bed, Blockade tarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

474560-01 Yuma, AZ Drip irrigation (buried 10 

inches), bed, tarp 

• Ventura, CA 

• Bakersfield, CA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

474560-01 Yuma, AZ Drip irrigation (buried 10 

inches), bed, untarp 

• Ventura, CA 

• Bakersfield, CA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL 

476793-01 Yuma, AZ* Drip irrigation (buried 6 

inches), bed, untarp 

• Ventura, CA 

• Bakersfield, CA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL* 

475769-01 Wasco, CA* Shank, broadcast, tarp • Ventura, CA 

• Bakersfield, CA 

47 
MRID Location Application Method Weather Data Modeled 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL* 

475769-01 Wasco, CA* Shank, strip, tarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL* 

475769-01 Wasco, CA* Shank, broadcast, untarp • Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL* 

475769-01 Wasco, CA* Shank, deep (18”) 

broadcast untarp 

• Ventura, CA 

• Bakersfield, CA 

• Yakima, WA 

• Flint, MI 

• Tallahassee, FL 

• Bradenton, FL* 

Taking the new data and stakeholder comments into consideration, EPA has revised the 

buffer zones that were presented in the July 2008 RED. The revised buffer zone tables are 

presented in Tables 5-16. The Agency believes the Wasco, CA studies are more representative 

of current shank application practices than the older Phoenix, AZ studies that were used as the 

baseline in the July 2008 RED because the new studies included the GAPs required by the July 

2008 RED. New buffer zone tables based on the Wasco, CA flux studies (Tables 5, 7, 8 and 9) 

for shank strip tarp, shank bed tarp7

, shank broadcast tarp, shank broadcast untarp, and shank 

deep (18”) broadcast untarp represent application blocks when soil moisture is measured at ≥

70% with an instrument (e.g., tensiometer) or if soil moisture is determined to be ≥ 75% using 

the USDA Feel and Appearance Method. Please see the GAP section for details on the USDA 

method. If the soil moisture is measured to be between 50-69% with a meter or falls into the 

USDA Feel and Appearance Method category of 50-75%, then the buffer zones are based on 

Tables 12, 14, 15 and 16, which represents a 3x increase from the Wasco, CA baseline. The 

Agency believes that the different tables are warranted based on the suite of emission studies 

available to the Agency that indicate a significant difference in emissions depending on the 

percent soil moisture. EPA considered increasing the GAP for soil moisture to 70% field 

capacity, but determined that larger buffers as provided in Tables 12, 14, 15, and 16 would 

adequately address risks resulting from the increased emissions associated with lower moisture. 

 

7

 For the shank bed tarp application the Agency believes the Wasco, CA shank strip tarp study is a reliable and 

appropriate surrogate because of the similarities in the application method. 

48 
Since the July 2008 RED, it has come to the Agency’s attention that the Phoenix, AZ 

shank bed tarp application did not start at 7 pm. Due to this error, and also the revision of the 

buffer zones based on the new emission study, the Agency is no longer requiring a 25% increase 

to the shank bed tarp buffers if applications are made between one hour before sunset and one 

hour after sunrise. 

 Although the Agency did not receive a new emission study for the shank bed untarp 

application method, EPA has included an additional buffer zone table for this scenario provided 

the soil moisture is measured to be ≥ 70% with an instrument or is determined to be ≥ 75% using 

the USDA Feel and Appearance Method. The revisions are based information from the Wasco, 

CA studies regarding the impact of soil moisture on emissions. Additional information presented 

to the Agency by Dr. Chad Hutchison of the University of Florida8

 indicates that the recent 

adoption of increased moisture and compaction of beds for potato production have allowed 

growers to increase the efficacy of chloropicrin. EPA believes that although an increase in 

efficacy does not directly correlate to emission reduction, that these practices do reduce 

chloropicrin emissions. The Agency believes that these important factors may not be reflected in 

the Phoenix, AZ emission study, and has developed the supplemental buffer table taking these 

factors into account. Since the Agency does not have an emission study specifically for the 

shank, bed, untarp application method, EPA is calling in this study as part of the DCI to confirm 

the buffer zones in Table 6. Buffer zone tables based on the Phoenix, AZ study are presented in 

Table 13. 

 Since the July 2008 RED EPA did receive an additional tarp drip irrigation study. 

However since the drip tape was buried 10 inches and the Agency understands that this is not a 

typical practice; this study was not used in the determination of the buffer zones for this 

application method. Therefore, the Agency is still using the Salinas, CA flux study with the poly 

tarp as the baseline for this scenario. Although EPA is still using the same study as the baseline, 

the buffers have increased slightly since the July 2008 RED. This is due to the percentage of 

organic matter in the soil. As detailed in the Agency’s May 14, 2009 updated factors memo, the 

Agency has determined that organic content of the soil has a significant impact on fumigant 

emissions and that the July 2008 RED credit for organic content can be refined to allow a credit 

at lower percentiles of organic matter. The July 2008 RED only gave a credit if organic matter 

was ≥ 3%. In the amended RED, credit is given if the organic matter is > 1%. Since the organic 

matter in the Salinas, CA study is greater than 1%, the buffer zone table had to be revised to 

ensure that this credit was not already taken into account in the baseline buffer table. The 

revised buffers are presented in Table 10. 

 In the July 2008 RED the Agency stated that it did not have adequate data to evaluate the 

drip buried untarp application method, and that this application method would be prohibited 

unless data were submitted that allowed EPA to develop appropriate mitigation. The Agency has 

since received and reviewed two untarp buried (6” and 10”) drip irrigation emission studies. The 

Agency used the buried 6” flux study as the baseline for the buffers for this application method, 

and this use is now eligible for reregistration with the mitigation specified for this scenario. 

Buffers for this application method are presented below in Table 11. 

 

8 www.regulations.gov, EPA-HQ-2007-0350-0155. 

49 
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, buffers for growers who use emissionreducing 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 

Buffer Zone Reduction Credits section. 

Chloropicrin agricultural field use buffer distances, amended as noted above, are 

specified in Tables 5-16 below. Distances in the buffer zone tables are listed in feet. Distances 

greater than 1⁄2 mile (2,640 feet) are listed in the buffer zone tables. However, no buffer zone, 

including a buffer zone that has been determined by applying credits, may exceed a distance of 1⁄2 

mile (2,640 feet). 

Like the July 2008 RED, 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 greenhouse buffer zone table (Table 17) remains unchanged from 

the July 2008 RED. 

The risks associated with the amended RED buffer zone distances are characterized as 

follows: 

• Buffer zone distances are based on a reversible endpoint. 

• The buffer zone distances selected for agricultural field and greenhouse pre-plant soil 

fumigations reach the target MOE of 1 at high percentiles (95%). 

• Buffers are protective of more severe effects. The MOEs at high percentiles (99th) of the 

whole field reach half of the target MOE. This MOE corresponds to the 0.15 ppm 

concentration of chloropicrin that can cause irritation without leading to more serious 

respiratory effects. 

• The use of GAPs, FMPs, and other mitigation measures required by this decision will 

contribute to an additional decrease in risk (see GAP and FMP sections). 

50 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

90 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25

95 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25

100 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25

105 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25

110 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 27 29

115 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 29 32

120 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 30 36

125 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 32 39

130 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 34 43

135 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 36 46

140 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 38 50

145 25 25 25 25 25 25 25 25 25 25 25 25 26 26 29 31 36 41 54 66

150 25 25 25 25 25 25 25 25 25 25 25 25 26 28 32 36 46 56 70 83

155 25 25 25 25 25 25 25 25 25 25 25 25 27 29 36 42 57 72 86 99

160 25 25 25 25 25 25 25 25 25 25 25 25 28 31 39 48 68 88 102 116

165 25 25 25 25 25 25 25 25 25 25 25 25 29 32 43 54 79 104 118 132

170 25 25 25 25 25 25 25 25 25 25 25 25 29 34 46 59 89 119 134 149

175 25 25 25 25 25 25 25 25 25 25 25 25 30 35 50 65 100 135 150 165

180 25 25 25 25 25 25 25 25 25 25 29 33 41 50 65 79 114 149 166 184

185 25 25 25 25 25 25 25 25 25 25 33 41 53 65 79 94 128 162 182 202

190 25 25 25 25 25 25 25 25 25 25 37 49 64 80 94 108 142 176 198 221

195 25 25 25 25 25 25 25 25 25 25 41 56 76 95 109 122 156 189 214 239

200 25 25 25 25 25 25 25 25 25 25 45 64 87 110 123 136 170 203 230 258

205 25 25 25 25 25 25 25 25 25 25 49 72 99 125 138 151 184 216 246 276

210 25 25 25 25 25 25 25 25 25 25 53 80 110 140 153 165 198 230 263 295

215 25 25 25 25 25 26 26 27 28 29 59 90 119 149 161 174 208 241 271 301

220 25 25 25 25 25 26 28 29 31 32 66 100 129 157 170 184 218 253 280 306

225 25 25 25 25 25 27 29 31 34 36 73 110 138 166 179 193 229 264 288 312

230 25 25 25 25 25 28 31 34 36 39 80 120 147 174 188 202 239 276 297 318

235 25 25 25 25 25 29 32 36 39 43 86 130 156 183 197 211 249 287 305 324

240 25 25 25 25 25 29 34 38 42 46 93 140 166 191 206 221 260 299 314 329

245 25 25 25 25 25 30 35 40 45 50 100 150 175 200 215 230 270 310 323 335

250 25 25 25 25 25 31 38 44 51 57 106 154 182 209 224 239 281 322 340 358

255 25 25 25 25 25 33 41 49 56 64 111 159 189 219 234 249 291 334 358 381

260 25 25 25 25 25 34 44 53 62 71 117 163 195 228 243 258 302 346 375 404

265 25 25 25 25 25 36 46 57 68 79 123 167 202 237 252 267 313 359 393 426

270 25 25 25 25 25 37 49 61 74 86 129 171 209 246 261 276 324 371 410 449

275 25 25 25 25 25 39 52 66 79 93 134 176 216 256 271 286 334 383 428 472

280 25 25 25 25 25 40 55 70 85 100 140 180 223 265 280 295 345 395 445 495

285 25 26 28 29 31 46 61 77 92 107 147 187 230 274 290 307 358 409 460 510

290 25 28 31 34 36 52 68 83 99 114 154 194 238 282 301 319 371 424 474 525

295 25 29 34 38 42 58 74 90 106 121 161 201 246 291 311 331 385 438 489 540

300 25 31 36 42 48 64 80 96 112 129 169 209 254 299 321 344 398 452 504 555

305 25 32 39 46 54 70 86 103 119 136 176 216 262 308 332 356 411 466 518 570

310 25 34 42 51 59 76 93 109 126 143 183 223 270 316 342 368 424 481 533 585

315 25 35 45 55 65 82 99 116 133 150 190 230 278 325 353 380 438 495 548 600

320 25 36 46 57 68 85 102 118 135 152 194 235 283 330 360 389 448 506 561 615

325 25 36 48 59 71 87 104 121 138 154 197 240 288 335 367 399 458 518 574 630

330 25 37 49 61 74 90 107 123 140 156 201 245 293 340 374 408 469 529 587 645

335 25 38 51 64 76 93 109 126 142 159 204 250 298 345 381 417 479 541 600 660

340 25 39 52 66 79 96 112 128 144 161 208 255 303 350 388 426 489 552 614 675

345 25 39 54 68 82 98 114 131 147 163 211 260 308 355 395 436 500 564 627 690

350 25 40 55 70 85 101 117 133 149 165 215 265 313 360 403 445 510 575 640 705

Application Block Size (Acres)

Broadcast Equivalent Application Rate (lbs ai/arce)

Table 5. Shank Bed Tarp/Strip Tarp Buffer Zones Based on Wasco, CA Flux Study 

51 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

15 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25

20 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 38 53 64 75

25 25 25 25 25 25 25 25 25 52 25 25 25 25 25 31 38 63 88 106 125

30 25 25 25 25 25 25 25 25 25 25 29 40 51 63 78 94 119 144 166 188

35 25 25 25 25 25 25 25 25 25 25 44 63 81 100 125 150 175 200 225 250

40 25 25 25 25 25 35 45 55 65 75 106 138 156 175 200 225 275 325 356 388

45 25 25 28 33 38 48 58 68 78 88 125 163 194 225 250 275 319 369 406 444

50 25 31 38 44 50 60 70 80 90 100 144 188 231 275 300 325 363 413 456 500

55 38 45 53 61 69 80 91 103 114 125 172 219 263 306 334 363 413 463 509 556

60 50 59 69 78 88 100 113 125 138 150 200 250 294 338 369 400 463 513 563 613

65 56 67 78 89 100 114 128 141 155 169 222 275 322 369 406 444 506 569 622 675

70 63 75 88 100 113 128 143 158 173 188 244 300 350 400 444 488 550 625 681 738

75 69 83 97 111 125 141 158 174 190 206 269 331 381 431 475 519 594 681 747 813

80 75 91 106 122 138 155 173 190 208 225 294 363 413 463 506 550 638 738 813 888

85 81 98 116 133 150 170 190 210 230 250 319 388 441 494 544 594 688 788 869 950

90 88 106 125 144 163 185 208 230 253 275 344 413 469 525 581 638 738 838 925 1013

95 88 113 138 163 188 210 233 255 278 300 381 463 525 588 650 713 813 938 1088 1238

100 94 119 144 169 194 218 241 265 289 313 397 481 550 619 684 750 850 969 1113 1256

105 100 125 150 175 200 225 250 275 300 325 413 500 575 650 719 788 888 1000 1138 1275

110 108 135 163 190 217 242 267 292 317 342 435 529 604 679 750 821 938 1063 1190 1317

115 117 146 175 204 233 258 283 308 333 358 458 558 633 708 781 854 988 1125 1242 1358

120 125 156 188 219 250 275 300 325 350 375 481 588 663 738 813 888 1038 1188 1294 1400

125 131 163 194 225 256 284 311 339 366 394 484 575 675 775 856 938 1075 1238 1331 1425

130 138 169 200 231 263 293 323 353 383 413 488 563 688 813 900 988 1113 1288 1369 1450

135 144 177 209 242 275 305 335 365 395 425 522 619 725 831 934 1038 1150 1338 1431 1525

140 150 184 219 253 288 318 348 378 408 438 556 675 763 850 969 1088 1188 1388 1494 1600

145 154 190 225 260 296 328 361 393 426 458 577 696 792 888 1002 1117 1250 1438 1565 1692

150 158 195 231 268 304 339 374 409 444 479 598 717 821 925 1035 1146 1313 1488 1635 1783

155 163 200 238 275 313 350 388 425 463 500 619 738 850 963 1069 1175 1375 1538 1706 1875

160 166 205 244 283 322 360 398 436 474 513 636 759 877 994 1097 1200 1406 1597 1773 1950

165 169 209 250 291 331 370 409 448 486 525 653 781 903 1025 1125 1225 1438 1656 1841 2025

170 172 214 256 298 341 380 419 459 498 538 670 803 930 1056 1153 1250 1469 1716 1908 2100

175 175 219 263 306 350 390 430 470 510 550 688 825 956 1088 1181 1275 1500 1775 1975 2175

Table 6. Shank Bed Untarp Based on Wasco, CA Flux Study 

Application Block Size (Acres)

B roadcast Equivalent A pplication R ate (lbs ai/arce)

52 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

70 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25

80 25 25 25 25 25 25 25 25 25 25 25 25 25 25 26 27 32 37 40 43

90 25 25 25 25 25 25 25 25 25 25 25 25 25 25 27 29 39 49 55 61

95 25 25 25 25 25 25 25 25 25 25 25 25 25 25 28 31 46 61 70 79

100 25 25 25 25 25 25 25 25 25 25 25 25 25 25 29 33 53 73 85 97

105 25 25 25 25 25 25 25 25 25 25 25 25 25 25 30 35 60 85 100 115

110 25 25 25 25 25 25 25 25 25 25 29 34 36 38 45 51 78 104 120 136

115 25 25 25 25 25 25 25 25 25 25 34 42 46 51 59 68 95 122 140 158

120 25 25 25 25 25 25 25 25 25 25 38 51 57 64 74 84 113 141 160 179

125 25 25 25 25 25 25 25 25 25 25 42 59 68 76 89 101 130 159 180 201

130 25 25 25 25 25 25 25 25 25 25 46 68 79 89 103 117 148 178 200 222

135 25 25 25 25 25 25 25 25 25 25 51 76 89 102 118 134 165 196 220 244

140 25 25 25 25 25 25 25 25 25 25 55 85 100 115 133 150 183 215 240 265

145 25 25 25 25 25 27 28 30 32 34 64 94 112 129 147 164 198 231 259 286

150 25 25 25 25 25 28 32 35 39 42 73 104 124 144 161 179 213 248 277 306

155 25 25 25 25 25 30 35 40 46 51 82 113 135 158 175 193 229 264 296 327

160 25 25 25 25 25 32 39 46 52 59 91 122 147 172 190 207 244 281 314 348

165 25 25 25 25 25 34 42 51 59 68 100 131 159 186 204 221 259 297 333 369

170 25 25 25 25 25 35 46 56 66 76 109 141 171 201 218 236 275 314 351 389

175 25 25 25 25 25 37 49 61 73 85 118 150 183 215 233 250 290 330 370 410

180 25 27 29 30 32 45 58 70 83 96 129 161 194 226 249 271 312 353 394 434

185 25 29 32 36 39 53 66 80 93 106 140 173 205 238 265 291 334 376 417 459

190 25 30 36 41 46 61 75 89 103 117 151 184 217 249 281 312 355 399 441 483

195 25 32 39 46 54 68 83 98 113 128 162 196 228 261 297 333 377 421 464 507

200 25 34 43 52 61 76 92 107 123 139 173 207 240 272 313 354 399 444 488 531

205 25 36 46 57 68 84 100 117 133 149 184 219 251 284 329 374 421 467 511 556

210 25 38 50 63 75 92 109 126 143 160 195 230 263 295 345 395 443 490 535 580

215 25 39 54 68 82 99 116 132 149 166 203 239 274 309 359 409 456 504 549 594

220 25 41 57 73 89 106 122 139 155 171 210 249 286 324 373 422 470 519 564 609

225 25 43 61 79 96 113 129 145 161 177 218 258 298 338 387 436 484 533 578 623

230 25 45 64 84 104 119 135 151 167 183 225 267 310 352 401 449 498 547 592 637

235 25 46 68 89 111 126 142 157 173 189 233 276 321 366 415 463 512 561 606 651

240 25 48 71 95 118 133 148 164 179 194 240 286 333 381 429 476 526 576 621 666

245 25 50 75 100 125 140 155 170 185 200 248 295 345 395 443 490 540 590 635 680

250 25 51 77 103 129 144 159 174 189 204 254 303 355 407 453 499 551 604 656 708

255 25 52 79 105 132 147 163 178 193 209 260 311 365 419 463 507 563 619 677 736

260 25 53 80 108 136 151 167 182 197 213 266 319 375 431 474 516 574 633 698 764

265 25 54 82 111 139 155 170 186 202 217 272 326 385 444 484 524 586 647 719 791

270 25 54 84 113 143 159 174 190 206 221 278 334 395 456 494 533 597 661 740 819

275 25 55 86 116 146 162 178 194 210 226 284 342 405 468 505 541 609 676 761 847

280 25 56 87.5 119 150 166 182 198 214 230 290 350 415 480 515 550 620 690 783 875

285 25 57 89 122 154 171 188 205 222 239 300 361 423 484 526 569 642 715 798 881

290 25 58 91.3 124 158 176 194 212 230 248 310 373 430 488 538 588 664 740 814 888

295 25 59 93.1 127 161 180 199 218 237 256 320 384 438 491 549 606 686 765 829 894

300 25 60 95 130 165 185 205 225 245 265 330 395 445 495 560 625 708 790 845 900

305 28 64 100 136 172 192 212 233 253 273 341 408 460 512 573 633 718 803 862 920

310 32 68 105 142 178 199 220 240 261 282 352 422 475 528 585 642 729 817 878 940

315 35 73 110 148 185 206 227 248 269 290 363 435 490 545 598 650 740 830 895 960

320 37 75 113 151 189 210 231 252 273 294 367 441 498 554 608 661 752 843 906 969

325 39 78 116 155 194 214 235 256 276 297 372 446 505 564 618 671 764 856 916 977

330 41 81 120 159 198 218 239 260 280 301 376 452 513 573 628 682 775 869 927 986

335 44 83 123 163 202 223 243 263 284 304 381 458 520 582 638 693 787 881 938 994

340 46 86 126 166 206 227 247 267 288 308 386 464 528 591 648 704 799 894 949 1003

345 48 89 129 170 211 231 251 271 291 311 390 469 535 601 658 714 811 907 959 1011

350 50 91 133 174 215 235 255 275 295 315 395 475 543 610 668 725 823 920 970 1020

Broadcast Equivalent Application Rate (lbs ai/arce)

Application Block Size (Acres)

Table 7. Shank Broadcast Tarp Buffer Zones Based on Wasco, CA Flux Study

53 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

30 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25

35 25 25 25 25 25 25 25 25 25 25 25 25 25 25 30 35 43 50 63 75

40 25 25 25 25 25 25 25 25 25 25 25 25 25 25 38 50 80 110 137.5 165

45 25 25 25 25 25 25 25 25 25 25 25 25 41 58 76 95 133 170 201 233

50 25 25 25 25 25 25 25 25 25 25 25 25 57.5 90 115 140 185 230 265 300

55 25 25 25 25 25 25 25 25 25 25 46 68 100 133 161 190 238 285 325 365

60 25 25 25 25 25 25 25 25 25 25 68 110 143 175 208 240 290 340 385 430

65 25 25 25 25 25 29 33 37 41 45 95 145 183 220 253 285 343 400 448 495

70 25 25 25 25 25 33 41 49 57 65 123 180 223 265 298 330 395 460 510 560

75 25 26 27 28 28 42.3 56 70 84 98 158 218 263 307 343 380 452 523 578 633

80 25 27 28 30 32 51.7 72 92 112 132 194 257 303 348 389 430 508 587 647 707

85 25 28 30 33 35 61 87 113 139 165 230 295 343 390 435 480 565 650 715 780

90 25 34 43 52 61 86.3 111 136 161 186 248 309 366 423 473 523 616 709 794 879

95 25 41 56 72 88 112 136 160 184 208 265 323 389 455 510 565 666 768 873 978

100 25 47 69 92 114 137 160 183 206 229 283 336 412 488 548 608 717 826 951 1076

105 25 54 83 111 140 162 184 206 228 250 300 350 435 520 585 650 768 885 1030 1175

110 25 56 88 119 150 173 196 218 241 264 325 386 473 559 628 696 817 938 1079 1220

115 25 59 93 126 160 184 207 231 254 278 350 422 510 598 670 742 867 991 1128 1265

120 25 61 98 134 170 194 219 243 268 292 375 458 548 637 713 788 916 1044 1177 1310

125 25 64 103 141 180 205 230 256 281 306 400 494 585 676 755 834 966 1097 1226 1355

130 25 66 108 149 190 216 242 268 294 320 425 530 623 715 798 880 1015 1150 1275 1400

135 25 71 118 164 210 238 265 293 320 348 450 553 651 750 833 915 1040 1165 1314 1463

140 25 76 128 179 230 259 288 317 346 375 475 575 680 785 868 950 1065 1180 1353 1525

145 25 78 130 183 235 268 301 334 367 400 500 600 706 811 903 994 1108 1223 1402 1581

150 25 79 133 186 240 277 314 351 388 425 525 625 731 838 938 1038 1151 1265 1451 1638

155 25 80 135 190 245 286 327 368 409 450 550 650 757 864 973 1081 1194 1308 1501 1694

160 25 81 138 194 250 295 340 385 430 475 575 675 783 890 1008 1125 1238 1350 1550 1750

165 25 85 146 206 267 310 353 397 440 483 595 707 817 927 1038 1150 1283 1417 1600 1783

170 25 90 154 219 283 325 367 408 450 492 615 738 851 963 1069 1175 1329 1483 1650 1817

175 25 94 163 231 300 340 380 420 460 500 635 770 885 1000 1100 1200 1375 1550 1700 1850

B roadcast Equivalent A pplication R ate (lbs ai/arce)

Application Block Size (Acres)

Table 8. Shank Broadcast Untarp Buffer Zones Based on Wasco, CA Flux Study 

54 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

30 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25

40 25 25 25 25 25 25 25 25 25 25 30 35 40 46 51 57 63 70 77 84

50 25 25 25 25 25 25 25 25 25 25 35 45 56 67 78 88 102 115 129 143

60 25 25 25 25 25 25 25 25 25 25 45 65 87 108 130 152 178 205 233 262

70 25 25 25 25 25 25 25 25 25 25 55 85 118 150 183 215 255 295 338 380

80 25 25 25 25 25 33 39 45 51 55 99 143 179 215 249 283 334 385 431 478

90 25 25 25 25 25 42 53 65 76 85 143 200 240 280 315 350 413 475 525 575

100 25 26 28 29 30 50 67 84 102 118 179 240 285 330 368 405 478 550 608 665

105 25 28 30 33 35 58 81 104 127 150 215 280 330 380 420 460 543 625 690 755

110 25 32 38 45 51 74 97 120 143 166 234 301 355 408 450 493 579 665 735 804

115 25 36 46 57 68 91 114 137 160 183 253 323 379 436 481 526 615 705 779 854

120 25 40 55 69 84 107 130 153 176 199 272 344 404 464 511 559 652 745 824 903

125 25 44 63 82 101 124 147 170 193 216 291 366 429 491 541 591 688 785 869 952

130 25 48 71 94 117 140 163 186 209 232 310 387 453 519 572 624 725 825 913 1001

135 25 52 79 106 134 157 180 203 226 249 329 409 478 547 602 657 761 865 958 1051

140 25 56 88 119 150 173 196 219 242 265 348 430 503 575 633 690 798 905 1003 1100

145 25 59 92 126 159 183 207 231 255 279 365 451 527 603 664 725 841 956 1061 1166

150 25 61 97 133 169 193 218 243 267 292 382 471 551 631 695 760 884 1008 1120 1231

155 25 63 101 140 178 203 229 255 280 306 399 492 575 659 727 795 927 1059 1178 1297

160 25 66 106 147 187 214 240 266 293 319 416 513 600 686 758 830 970 1111 1237 1363

165 25 68 111 154 196 224 251 278 306 333 433 534 624 714 790 865 1014 1162 1295 1429

170 25 70 115 161 206 234 262 290 318 346 450 554 648 742 821 900 1057 1214 1354 1494

175 25 73 120 168 215 244 273 302 331 360 468 575 673 770 853 935 1100 1265 1413 1560

180 25 75 126 176 226 257 287 317 347 377 491 605 704 803 886 969 1139 1309 1452 1594

185 25 78 131 185 238 269 300 332 363 394 515 635 735 836 920 1004 1179 1354 1491 1629

190 25 81 137 193 249 282 314 347 379 411 538 665 767 869 953 1038 1218 1398 1530 1663

195 25 84 143 202 261 294 328 361 395 429 562 695 798 901 987 1072 1257 1442 1570 1697

200 25 87 149 210 272 307 342 376 411 446 585 725 830 934 1020 1106 1296 1486 1609 1731

205 25 90 154 219 284 319 355 391 427 463 609 755 861 967 1054 1141 1336 1531 1648 1766

210 25 93 160 228 295 332 369 406 443 480 633 785 893 1000 1088 1175 1375 1575 1688 1800

215 32 101 170 238 307 345 383 420 458 496 650 805 913 1021 1111 1201 1409 1617 1721 1825

220 39 109 179 249 319 358 396 435 473 511 668 825 934 1043 1135 1228 1444 1659 1755 1850

225 46 118 189 260 331 371 410 449 488 527 686 845 955 1064 1159 1254 1478 1701 1788 1875

230 54 126 199 271 344 383 423 463 503 543 704 865 975 1086 1183 1281 1512 1744 1822 1900

235 61 134 208 282 356 396 437 477 518 559 722 885 996 1107 1207 1307 1546 1786 1855 1925

240 68 143 218 293 368 409 450 492 533 574 740 905 1017 1129 1231 1334 1581 1828 1889 1950

245 75 151 228 304 380 422 464 506 548 590 758 925 1038 1150 1255 1360 1615 1870 1923 1975

250 82 159 235 312 389 431 474 516 559 601 769 936 1057 1179 1283 1387 1641 1896 1962 2029

255 89 166 243 320 397 440 483 527 570 613 780 946 1077 1207 1311 1414 1668 1921 2002 2082

260 96 174 251 328 406 449 493 537 581 624 791 957 1096 1236 1339 1441 1694 1947 2041 2136

265 104 181 259 337 414 459 503 547 591 636 802 968 1116 1264 1366 1469 1721 1973 2081 2189

270 111 189 267 345 423 468 513 557 602 647 813 979 1136 1293 1394 1496 1747 1999 2121 2243

275 118 196 275 353 431 477 522 568 613 659 824 989 1155 1321 1422 1523 1774 2024 2160 2296

280 125 204 283 361 440 486 532 578 624 670 835 1000 1175 1350 1450 1550 1800 2050 2200 2350

285 129 208 287 366 446 493 541 588 635 683 853 1023 1201 1379 1479 1579 1836 2093 2243 2393

290 132 212 292 372 451 500 549 598 647 696 871 1046 1226 1407 1507 1607 1871 2136 2286 2436

295 136 216 296 377 457 507 558 608 658 709 889 1069 1252 1436 1536 1636 1907 2179 2329 2479

300 139 220 301 382 463 515 566 618 670 721 906 1091 1278 1464 1564 1664 1943 2221 2371 2521

305 143 224 306 387 469 522 575 628 681 734 924 1114 1304 1493 1593 1693 1979 2264 2414 2564

310 146 228 310 392 474 529 583 638 693 747 942 1137 1329 1521 1621 1721 2014 2307 2457 2607

315 150 233 315 398 480 536 592 648 704 760 960 1160 1355 1550 1650 1750 2050 2350 2500 2650

320 151 235 319 403 486 543 599 656 712 769 973 1177 1371 1566 1675 1784 2085 2385 2559 2734

325 153 238 323 408 493 550 607 663 720 777 986 1194 1388 1581 1700 1819 2119 2420 2619 2817

330 154 241 327 413 499 557 614 671 728 786 999 1211 1404 1597 1725 1853 2154 2455 2678 2901

335 156 243 331 418 506 563 621 679 737 794 1011 1229 1421 1613 1750 1887 2189 2490 2737 2984

340 157 246 335 423 512 570 628 687 745 803 1024 1246 1437 1629 1775 1921 2223 2525 2796 3068

345 159 249 339 429 519 577 636 694 753 811 1037 1263 1454 1644 1800 1956 2258 2560 2856 3151

350 160 251 343 434 525 584 643 702 761 820 1050 1280 1470 1660 1825 1990 2293 2595 2915 3235

Application Block Size (Acres)

Table 9. Shank Broadcast Deep (18 inches) Untarp Buffer Zones Based on Wasco, CA Flux Study Broadcast Equivalent Application Rate (lbs ai/arce)

55 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

120 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30

125 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 35 40

130 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 40 50

135 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 45 60

140 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 45 60

145 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 45 60

150 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 45 60

155 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 38 45 53 60

160 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 38 45 53 60

165 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 40 60 60 60

170 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 40 50 60 60 60

175 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 40 50 60 60 60

180 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 40 60 60 60 60

185 30 30 30 30 30 30 30 30 30 30 30 32 34 36 38 40 60 60 62 64

190 30 30 30 30 30 30 30 30 30 30 30 32 34 36 38 40 60 60 64 68

195 30 30 30 30 30 30 30 30 30 30 30 32 34 36 38 40 60 60 66 73

200 30 30 30 30 30 30 30 30 30 30 30 32 34 36 38 40 60 60 68 77

205 30 30 30 30 30 30 30 30 30 30 30 32 34 36 38 40 60 60 70 81

210 30 30 30 30 30 30 30 30 30 30 30 32 34 36 38 40 60 60 73 85

215 30 30 30 30 30 30 30 30 30 30 30 33 37 40 43 47 68 77 90 103

220 30 30 30 30 30 30 30 30 30 30 30 35 39 44 49 53 77 93 108 122

225 30 30 30 30 30 30 30 30 30 30 30 40 50 60 60 60 85 110 125 140

230 30 30 30 30 30 30 30 30 30 30 39 48 56 65 67 68 103 120 134 148

235 30 30 30 30 30 30 30 30 30 30 40 50 60 70 73 77 122 130 143 157

240 30 30 30 30 30 30 30 30 30 30 45 60 68 75 80 85 140 140 153 165

245 30 30 30 30 30 30 30 30 30 30 46 63 70 78 86 94 143 150 165 179

250 30 30 30 30 30 30 30 30 30 30 48 65 73 82 93 103 147 160 177 193

255 30 30 30 30 30 30 30 30 30 30 49 68 76 85 99 113 150 170 189 208

260 30 30 30 30 30 30 30 30 30 30 50 70 79 88 105 122 153 180 201 222

265 30 30 30 30 30 30 30 30 30 30 51 73 82 92 111 131 157 190 213 236

270 30 30 30 30 30 30 30 30 30 30 53 75 85 95 118 140 160 200 225 250

275 30 30 30 30 30 32 33 35 36 38 61 84 95 108 131 153 176 215 241 267

280 30 30 30 30 30 33 36 39 42 45 69 93 105 122 145 167 192 230 257 283

285 30 30 30 30 30 35 39 44 48 53 78 103 115 135 159 180 208 245 273 300

290 30 30 30 30 30 36 42 48 54 60 86 112 125 148 173 193 223 260 288 317

295 30 30 30 30 30 38 45 53 60 68 94 121 135 162 186 207 239 275 304 333

300 30 30 30 30 30 39 48 57 66 75 110 130 145 175 200 220 255 290 320 350

Table 10. Drip Tarp Buffer Zones Broadcast Equivalent Application Rate (lbs ai/a) 

Application Block Size (Acres)

 

56 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

90 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30

95 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 42 53 64 75

100 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 53 77 98 120

105 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 65 100 133 165

110 30 30 30 30 30 30 30 30 30 30 30 30 33 37 45 53 93 133 165 197

115 30 30 30 30 30 30 30 30 30 30 30 30 37 43 60 77 122 167 198 228

120 30 30 30 30 30 30 30 30 30 30 30 30 40 50 75 100 150 200 230 260

125 30 30 30 30 30 30 30 30 30 30 33 37 54 72 103 133 182 230 257 283

130 30 30 30 30 30 30 30 30 30 30 37 43 68 93 130 167 213 260 283 307

135 30 30 30 30 30 30 30 30 30 30 40 50 83 115 158 200 245 290 310 330

140 30 30 30 30 30 30 30 30 30 30 48 67 105 143 182 220 273 327 350 373

145 30 30 30 30 30 30 30 30 30 30 57 83 128 172 206 240 302 363 390 417

150 30 30 30 30 30 30 30 30 30 30 65 100 150 200 230 260 330 400 430 460

155 30 30 30 30 30 31 33 34 35 37 78 120 170 220 252 283 349 415 457 498

160 30 30 30 30 30 33 35 38 41 43 92 140 190 240 273 307 368 430 483 537

165 30 30 30 30 30 34 38 42 46 50 105 160 210 260 295 330 388 445 510 575

170 30 30 30 30 30 36 42 48 54 60 118 177 228 278 315 352 413 473 543 613

175 30 30 30 30 30 38 46 54 62 70 132 193 245 297 335 373 438 502 577 652

180 30 30 30 30 30 40 50 60 70 80 145 210 263 315 355 395 463 530 610 690

185 30 30 30 30 30 43 56 69 82 95 162 228 281 333 376 418 488 558 636 713

190 30 30 30 30 30 46 62 78 94 110 178 247 299 352 397 442 514 587 662 737

195 30 30 30 30 30 49 68 87 106 125 195 265 318 370 418 465 540 615 688 760

200 30 30 30 30 30 51 71 92 113 133 208 282 334 387 437 487 565 643 713 783

205 30 30 30 30 30 52 75 97 119 142 220 298 351 403 456 508 590 672 739 807

210 30 30 30 30 30 54 78 102 126 150 233 315 368 420 475 530 615 700 765 830

215 30 30 30 30 30 56 82 108 134 160 242 323 378 433 485 537 627 717 786 855

220 30 30 30 30 30 58 86 114 142 170 251 332 389 447 495 543 638 733 807 880

225 30 30 30 30 30 60 90 120 150 180 260 340 400 460 505 550 650 750 828 905

230 30 33 37 40 43 75 106 137 169 200 278 357 420 483 533 583 680 777 868 958

235 30 37 43 50 57 89 122 155 187 220 297 373 440 507 562 617 710 803 908 1012

240 30 40 50 60 70 104 138 172 206 240 315 390 460 530 590 650 740 830 948 1065

245 30 42 54 66 78 112 146 179 213 247 325 403 472 540 602 663 753 843 964 1085

250 30 44 58 73 87 120 153 187 220 253 335 417 483 550 613 677 767 857 981 1105

255 30 46 63 79 95 128 161 194 227 260 345 430 495 560 625 690 780 870 998 1125

260 30 48 67 85 103 136 168 200 233 265 355 445 508 570 638 705 800 895 1020 1145

265 30 50 71 91 112 143 175 207 238 270 365 460 520 580 650 720 820 920 1043 1165

270 30 53 75 98 120 151 182 213 244 275 375 475 533 590 663 735 840 945 1065 1185

275 30 53 77 100 123 155 187 219 251 283 383 482 544 607 681 755 862 968 1089 1210

280 30 54 78 103 127 160 193 226 259 292 390 488 556 623 699 775 883 992 1113 1235

285 30 55 80 105 130 164 198 232 266 300 398 495 568 640 718 795 905 1015 1138 1260

290 30 56 82 108 133 168 203 237 272 307 404 502 579 657 732 807 923 1040 1160 1280

295 30 57 83 110 137 172 207 243 278 313 411 508 591 673 746 818 942 1065 1183 1300

300 30 58 85 113 140 176 212 248 284 320 418 515 603 690 760 830 960 1090 1205 1320

Application Block Size (Acres)

Broadcast Equivalent Application Rate (lbs ai/arce)

Table 11. Drip Untarp Buried (6") Buffer Zones

57 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

90 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75

95 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75

100 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75

105 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75

110 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 80 86

115 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 86 96

120 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 91 107

125 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 96 118

130 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 102 129

135 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 107 139

140 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 113 150

145 75 75 75 75 75 75 75 75 75 75 75 75 77 79 86 92 107 122 161 199

150 75 75 75 75 75 75 75 75 75 75 75 75 79 84 96 109 139 169 209 249

155 75 75 75 75 75 75 75 75 75 75 75 75 81 88 107 126 171 216 257 298

160 75 75 75 75 75 75 75 75 75 75 75 75 84 92 118 144 204 264 305 347

165 75 75 75 75 75 75 75 75 75 75 75 75 86 96 129 161 236 311 354 396

170 75 75 75 75 75 75 75 75 75 75 75 75 88 101 139 178 268 358 402 446

175 75 75 75 75 75 75 75 75 75 75 75 75 90 105 150 195 300 405 450 495

180 75 75 75 75 75 75 75 75 75 75 87 99 124 150 194 238 342 446 498 551

185 75 75 75 75 75 75 75 75 75 75 99 122 159 195 238 281 384 486 546 606

190 75 75 75 75 75 75 75 75 75 75 110 146 193 240 282 324 425 527 595 662

195 75 75 75 75 75 75 75 75 75 75 122 169 227 285 326 366 467 568 643 718

200 75 75 75 75 75 75 75 75 75 75 134 193 261 330 370 409 509 609 691 774

205 75 75 75 75 75 75 75 75 75 75 146 216 296 375 414 452 551 649 739 829

210 75 75 75 75 75 75 75 75 75 75 158 240 330 420 458 495 593 690 788 885

215 75 75 75 75 75 77 79 81 84 86 178 270 358 446 484 523 624 724 813 902

220 75 75 75 75 75 79 84 88 92 96 198 300 386 471 511 551 655 759 839 919

225 75 75 75 75 75 81 88 94 101 107 219 330 414 497 538 579 686 793 865 936

230 75 75 75 75 75 84 92 101 109 118 239 360 441 523 565 606 717 827 890 954

235 75 75 75 75 75 86 96 107 118 129 259 390 469 549 591 634 748 861 916 971

240 75 75 75 75 75 88 101 114 126 139 280 420 497 574 618 662 779 896 942 988

245 75 75 75 75 75 90 105 120 135 150 300 450 525 600 645 690 810 930 968 1005

250 75 75 75 75 75 94 114 133 152 171 317 463 545 628 673 718 842 966 1020 1074

255 75 75 75 75 75 99 122 146 169 193 334 476 566 656 701 746 874 1003 1073 1142

260 75 75 75 75 75 103 131 159 186 214 351 489 586 684 729 774 906 1039 1125 1211

265 75 75 75 75 75 107 139 171 204 236 369 501 606 711 756 801 939 1076 1178 1279

270 75 75 75 75 75 111 148 184 221 257 386 514 627 739 784 829 971 1112 1230 1348

275 75 75 75 75 75 116 156 197 238 279 403 527 647 767 812 857 1003 1149 1283 1416

280 75 75 75 75 75 120 165 210 255 300 420 540 668 795 840 885 1035 1185 1335 1485

285 75 79 84 88 92 138 184 230 276 321 441 561 691 821 871 921 1075 1228 1379 1530

290 75 84 92 101 109 156 203 249 296 343 463 583 715 846 902 958 1114 1271 1423 1575

295 75 88 101 114 126 174 222 269 317 364 484 604 738 872 933 994 1154 1314 1467 1620

300 75 92 109 126 144 192 240 289 337 386 506 626 762 898 964 1031 1194 1356 1511 1665

305 75 96 118 139 161 210 259 309 358 407 527 647 785 924 995 1067 1233 1399 1555 1710

310 75 101 126 152 178 228 278 328 378 429 549 669 809 949 1026 1104 1273 1442 1599 1755

315 75 105 135 165 195 246 297 348 399 450 570 690 833 975 1058 1140 1313 1485 1643 1800

320 75 107 139 171 204 254 305 355 406 456 581 705 848 990 1079 1168 1344 1519 1682 1845

325 75 109 144 178 212 262 312 363 413 463 591 720 863 1005 1100 1196 1375 1554 1722 1890

330 75 111 148 184 221 270 320 370 420 469 602 735 878 1020 1122 1224 1406 1588 1761 1935

335 75 114 152 191 229 279 328 377 426 476 613 750 893 1035 1143 1251 1437 1622 1801 1980

340 75 116 156 197 238 287 336 384 433 482 624 765 908 1050 1165 1279 1468 1656 1841 2025

345 75 118 161 204 246 295 343 392 440 489 634 780 923 1065 1186 1307 1499 1691 1880 2070

350 75 120 165 210 255 303 351 399 447 495 645 795 938 1080 1208 1335 1530 1725 1920 2115

Table 12. Increased Shank Bed Tarp/Strip Tarp Buffer Zones Broadcast Equivalent Application Rate (lbs ai/arce)

Application Block Size (Acres)

58 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

15 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 35 43 50

20 25 25 25 25 25 25 25 25 25 25 28 30 34 38 44 50 75 105 128 150

25 25 25 25 25 25 25 25 25 25 25 30 35 43 50 63 75 125 175 213 250

30 25 25 25 25 25 28 30 33 35 38 59 80 103 125 156 188 238 288 331 375

35 25 25 25 25 25 30 35 40 45 50 88 125 163 200 250 300 350 400 450 500

40 25 31 38 44 50 70 90 110 130 150 213 275 313 350 400 450 550 650 713 775

45 38 47 56 66 75 95 115 135 155 175 250 325 388 450 500 550 638 738 813 888

50 50 63 75 88 100 120 140 160 180 200 288 375 463 550 600 650 725 825 913 1000

55 75 91 106 122 138 160 183 205 228 250 344 438 525 613 669 725 825 925 1019 1113

60 100 119 138 156 175 200 225 250 275 300 400 500 588 675 738 800 925 1025 1125 1225

65 113 134 156 178 200 228 255 283 310 338 444 550 644 738 813 888 1013 1138 1244 1350

70 125 150 175 200 225 255 285 315 345 375 488 600 700 800 888 975 1100 1250 1363 1475

75 138 166 194 222 250 283 315 348 380 413 538 663 763 863 950 1038 1188 1363 1494 1625

80 150 181 213 244 275 310 345 380 415 450 588 725 825 925 1013 1100 1275 1475 1625 1775

85 163 197 231 266 300 340 380 420 460 500 638 775 881 988 1088 1188 1375 1575 1738 1900

90 175 213 250 288 325 370 415 460 505 550 688 825 938 1050 1163 1275 1475 1675 1850 2025

95 175 225 275 325 375 420 465 510 555 600 763 925 1050 1175 1300 1425 1625 1875 2175 2475

100 188 238 288 338 388 435 483 530 578 625 794 963 1100 1238 1369 1500 1700 1938 2225 2513

105 200 250 300 350 400 450 500 550 600 650 825 1000 1150 1300 1438 1575 1775 2000 2275 2550

110 217 271 325 379 433 483 533 583 633 683 871 1058 1208 1358 1500 1642 1875 2125 2379 2633

115 233 292 350 408 467 517 567 617 667 717 917 1117 1267 1417 1563 1708 1975 2250 2483 2717

120 250 313 375 438 500 550 600 650 700 750 963 1175 1325 1475 1625 1775 2075 2375 2588 2800

125 263 325 388 450 513 568 623 678 733 788 969 1150 1350 1550 1713 1875 2150 2475 2663 2850

130 275 338 400 463 525 585 645 705 765 825 975 1125 1375 1625 1800 1975 2225 2575 2738 2900

135 288 353 419 484 550 610 670 730 790 850 1044 1238 1450 1663 1869 2075 2300 2675 2863 3050

140 300 369 437.5 506 575 635 695 755 815 875 1113 1350 1525 1700 1938 2175 2375 2775 2988 3200

145 308 379 450 521 592 657 722 787 852 917 1154 1392 1583 1775 2004 2233 2500 2875 3129 3383

150 317 390 463 535 608 678 748 818 888 958 1196 1433 1642 1850 2071 2292 2625 2975 3271 3567

155 325 400 475 550 625 700 775 850 925 1000 1238 1475 1700 1925 2138 2350 2750 3075 3413 3750

160 331 409 488 566 644 720 796 873 949 1025 1272 1519 1753 1988 2194 2400 2813 3194 3547 3900

165 338 419 500 581 663 740 818 895 973 1050 1306 1563 1806 2050 2250 2450 2875 3313 3681 4050

170 344 428 513 597 681 760 839 918 996 1075 1341 1606 1859 2113 2306 2500 2938 3431 3816 4200

175 350 438 525 613 700 780 860 940 1020 1100 1375 1650 1913 2175 2363 2550 3000 3550 3950 4350

Table 13. Shank Bed Untarp Based on Phoenix, AZ Flux Study 

Application Block Size (Acres)

Broadcast Equivalent Application Rate (lbs ai/arce)

59 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

70 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75

80 75 75 75 75 75 75 75 75 75 75 75 75 75 75 78 81 96 111 120 129

90 75 75 75 75 75 75 75 75 75 75 75 75 75 75 81 87 117 147 165 183

95 75 75 75 75 75 75 75 75 75 75 75 75 75 75 84 93 138 183 210 237

100 75 75 75 75 75 75 75 75 75 75 75 75 75 75 87 99 159 219 255 291

105 75 75 75 75 75 75 75 75 75 75 75 75 75 75 90 105 180 255 300 345

110 75 75 75 75 75 75 75 75 75 75 88 101 107 114 134 154 233 311 360 409

115 75 75 75 75 75 75 75 75 75 75 101 126 139 152 178 204 285 366 420 474

120 75 75 75 75 75 75 75 75 75 75 114 152 171 191 222 253 338 422 480 538

125 75 75 75 75 75 75 75 75 75 75 126 178 204 229 266 302 390 478 540 602

130 75 75 75 75 75 75 75 75 75 75 139 204 236 268 310 351 443 534 600 666

135 75 75 75 75 75 75 75 75 75 75 152 229 268 306 354 401 495 589 660 731

140 75 75 75 75 75 75 75 75 75 75 165 255 300 345 398 450 548 645 720 795

145 75 75 75 75 75 80 85 90 96 101 192 283 335 388 440 493 594 694 776 857

150 75 75 75 75 75 85 96 106 116 126 219 311 371 431 483 536 640 744 831 919

155 75 75 75 75 75 90 106 121 137 152 245 339 406 474 526 579 686 793 887 981

160 75 75 75 75 75 96 116 137 157 178 272 366 441 516 569 621 732 842 943 1044

165 75 75 75 75 75 101 126 152 178 204 299 394 477 559 612 664 778 891 999 1106

170 75 75 75 75 75 106 137 168 198 229 326 422 512 602 655 707 824 941 1054 1168

175 75 75 75 75 75 111 147 183 219 255 353 450 548 645 698 750 870 990 1110 1230

180 75 80 86 91 96 135 173 211 249 287 386 484 582 679 746 812 935 1059 1181 1303

185 75 86 96 107 118 158 198 239 279 319 419 519 616 714 794 874 1001 1127 1251 1376

190 75 91 107 123 139 182 224 267 309 351 452 553 650 748 842 936 1066 1196 1322 1449

195 75 96 118 139 161 205 250 294 339 384 485 587 685 782 890 999 1131 1264 1393 1521

200 75 102 129 155 182 229 276 322 369 416 519 621 719 816 939 1061 1197 1333 1464 1594

205 75 107 139 171 204 252 301 350 399 448 552 656 753 851 987 1123 1262 1401 1534 1667

210 75 113 150 188 225 276 327 378 429 480 585 690 788 885 1035 1185 1328 1470 1605 1740

215 75 118 161 204 246 297 347 397 447 497 608 718 823 928 1077 1226 1369 1513 1648 1783

220 75 123 171 220 268 317 366 416 465 514 630 746 858 971 1119 1266 1411 1556 1691 1826

225 75 129 182 236 289 338 386 435 483 531 653 774 894 1014 1160 1307 1453 1599 1734 1869

230 75 134 193 252 311 358 406 453 501 549 675 801 929 1056 1202 1348 1495 1641 1776 1911

235 75 139 204 268 332 379 426 472 519 566 698 829 964 1099 1244 1389 1536 1684 1819 1954

240 75 145 214 284 354 399 445 491 537 583 720 857 1000 1142 1286 1429 1578 1727 1862 1997

245 75 150 225 300 375 420 465 510 555 600 743 885 1035 1185 1328 1470 1620 1770 1905 2040

250 75 153 230 308 386 431 477 522 567 613 761 909 1065 1221 1359 1496 1654 1813 1968 2124

255 75 155 236 316 396 442 488 534 580 626 779 932 1095 1258 1390 1521 1689 1856 2031 2207

260 75 158 241 324 407 453 500 546 592 639 797 956 1125 1294 1421 1547 1723 1899 2095 2291

265 75 161 246 332 418 465 511 558 605 651 815 979 1155 1331 1452 1573 1757 1941 2158 2374

270 75 163 252 340 429 476 523 570 617 664 834 1003 1185 1367 1483 1599 1791 1984 2221 2458

275 75 166 257 348 439 487 534 582 630 677 852 1026 1215 1404 1514 1624 1826 2027 2284 2541

280 75 169 263 356 450 498 546 594 642 690 870 1050 1245 1440 1545 1650 1860 2070 2348 2625

285 75 172 268 365 461 512 563 614 665 716 900 1084 1268 1451 1579 1706 1926 2145 2394 2644

290 75 174 274 373 473 527 581 635 689 743 930 1118 1290 1463 1613 1763 1991 2220 2441 2663

295 75 177 279 382 484 541 598 655 712 769 960 1151 1313 1474 1646 1819 2057 2295 2488 2681

300 75 180 285 390 495 555 615 675 735 795 990 1185 1335 1485 1680 1875 2123 2370 2535 2700

305 85 193 300 408 515 576 637 698 759 820 1023 1225 1380 1535 1718 1900 2155 2410 2585 2760

310 95 205 315 425 535 597 659 721 783 845 1055 1265 1425 1585 1755 1925 2188 2450 2635 2820

315 105 218 330 443 555 618 681 744 807 870 1088 1305 1470 1635 1793 1950 2220 2490 2685 2880

320 111 226 340 454 568 630 693 756 818 881 1101 1322 1493 1663 1823 1982 2255 2529 2717 2906

325 118 234 349 465 581 643 705 767 829 891 1115 1339 1515 1691 1853 2014 2291 2567 2749 2931

330 124 242 359 476 594 655 717 779 840 902 1129 1356 1538 1719 1883 2046 2326 2606 2781 2957

335 131 250 369 488 606 668 729 790 852 913 1143 1374 1560 1746 1913 2079 2361 2644 2814 2983

340 137 258 378 499 619 680 741 802 863 924 1157 1391 1583 1774 1943 2111 2397 2683 2846 3009

345 144 266 388 510 632 693 753 813 874 934 1171 1408 1605 1802 1973 2143 2432 2721 2878 3034

350 150 274 398 521 645 705 765 825 885 945 1185 1425 1628 1830 2003 2175 2468 2760 2910 3060

Table 14. Increased Shank Broadcast Tarp Buffer Zones

Application Block Size (Acres)

Broadcast Equivalent Application Rate (lbs ai/arce)

60 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

30 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75

35 75 75 75 75 75 75 75 75 75 75 75 75 75 75 90 105 128 150 188 225

40 75 75 75 75 75 75 75 75 75 75 75 75 75 75 113 150 240 330 413 495

45 75 75 75 75 75 75 75 75 75 75 75 75 124 173 229 285 398 510 604 698

50 75 75 75 75 75 75 75 75 75 75 75 75 173 270 345 420 555 690 795 900

55 75 75 75 75 75 75 75 75 75 75 139 203 300 398 484 570 713 855 975 1095

60 75 75 75 75 75 75 75 75 75 75 203 330 428 525 623 720 870 1020 1155 1290

65 75 75 75 75 75 87 99 111 123 135 285 435 548 660 758 855 1028 1200 1343 1485

70 75 75 75 75 75 99 123 147 171 195 368 540 668 795 893 990 1185 1380 1530 1680

75 75 78 80 83 85 127 169 211 253 295 475 655 788 920 1030 1140 1355 1570 1735 1900

80 75 80 85 90 95 155 215 275 335 395 583 770 908 1045 1168 1290 1525 1760 1940 2120

85 75 83 90 98 105 183 261 339 417 495 690 885 1028 1170 1305 1440 1695 1950 2145 2340

90 75 102 129 157 184 259 334 409 484 559 743 926 1097 1268 1418 1568 1847 2126 2381 2636

95 75 122 169 216 263 335 407 479 551 623 795 968 1166 1365 1530 1695 1999 2303 2618 2933

100 75 142 208 275 341 410 479 548 617 686 848 1009 1236 1463 1643 1823 2151 2479 2854 3229

105 75 161 248 334 420 486 552 618 684 750 900 1050 1305 1560 1755 1950 2303 2655 3090 3525

110 75 169 263 356 450 518 587 655 724 792 975 1158 1418 1677 1883 2088 2451 2814 3237 3660

115 75 176 278 379 480 551 622 692 763 834 1050 1266 1530 1794 2010 2226 2600 2973 3384 3795

120 75 184 293 401 510 583 656 730 803 876 1125 1374 1643 1911 2138 2364 2748 3132 3531 3930

125 75 191 308 424 540 616 691 767 842 918 1200 1482 1755 2028 2265 2502 2897 3291 3678 4065

130 75 199 323 446 570 648 726 804 882 960 1275 1590 1868 2145 2393 2640 3045 3450 3825 4200

135 75 214 353 491 630 713 795 878 960 1043 1350 1658 1954 2250 2498 2745 3120 3495 3941 4388

140 75 229 383 536 690 777 864 951 1038 1125 1425 1725 2040 2355 2603 2850 3195 3540 4058 4575

145 75 233 390 548 705 804 903 1002 1101 1200 1500 1800 2117 2434 2708 2981 3324 3668 4206 4744

150 75 236 398 559 720 831 942 1053 1164 1275 1575 1875 2194 2513 2813 3113 3454 3795 4354 4913

155 75 240 405 570 735 858 981 1104 1227 1350 1650 1950 2271 2591 2918 3244 3583 3923 4502 5081

160 75 244 413 581 750 885 1020 1155 1290 1425 1725 2025 2348 2670 3023 3375 3713 4050 4650 5250

165 75 256 438 619 800 930 1060 1190 1320 1450 1785 2120 2450 2780 3115 3450 3850 4250 4800 5350

170 75 269 463 656 850 975 1100 1225 1350 1475 1845 2215 2553 2890 3208 3525 3988 4450 4950 5450

175 75 281 488 694 900 1020 1140 1260 1380 1500 1905 2310 2655 3000 3300 3600 4125 4650 5100 5550

Table 15. Increased Shank Broadcast Untarp Buffer Zones

Application Block Size (Acres)

Broadcast Equivalent Application Rate (lbs ai/arce)

61 
1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80

30 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75 75

40 75 75 75 75 75 75 75 75 75 75 90 105 121 138 154 170 190 210 231 253

50 75 75 75 75 75 75 75 75 75 75 105 135 168 200 233 265 305 345 388 430

60 75 75 75 75 75 75 75 75 75 75 135 195 260 325 390 455 535 615 700 785

70 75 75 75 75 75 75 75 75 75 75 165 255 353 450 548 645 765 885 1013 1140

80 75 75 75 75 75 100 117 134 152 165 296 428 536 645 746 848 1001 1155 1294 1433

90 75 75 75 75 75 125 159 194 228 255 428 600 720 840 945 1050 1238 1425 1575 1725

100 75 79 83 86 90 149 201 253 305 353 536 720 855 990 1103 1215 1433 1650 1823 1995

105 75 83 90 98 105 174 243 312 381 450 645 840 990 1140 1260 1380 1628 1875 2070 2265

110 75 95 115 134 154 223 292 361 430 499 702 904 1064 1224 1351 1479 1737 1995 2204 2413

115 75 107 139 171 204 273 342 411 480 549 759 969 1138 1307 1442 1577 1846 2115 2338 2561

120 75 119 164 208 253 322 391 460 529 598 815 1033 1212 1391 1533 1676 1955 2235 2472 2709

125 75 132 189 245 302 371 440 509 578 647 872 1097 1286 1474 1624 1774 2065 2355 2606 2856

130 75 144 213 282 351 420 489 558 627 696 929 1161 1360 1558 1715 1873 2174 2475 2740 3004

135 75 156 238 319 401 470 539 608 677 746 986 1226 1434 1641 1806 1971 2283 2595 2874 3152

140 75 169 263 356 450 519 588 657 726 795 1043 1290 1508 1725 1898 2070 2393 2715 3008 3300

145 75 176 276 377 478 549 621 693 764 836 1094 1352 1580 1809 1992 2175 2522 2869 3183 3497

150 75 183 290 398 506 580 654 728 802 876 1145 1414 1653 1892 2086 2280 2652 3024 3359 3694

155 75 190 304 419 534 610 687 764 840 917 1197 1476 1726 1976 2180 2385 2781 3178 3535 3891

160 75 197 318 440 561 641 720 799 879 958 1248 1539 1799 2059 2275 2490 2911 3332 3710 4089

165 75 204 332 461 589 671 753 835 917 999 1300 1601 1872 2143 2369 2595 3041 3486 3886 4286

170 75 211 346 482 617 702 786 870 955 1039 1351 1663 1945 2226 2463 2700 3170 3641 4062 4483

175 75 218 360 503 645 732 819 906 993 1080 1403 1725 2018 2310 2558 2805 3300 3795 4238 4680

180 75 226 377 528 679 770 860 951 1041 1131 1473 1815 2112 2409 2658 2908 3418 3928 4355 4783

185 75 235 394 554 714 807 901 995 1089 1183 1544 1905 2206 2507 2759 3011 3536 4061 4473 4886

190 75 243 411 580 748 845 942 1040 1137 1234 1615 1995 2300 2606 2860 3114 3654 4194 4591 4989

195 75 252 429 605 782 883 984 1084 1185 1286 1685 2085 2395 2704 2960 3216 3771 4326 4709 5091

200 75 260 446 631 816 921 1025 1129 1233 1337 1756 2175 2489 2803 3061 3319 3889 4459 4827 5194

205 75 269 463 657 851 958 1066 1173 1281 1389 1827 2265 2583 2901 3162 3422 4007 4592 4945 5297

210 75 278 480 683 885 996 1107 1218 1329 1440 1898 2355 2678 3000 3263 3525 4125 4725 5063 5400

215 96 303 509 715 921 1035 1148 1261 1374 1487 1951 2415 2740 3064 3334 3604 4228 4851 5163 5475

220 118 328 538 748 958 1073 1188 1304 1419 1534 2005 2475 2802 3129 3406 3684 4331 4978 5264 5550

225 139 353 567 781 994 1112 1229 1347 1464 1581 2058 2535 2864 3193 3478 3763 4434 5104 5365 5625

230 161 378 596 813 1031 1150 1270 1389 1509 1629 2112 2595 2926 3257 3550 3842 4536 5231 5465 5700

235 182 403 625 846 1067 1189 1311 1432 1554 1676 2165 2655 2988 3321 3621 3921 4639 5357 5566 5775

240 204 429 654 879 1104 1227 1351 1475 1599 1723 2219 2715 3050 3386 3693 4001 4742 5484 5667 5850

245 225 454 683 911 1140 1266 1392 1518 1644 1770 2273 2775 3113 3450 3765 4080 4845 5610 5768 5925

250 246 476 706 936 1166 1293 1421 1549 1677 1804 2306 2807 3171 3536 3849 4161 4924 5687 5886 6086

255 268 499 730 961 1191 1321 1450 1580 1709 1839 2339 2839 3230 3621 3932 4243 5004 5764 6005 6246

260 289 521 753 985 1217 1348 1479 1611 1742 1873 2372 2871 3289 3707 4016 4324 5083 5841 6124 6407

265 311 544 777 1010 1243 1376 1509 1641 1774 1907 2405 2904 3348 3793 4099 4406 5162 5919 6243 6568

270 332 566 800 1034 1269 1403 1538 1672 1807 1941 2439 2936 3407 3879 4183 4487 5241 5996 6362 6729

275 354 589 824 1059 1294 1431 1567 1703 1839 1976 2472 2968 3466 3964 4266 4569 5321 6073 6481 6889

280 375 611 848 1084 1320 1458 1596 1734 1872 2010 2505 3000 3525 4050 4350 4650 5400 6150 6600 7050

285 386 624 861 1099 1337 1479 1622 1764 1906 2049 2559 3069 3602 4136 4436 4736 5507 6279 6729 7179

290 396 636 875 1115 1354 1501 1647 1794 1941 2087 2612 3137 3679 4221 4521 4821 5614 6407 6857 7307

295 407 648 889 1130 1371 1522 1673 1824 1975 2126 2666 3206 3756 4307 4607 4907 5721 6536 6986 7436

300 418 661 903 1146 1389 1544 1699 1854 2009 2164 2719 3274 3834 4393 4693 4993 5829 6664 7114 7564

305 429 673 917 1161 1406 1565 1725 1884 2043 2203 2773 3343 3911 4479 4779 5079 5936 6793 7243 7693

310 439 685 931 1177 1423 1587 1750 1914 2078 2241 2826 3411 3988 4564 4864 5164 6043 6921 7371 7821

315 450 698 945 1193 1440 1608 1776 1944 2112 2280 2880 3480 4065 4650 4950 5250 6150 7050 7500 7950

320 454 706 957 1208 1459 1629 1798 1967 2136 2306 2919 3531 4114 4697 5025 5353 6254 7155 7678 8201

325 459 714 969 1224 1479 1649 1820 1990 2161 2331 2957 3583 4164 4744 5100 5456 6358 7260 7856 8451

330 463 722 980 1239 1498 1670 1842 2013 2185 2357 2996 3634 4213 4791 5175 5559 6462 7365 8034 8702

335 467 730 992 1255 1517 1690 1863 2037 2210 2383 3034 3686 4262 4839 5250 5661 6566 7470 8211 8953

340 471 738 1004 1270 1536 1711 1885 2060 2234 2409 3073 3737 4311 4886 5325 5764 6670 7575 8389 9204

345 476 746 1016 1286 1556 1731 1907 2083 2259 2434 3111 3789 4361 4933 5400 5867 6774 7680 8567 9454

350 480 754 1028 1301 1575 1752 1929 2106 2283 2460 3150 3840 4410 4980 5475 5970 6878 7785 8745 9705

Table 16. Increased Shank Broadcast Deep (18 inches) Untarp Buffer Zones Broadcast Equivalent Application Rate (lbs ai/arce)

Application Block Size (Acres)

62 
Table 17. Buffer Zones for Pre-Plant Greenhouse Tarped Soil Fumigations 

Structure Size Buffer Zone 

≤ 25,000 square feet 25 feet 

> 25,000 square feet and ≤ 30,000 square feet 50 feet 

> 30,000 square feet and ≤ 35,000 square feet 75 feet 

> 35,000 square feet and ≤ 40,000 square feet 100 feet 

> 40,000 square feet and ≤ 45,000 square feet 115 feet 

> 45,000 square feet and up to 50,000 square feet 130 feet 

Table 9, from the July 2008 RED, summarized the required buffer zone distances and 

corresponding PERFUM modeling results for the pre-plant soil uses assessed by the Agency 

during Phase 5 of the reregistration process. It also showed the percentile for the whole and 

maximum field distributions for each buffer distance, as well as the MOE at the 95th and 99th

percentile air concentration of PERFUM. (See Appendix D for more details on the PERFUM 

model inputs and outputs). 

The Agency has revised Table 9 from the July 2008 RED based on the new Wasco, CA 

data. As noted above the Wasco emission data did not include a study for the untarp bed 

application method, and therefore the numbers for the scenarios have not changed since the July 

2008 RED. These scenarios are italicized in the table. Since the Agency believes that the Wasco 

studies are more representative of current practices, the results characterized below represent 

information from the Wasco studies. Table 18 contains the new information. 

In Table 18 the buffer zones reach the target MOE of 1 at high percentiles, i.e., at least at 

95% whole field and all maximum percentiles range from 50 to above 99 percent. Furthermore 

the numbers also reach half of the target at the 99th percentile air concentration in PERFUM runs. 

This concentration corresponds to minor, reversible irritation effects observed in the human 

study. Even though the new buffer zones are smaller, the new distances reach the Agency’s 

target at higher percentiles. As such, the Agency is confident that the buffer zones are still 

protective against severe health effects while also reducing the impacts to users. 

Focusing on the forest seedling nursery in the Southeast as an example, the buffer zone 

for a 10 acre plot at a rate of 300 lbs ai/A is 265 feet. At 265 feet, the PERFUM model predicts 

the 95th percentile for the whole field distribution and the 55th percentile for the maximum field 

distribution. The risk level corresponding to this buffer zone distance at the 95th 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 95 percent chance of having of an exposure below the level of 

concern (i.e., MOE of 1or higher). The risk level corresponding to the buffer zone distances at 

the 55th 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 55 

percent chance of having of an exposure below the level of concern (i.e., MOE of 1 or higher). 

The Agency believes that the buffer zone distances described above, combined with other 

risk mitigations described herein, will provide protection against unreasonable adverse effects. 

63 
Table 18. Projected Buffer Zone Distances for Crops with Significant Chloropicrin Usage 

Whole and 

Maximum Field 

Percentiles 

(MOE = 1) 

MOE at 95th

and 99th

Percentile of 

PERFUM 2 

Crop Region Application 

Method 

Rate 

(lb 

ai/A) 

Block 

Size 

(acres) 

Buffer 

zone 

Distances 

without 

credits Whole Max 95th 99th

CA & 10 25 99 90 >1 1 

Southeast 

Tarp Broadcast 50 

40 25 99 90 >1 1 

CA & 10 25 99 99 >1 1 

Southeast 

Tarp Bed 50 

40 25 99 99 >1 1 

Michigan Tarp Broadcast 70 10 25 99 90 >1 1 

40 25 99 90 >1 1 

10 25 99 99 >1 1 

Cucurbits 

Michigan Tarp Bed 70 

40 25 99 99 >1 1 

Eggplant CA & 10 25 99 99 >1 1 

Southeast 

Tarp Bed 75 

40 25 99 99 >1 1 

Southeast Tarp Broadcast 300 10 265 95 55 1 0.6 

20 395 95 50 1 0.6 

10 25 99 80 >1 1 

Forest 

Seedling 

West Tarp Broadcast 116 

20 51 99 80 >1 1 

Orchard 20 25 99 99 >1 1 

Replant-Stone 

CA Deep Tarp Bed 43 

30 25 99 99 >1 1 

CA & MI Tarp Bed 100 10 25 99 99 >1 1 

40 25 99 95 >1 1 

10 25 99 99 >1 1 

Pepper 

Southeast Tarp Bed 75 

40 25 99 99 >1 1 

CA Tarp Bed 117 10 25 99 99 >1 1 

20 25 99 95 >1 1 

10 25 97 90 >1 1 

Strawberry 

FL Tarp Bed 143 

20 25 95 80 1 1 

Strawberry 10 139 99 55 >1 1 

Nursery 

CA & 

Southeast 

Tarp Broadcast 200 

40 354 95 50 1 1 

Sweet Potato Texas Tarp Bed 10 10 25 99 99 >1 1 

40 25 99 99 >1 1 

Tobacco All States Tarp Bed 80 10 25 99 99 >1 1 

40 25 99 95 >1 1 

CA & FL Tarp Bed 133 10 25 99 97 >1 1 

40 25 95 80 1 1 

10 25 99 99 >1 1 

Tomato 

MI Tarp Bed 114 

40 25 97 80 >1 1 

Carrot CA Bed 18 80 50 90 65 0.9 0.5 

Onion Oregon Bed Compaction 34 40 300 90 50 0.9 0.5 

Washington Bed Compaction 22 40 100 97 80 0.9 0.6 

Orchard 20 25 97 85 >1 1 

Replant-Grape 

& Nut 

CA Deep Bed 

Compaction 

12 

30 25 95 75 >1 1 

Orchard 

Replant-Pome 

Pacific NW Deep Bed 

Compaction 

50 5 100 90 50 0.9 0.5 

Orchard 

Replant-Stone 

Pacific NW Deep Bed 

Compaction 

68 5 225 90 50 0.9 0.5 

64 
 Amended Buffer Zone Requirements 

The following describes the general buffer zone requirements, as amended, for chloropicrin: 

• “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 

8 and 9 in Appendix D for further explanation.) 

Buffer zone proximity

• To reduce the potential for off-site movement from multiple fumigated fields, buffer zones 

from multiple chloropicrin 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. 

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). 

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 

65 
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, and 

° Sensory irritation is not experienced. 

• 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. 

• 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. 

 

66 
ii. 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,”9 in the chloropicrin 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 chloropicrin RED gave buffer zone 

reduction credits for: high barrier tarps (40%), high barrier tarps used in combination with the 

SymmetryTM application system (50%), potassium thiosulfate (KTS) applied over tarped fields 

(5%), soils with high organic matter (10%), and soils with high clay content (10%). The July 

2008 RED stated that the buffer zone credits were additive, but that the total credit could not 

exceed 50 percent. EPA noted that changing current use practices or site conditions to utilize 

these credits may be a challenge, but that the Agency believed that in addition to reducing 

bystander risk and the size of buffer zones, the credits for high barrier tarps, SymmetryTM

application system, and KTS had the potential to increase efficacy, and also that the use of high 

barrier tarps could reduce application rates. 

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 

additive effect in reducing emissions when multiple factors were combined. As a result, EPA 

has updated the buffer reduction credits and determined that the 50% 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 D362369, Updated Health Effects Division Recommendations For Good Agricultural 

Practices and Associated Buffer Credits,” in the chloropicrin docket. 

 High Barrier Tarps 

Credits in the July 2008 RED 

 

9

 EPA-HQ-OPP-2007-0350-0173. Factors Which Impact Soil Fumigant Emissions - Evaluation for Use in Soil 

Fumigant Buffer Zone Credit Factor Approach, June 9, 2008, DP Barcode: 306857 

67 
The July 2008 RED determined that a 40% buffer credit for chloropicrin was appropriate 

for the following high barrier tarps: Bromostop® (1.38 mil), IPM Clear VIF (1.38 mil), 

Eval/Mitsui (1.38 mil), Hytiblock 7 Black (0.00125”), XL Black Blockade (0.00125”), and 

Hytibar (1.5 mil). The Agency believed that the actual reduction for tarps could be higher for 

certain conditions but that a 40% 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 high 

barrier 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 

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 D362369, 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 

68 
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. 

 High Barrier Tarps with SymmetryTM Application System 

Credits in the July 2008 RED 

In the July 2008 RED, the Agency gave a 50% credit when the SymmetryTM application 

system was used with approved high barrier tarps (tarps listed in the July 2008 RED) and the 

application rate was less than 100 lbs ai/A. The 50% credit was based on the 40% credit for the 

high barrier tarps and a 10% credit for the SymmetryTM application method. This credit was 

based on studies sponsored by Arysta Life Sciences North America Corporation.10, 11 EPA stated 

in the 2008 RED that due to limited information regarding how the application system reduced 

emissions without high barrier tarps or at higher application rates, the Agency believed the 

credit, while conservative, is appropriate. 

Credits for the Amended RED 

 The Agency did not receive any comments or additional data on this credit in particular. 

However since the credits for the high barrier tarps have changed the Agency is increasing the 

credit to 70% when the SymmetryTM application system is used with the following high barrier 

tarps: 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), provided the application rate is less than 100 

lbs ai/A. The 70% credit is based on the 60% credit for the tarp and a 10% credit for the 

SymmetryTM application method. In addition to the increase, the Agency is giving a 40% credit 

when the SymmetryTM application system is used with Canslit Heatstrip Silver and Canslit 

Metalized high-barrier tarps, provided the application rate is less than 100 lbs ai/A. The 40% 

credit was based on the 30% credit for the high barrier tarps and a 10% credit for the 

SymmetryTM application method. 

 Potassium Thiosulfate (KTS) and Tarps 

Credits in the July 2008 RED 

 

10 EPA MRID 472952-03 Baker, F.: Arndt, T. (2007) Direct and Indirect Flux Determination of Iodomethane and 

Chloropicrin Under Field Conditions Following Tarped/Raised Bed/Shallow Shank Injection of Midas 50:50 in 

Bainbridge, GA. Project Number: 1619W, 1619W/1. Unpublished study prepared by PTRL West, Inc, Paragon 

Research Services, Pacific Ag Group. 590 p. [Black Hytiblock] 11 EPA MRID 472952-04; Baker F.; Arndt, T. (2007) Direct and Indirect Flux Determination of Iodomethane and 

Chloropicrin Under Field Conditions Following Tarped/Raised Bed/Shallow Shank Injection of Midas 50:50 in 

Hart, Michigan. Project Number: 1646W, 1646W/1. Unpublished study prepared by PTRL West, Inc, Paragon 

Research Services, Pacific Ag Group, 590 p. [Black Blockade] 

69 
EPA gave a 5% credit for applications of KTS. The KTS credit was based on a field 

study conducted by Dr. Husein Ajwa12 that indicated reductions in chloropicrin emissions when 

KTS is applied to the top of tarps after the fumigation. In the 2008 RED the Agency stated that 

the KTS credit could be added to the high barrier tarp credit, e.g., the buffer zone could be 

reduced by 45%. However, only a 5% credit would apply if KTS was used with any other tarp. 

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 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. 

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 any other tarp not currently listed in the amended RED, 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 

Water Seal in Strawberry Raised Beds. California Strawberry Commission Annual Production 

Research Report 2007-2008,” show 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. 

 

12 Ajwa, H. Fumigant Emission Reductions by Using Low Permeability Film and Thiosulfate Water Seal. 2007 

Methyl Bromide Alternatives Outreach Conference. http://mbao.org/2007/PDF/Preplant/PP1/Ajwa(6).pdf. 

70 
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 any other tarp not currently listed in the 

amended RED, the credit is 15%. 

 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 June 2008 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 the organic matter credit can be 

revised. A 10% credit will be given if chloropicrin 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. 

71 
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 which examined 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 with 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 

 The amended RED is not going to provide credits for soil moisture. However, based on 

the Wasco, CA emission studies the Agency has developed buffer tables based on different soil 

moisture percentiles. 

 Soil Temperature 

July 2008 RED 

 EPA did not give a credit for soil temperature in the July 2008 RED. Instead the Agency 

required a maximum temperature as part of the mandatory GAPs. 

Comments on the July 2008 RED 

 Stakeholders commented that chloropicrin should receive a credit for lower soil 

temperatures. 

Credits for the Amended RED 

72 
Most of the emission studies occurred at reasonable temperatures, with the average 

day/night air temperature around 70°F. Data presented in the Agency’s June 2008 factors 

document indicate that increased soil temperatures correspond to increase fumigant emissions. 

Based on this information and the GAP for soil temperature, a 10% emission credit is being 

provided to reduce the buffers for applications in soils with temperatures of 50°F or less when 

measured at a soil depth of 3 inches. 

 Buffer Zone Credit Cap 

Credits in the July 2008 RED 

The Agency determined, in the July 2008 RED, that the buffer zone credits were 

additive. This meant, for example, that a 40% credit for a high barrier tarp could be added to a 

10 % credit for organic matter to achieve a total credit of 50%. The Agency placed a limit, or 

“credit cap,” of 50% on the total size of the credit allowed for chloropicrin. 

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 50% 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 

credits cap to 80%. The Agency has reviewed the new studies to evaluate the extent to which the 

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 chloropicrin. 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 forest seedling nurseries in the Southeast as an example, the buffer zone 

distance for a 10 acre application block at a rate of 300 lbs ai/A is 265 feet without any credits 

(see Table 7). 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 106 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 53 feet. 

73 
 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: D362369, 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 chloropicrin 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. 

b. 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 

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 daycare 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 phrase, “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 

74 
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 daycare 

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 

(1320 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. 

c. 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. 

Comments received in response to the July 2008 RED 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 

75 
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, etc.), 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 amended RED. 

The revised posting requirements are listed below and have been included in the revised 

label table. 

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. 

76 
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). 

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," 

-- "Chloropicrin 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," 

-- "Chloropicrin OR [Name of product] 

Fumigant BUFFER ZONE,” 

-- contact information for the certified 

applicator in charge of the fumigation 

77 
d. Use Prohibitions 

In the July 2008 RED the Agency prohibited the drip untarp buried application method 

because it did not have adequate data to determine the appropriate mitigation. As described in 

the Buffer Zone section, EPA has reviewed emission studies for the drip irrigation buried untarp 

application method, and this use is now eligible for reregistration. 

2. Occupational Mitigation 

a. 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; 

• 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, 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 

78 
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). 

b. Handler Requirements 

Currently, chloropicrin labels require that all handlers involved in a chloropicrin 

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 

that 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, except water run, (e.g., shank) 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 water-run applications (e.g., drip), the certified applicator must be at the fumigation 

site to start the application including set-up, calibration, and initiation of the application. 

The certified applicator may leave the site but must return every two hours to visually 

inspect the equipment to ensure proper functioning and must directly supervise all WPStrained handlers on-site until the fumigation has stopped being delivered/dispersed into 

the soil. WPS-trained handlers may perform the monitoring functions in place of the 

certified applicator but must be under the supervision of the certified applicator and be 

able to communicate with the certified applicator at all times during monitoring activities 

via cell phone or other means. The results of monitoring activities must be captured in 

the FMP’s post-application summary report. 

• 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 

79 
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 chloropicrin training program within the preceding 12 months before they apply a 

chloropicrin 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 PostRED 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. 

c. Respiratory Protection 

The Agency’s human health risk assessment indicates that inhalation risks exceed the 

Agency’s level of concern for many handler activities. The human study which served as the 

basis for the occupational risk assessment indicates that transient eye and nose irritation 

associated with acute chloropicrin exposure do not carryover day to day, and therefore the 

Agency is most concerned about protecting handlers and workers from acute inhalation 

exposure. 

To address the acute inhalation risks the July 2008 Chloropicrin 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 0.15 ppm for chloropicrin, which is the level that corresponds to early signs 

of exposure. If air samples indicated 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. 

The Agency’s decision to require respiratory protection only if certain triggers were 

reached took into consideration current label requirements,13 the identified risks, and stakeholder 

 

13 Current chloropicrin labels state that the acceptable air concentration level is 0.1 ppm, and require air-purifying 

respirators when the air concentration of chloropicrin exceeds 0.1 ppm, and SCBA when the air concentration 

exceeds 4 ppm. The labels, however, do not require monitoring to determine whether the acceptable air 

80 
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 chloropicrin, comments focused on the feasibility, 

reliability, and protectiveness of using colorimetric tubes due to the current sensitivity and 

accuracy of the tubes, the cost of the tubes, and the Agency’s action level of 0.15 ppm (some 

commenters claim that 0.15 ppm is overly protective, while others state the level should not have 

been changed from 0.1 ppm). Other comments stated that handlers should have the option of 

ceasing the application until air concentrations of 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 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 chloropicrin including colorimetric tubes from 

manufacturers including: Matheson/Kitagawa, Sensidyne, and Dräger. While these tubes have 

detection limits that are less than the Agency’s action level of 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. 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 with available devices would 

significantly reduce handler risks. In addition, EPA is aware that monitoring with these devices 

adds significant costs to fumigations, please see the following document for more details, 

“Analysis of Soil Fumigant Risk Management Requirements using Geographic Information 

Systems: Case Studies Based on a Forest Seedling Nursery (DP # 363546)” May 13, 2009. EPA 

is also concerned that monitoring with devices that are not reliable could cause handlers to 

believe that concentrations are below the action level despite other indications such as eye 

irritation. As a result, the Agency is removing the initial monitoring requirement. 

 concentration as been exceeded. The 4 ppm level was formerly NIOSH’s IDLH (immediately dangerous to life and 

health) level. This level has since been revised to 2 ppm. (http://www.cdc.gov/Niosh/idlh/76062.html) 

81 
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 that are practical and reliable for field use 

at action-level concentrations. 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. 

Although the Agency has removed the initial monitoring requirement, EPA is keeping the 

action level for chloropicrin at 0.15 ppm. The Agency does not believe that this level is overly 

conservative because 0.15 ppm corresponds to approximately two times the BMCL10 of 0.073 

ppm. While 0.15 ppm is greater than the BMCL10, EPA is keeping this action level because this 

is the level at which participants in the human study began to experience eye irritation that was 

mild and reversible and effects did not carry over. Since effects are non-severe and reversible 

the Agency believes that this level is effective as a warning for handlers of when concentrations 

are reaching the point where steps are needed to protect fumigant handlers. 

 In addition to the comments on the monitoring devices, EPA received a comment 

requesting that tractor drivers should be exempt from monitoring when operating tractors with 

enclosed cabs that meet one of the following specifications: 

• ANSI/ASAE S525-1.1 May 1998 Sections 7.1.5., 7.1.7, 7.2.3, and 9, or 

• The requirements listed in the WPS for agricultural pesticides- 40 CFR170.240(d)(5). 

The cab must be equipped with a vapor adsorptive filter containing a minimum of 1000g 

of activated charcoal. The filter must be changed after no more than 50 hours of 

application time. 

The commenter requests that EPA add this language to chloropicrin labels since the language is 

currently on 1,3-D labels. Since the Agency is now relying on sensory irritation as the trigger for 

when respiratory protection is needed, every handler must either put on a respirator or stop work 

regardless of the handler’s task. Therefore drivers in any enclosed cab would be subject to the 

same requirements. 

82 
 Even if EPA still had the initial monitoring requirement the Agency does not currently 

support adding this language to chloropicrin labels because ANSI/ASAE has withdrawn this 

standard due to problems with verifying protective factors. 

 

i. 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. When chloropicrin is used in combination 

with other fumigants such as methyl bromide, iodomethane, and 1,3-D, the mitigation may differ 

somewhat due to the risks associated with the other fumigant; the most stringent mitigation must 

be followed. The following procedures must be followed for all agricultural field and 

greenhouse pre-plant soil applications of chloropicrin:

• 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 

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, then 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) an 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 

chloropicrin have decreased to less than 0.15 ppm, provided that handlers do not 

experience sensory irritation. 

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. 

• Work activities may resume if the following conditions exist provided that the 

appropriate respiratory protection is worn: 

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 but greater than 0.15 ppm, 

o Handlers do not experience sensory irritation while wearing the APR, and 

o Cartridges have been changed. 

83 
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. 

 

Figure 1 provides an illustration of the requirements when handlers cease operations. 

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 0.15 

ppm and NO sensory irritation, 

then

Resume operations. 

Handler activity begins. Handlers 

are NOT wearing APRs. 

84 
Figure 2 provides an illustration of the requirements when handlers put on a respirator. 

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 1.5 ppm. 

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 0.15 ppm BUT below 1.5 

ppm, 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 0.15 ppm and NO sensory 

irritation, then 

Resume operations wearing an 

APR. Air monitoring continues. 

Resume operations without an 

APR or remove respirator. 

Handler activity begins. Handlers 

are NOT wearing APRs. 

85 
 Respiratory Protection Equipment Requirement 

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 chloropicrin concentrations of 1.5 ppm; and if 

concentrations exceed 1.5 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 APR 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. Note that while EPA assumes that a full-face respirator has a protection factor of 50, 

the Agency is keeping the cease-work action level at 1.5 ppm because respirators have not been 

tested for effectiveness against chloropicrin specifically and EPA does not believe handlers 

should continue fumigant operations, even if using respiratory protection, if chloropicrin 

concentrations resulting from the application are near the IDLH of 2 ppm. 

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. Comments suggested that the Agency require organicvapor cartridges. 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 notes that current chloropicrin labels do not permit the use of closed 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 the following 

document, “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” May 14, 2009. 

 As a result of the changes discussed above the amended requirements are listed below: 

86 
• The Agency is requiring full-face respirators with organic-vapor cartridges when 

respirators are necessary. EPA will also consider other APR-cartridge combinations, 

provided written certification of their efficacy against chloropicrin is submitted to the 

Agency. 

• If chloropicrin concentrations exceed 1.5 ppm operations must cease. 

 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 the following document, “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” 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, medical qualification, and training 

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 

on 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 

87 
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: 

“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 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 (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 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.” 

88 
d. 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 

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. 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 off-gassing. New studies currently underway which involve use of high barrier 

89 
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. In order 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 

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 Requirements 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 off-gas 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 Requirements section; therefore the risk to handlers will 

90 
not increase as a result of this modification. EPA considered the suggestion to monitor before 

tarp removal begins; however, because of technical limitations with current technology the 

Agency did not include monitoring as part of the mitigation. As with the respiratory protection 

section, the Agency sees the value in a monitoring program if reliable and accurate devices are 

available and will consider monitoring during Registration Review or sooner if information 

becomes available. 

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 and 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, 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 Requirements 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 

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. 

• 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. 

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• 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. 

e. Entry Restricted Period 

Most of the current chloropicrin labels allow reentry to the treated field by workers 48 

hours after application. When chloropicrin is used in combination with 1,3-D the labels permit 

worker reentry into the treated field 5 days after application. The 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 RED indicated that non-handler entry to perform postapplication (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 chloropicrin 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. 

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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 3, or 

• After tarps are perforated and removed if tarp removal is completed less than 14 days 

after application, see Figure 4, or 

• 48 hours after tarps are perforated if they will not be removed prior to planting, see 

Figure 5, 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 6. 

Figures 3, 4, 5, and 6 provide illustrations of tarp perforation/removal and entry prohibition 

mitigation required for various chloropicrin applications. The intervals depicted are the 

minimum that must be followed. 

Figure 3. Untarped Applications 

Buffer Zone 

Period Ends 

Entry 

Restricted 

Period Ends 

Buffer Zone 

Period 

Begins 

Entry 

Restricted 

Period 

Begins 

Application 

Ends 

Application 

Begins 

48 hours

5 days (120 hours)

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Figure 4. 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 

Restricted 

Period Ends 

Tarp 

Removal 

Begins 

Tarp 

Removal 

Ends 

Application 

Begins 

48 hours 

2 hours 

5 days (120 hours) 

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Figure 5. 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) 

95 
Figure 6. Tarp Bed/Broadcast Applications (Tarps are not perforated until 14 days after 

application) 

Application 

Begins 

Buffer Zone 

Period 

Begins 

Entry 

Restricted 

Period 

Begins 

Application 

Ends 

Buffer Zone 

Period Ends 

Entry 

Restricted 

Period Ends 

48 hours 

Tarp 

Perforation 

& Planting 

5 days (120 hours) 

14 days 

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ii. Other Mitigation 

Below are requirements for FMPs, GAPs, emergency preparedness and response, notice 

to state-lead agencies, training, and community outreach and education 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. 

1. 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 chloropicrin. The practices specified contribute to reducing emissions 

and thereby are expected to reduce potential for worker and bystander exposures. 

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 following document, “SRRD’s Response 

to Post-RED Comments on the Soil Fumigants” May 27, 2009. Based on the comments, the 

Agency has revised some of the GAPs. 

The GAPs outlined in the July 2008 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 Reduction 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 

97 
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. 

Tarps (when tarps are used in chloropicrin 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 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 

The written tarp plan must be included in the site-specific FMP as described in the FMP section. 

This section of the GAPs has not changed from the July 2008 RED. 

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 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. 

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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 

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 the revised language 

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 

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. 

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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 and Soil Moisture 

 In the July 2008 RED the Agency required the soil temperature and soil moisture GAPs 

for all chloropicrin applications, i.e., both shank and drip. After discussions with CMTF, the 

Agency is no longer requiring these GAPs for drip applications. Soil temperature has been 

removed because once the water is applied the soil temperature is cooled by evaporative cooling. 

The soil moisture GAP was removed from drip applications because the soil needs to be below 

field capacity before the application to prevent the potential for the beds to become oversaturated 

during the application, which could potentially cause chloropicrin to leak into the furrows or 

could cause the beds to collapse. Since water is a part of the drip application, the soil moisture is 

brought up to field capacity during the application. As a result soil temperature and soil moisture 

GAPs have been moved to the Chloropicrin Bedded and Broadcast Shank Applications: 

Additional GAPs section. 

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 of the chisel trace 

using press sealers, bed shapers, cultipackers, or by re-shaping (relisting, lifting and 

100 
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.

Chloropicrin Bedded and Broadcast Shank Applications: Additional GAPs

In addition to the GAPs required for all chloropicrin soil fumigation applications, the following 

GAPs apply for injection applications: 

Tarps (when tarps are used in chloropicrin applications) 

• 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. 

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. Soil moisture must be determined by one 

of the following methods: 

o The USDA Feel and Appearance Method for testing (see below). Surface soil generally 

dries rapidly and must not be considered in this determination, or 

o An instrument, such as a tensiometer. 

• 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 

To use the buffers zones tables based on the Wasco, CA data (Tables 5-9), the soil shall contain 

at the time of application enough moisture at 9 inches below the surface. Soil moisture must 

either be measured at ≥ 70% with an instrument (e.g., tensiometer), or meet the following criteria 

defined in the USDA Feel and Appearance method for estimating soil moisture as appropriate for 

the soil texture. 

101 
• For coarse textured soils (fine sand and loamy fine sand) there must be enough moisture 

(75-100 percent available soil water moisture) so that the soil is wet, forms a weak ball, 

loose and aggregated sand grains remain on fingers, darkened color, heavy water staining 

on fingers, will not ribbon. 

• For moderately coarse textured soils (sandy loam and fine sandy loam) there must be 

enough moisture (75-100 percent available soil water moisture) so that the soil is wet, 

forms a ball with a wet outline left on hand, light to medium staining on fingers, makes a 

weak ribbon between the thumb and forefinger. 

• For medium textured soils (sandy clay loam, loam, and silt loam) there must be enough 

moisture (75-100 percent available soil water moisture) so that the soil is wet, forms a 

ball with well-defined finger marks, light to heavy soil/water coating on fingers, ribbons 

between thumb and forefinger. 

• For fine textured soils (clay, clay loam, and silty clay loam) there must be enough 

moisture 75-100 percent available soil water moisture) ) so that the soil is wet, forms a 

ball, uneven medium to heavy soil/water coating on fingers, ribbons easily 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, a local 

extension service or soil conservation service specialist or pest control advisor 

(agriculture consultant) should be consulted for assistance. 

If the field capacity is measured to be between 50-69% with a meter or falls into the USDA Feel 

and Appearance Method category of 50-75% then the buffer zones are based on Tables 12-16. 

• For coarse textured soils (fine sand and loamy fine sand) there must be enough moisture 

(50 to 75 percent available soil water moisture) so the soil is moist, forms 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) there must be 

enough moisture (50 to 75 percent available soil water moisture) so the soil is moist, 

forms 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) there must be enough 

moisture (50 to 75 percent available soil water moisture) so the soil is moist, forms 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) there must be enough 

moisture (50 to 75 percent available soil water moisture) so the soil is moist, forms a 

smooth ball with defined finger marks, light soil/water staining on fingers, ribbons 

between thumb and forefinger. 

102 
• 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, a local 

extension service or soil conservation service specialist or pest control advisor 

(agriculture consultant) should be consulted for assistance. 

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 Untarped-Bedded Applications: The injection point shall be a minimum of 12 inches 

from the nearest final soil/air interface. 

• For Untarped-Broadcast Applications: The injection point shall be a minimum of 10 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 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). 

103 
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. 

Chloropicrin Drip Applications: Additional GAPs

The Agency has made one minor change to the additional GAPs for chloropicrin drip 

applications from the July 2008 RED. This change is in the soil sealing section. The July 2008 

RED required that every drip application was tarped. Since the Agency has received and 

reviewed drip untarp emission studies, EPA has deleted this requirement. 

In addition to the GAPs required for all chloropicrin soil fumigation applications, the following 

GAPs apply for drip applications: 

Soil Preparation 

• Till fields with known plowpans because they can lead to puddling of the fumigant due to 

inadequate soil drainage. 

Product and Dosage 

• Plan the application by calculating the amount of fumigant required at the appropriate 

rate for the crop, acreage and target pest. Fumigant must be metered into the water 

104 
supply line and then passed through a mixing device, such as a centrifugal pump or static 

mixer, to assure proper agitation. 

System Controls and Integrity 

• The irrigation system (main lines, headers, drip tape) must be thoroughly checked for 

leaks before the start of application. Leak detection requires that the irrigation system be 

at full operating pressure. The amount of time needed at full operating pressure will vary 

by irrigation system design. Look for puddling along major pipes (holes in pipes or leaky 

joints), at the top and ends of rows (leaky connection, open drip tape), and on the bed 

surface (damaged drip tape, malfunctioning emitters). Any leaks discovered during the 

pre-application check must be repaired prior to fumigant application. 

• To inject fumigant, use a metering system (such as a positive pressure system, positive 

displacement injection pump, diaphragm pump, or a Venturi system) effectively designed 

and constructed of materials that are compatible with the fumigant and capable of being 

fitted with system interlocking controls. Do not use containers pumps or other equipment 

made of aluminum, magnesium or their alloys as chloropicrin can be corrosive to such 

metals. 

• The system must contain: 

o A functional check valve and low-pressure drain appropriately located on the 

irrigation pipeline to prevent water source contamination and backflow; 

o A functional, automatic, quick-closing check valve to prevent the flow of fluids 

back toward the fumigant container; 

o A functional, normally closed valve located on the intake side of the injection 

point and connected to the system interlock to prevent the fumigant from being 

withdrawn from the supply tank when the irrigation system is either automatically 

or manually shut down; 

o Functional interlocking controls to automatically shut off the fumigant injection 

when the irrigation water flow stops or decreases to the point where fumigant 

distribution is adversely affected. 

Site of Injection and Irrigation System Layout 

• Site of injection must be as close as practical to the area being treated (such as direct 

injection of fumigant into the header pipe/manifold or into an aboveground delivery pipe 

attached to the header). If the fumigant is injected into a main line, make sure the 

irrigation pipe is able to be cleared of all fumigant as the fumigant may pool in low 

sections of the pipe. Also make sure that valves on lateral lines of the main line are 

closed, if these lateral lines lead to areas not being fumigation at the time of the 

application. 

System Flush 

• After application of the fumigant, continue to drip-irrigate the area with water to flush the 

irrigation system. Do not allow the fumigant to remain in the irrigation system after the 

application is complete. The total volume of water, including the amount used for 

flushing the irrigation system, must be adequate to completely remove the fumigant from 

the lines, but should be less than the amount that could over-saturate the beds (bed 

collapse can occur from over-saturation). If common lines are used for both the fumigant 

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application and water seal (if a water seal is applied) these lines must be adequately 

flushed before starting the water seal and/or normal irrigation practices. 

Soil Sealing 

• If tarps are used they must be put in place before the fumigation begins. 

• Tarp edges must be buried along the furrow and at the ends of rows. 

Chloropicrin Tree Replant Application: GAPs 

This section has not changed from the July 2008 RED. 

This application method is used when chloropicrin is applied to individual tree sites in an 

existing orchard where shank or drip application are not possible. 

In addition to the GAPs required for all chloropicrin soil fumigation applications, the following 

GAPs apply for chloropicrin tree replant applications: 

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. 

2. 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 Association14 (i.e., through “Administrative” and “Workplace” controls). The 

 

14 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) 

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Centers for Disease Control provides guidance for developing health and safety plans in 

agricultural settings.15 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 

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.16

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. 

 

15 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 

16 United States Department of Labor, Occupational Safety and Health Administration (2008) Lookback Reviews 

available at http://www.osha.gov/dea/lookback.html 

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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 

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 chloropicrin. 

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 

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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 

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 chloropicrin training program) 

 General site information 

3⁄4 Application block location, 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 (schools, state licensed daycare 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 

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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 

than certified applicator) 

3⁄4 Equipment/methods used to perforate tarps 

3⁄4 Schedule and target dates for perforating 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 label (lbs ai/acre) 

3⁄4 Application block size from lookup table on 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 perforators/removers, irrigators) for complying with 

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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 

 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). 

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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 cut 

3⁄4 Date tarps were removed 

 Complaint details (if applicable) 

3⁄4 Person filing complaint (e.g., on-site handler, person off-site) 

3⁄4 If off-site person, name, address, and phone number of person filing complaint 

3⁄4 Description of control measures or emergency procedures followed after complaint 

 Description of incidents, equipment failure, or other emergency and emergency procedures 

followed (if applicable) 

 Details of elevated air concentrations monitored on-site (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) 

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 When using a direct read instrument: 

• Sample date and time 

• Handler task/activity 

• Handler location 

• Air concentration 

• Sampling method 

 Date of 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 (Appendix 

E), 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

The Agency has provided a template in Appendix E. This template is specific for methyl 

bromide. A chloropicrin template will be provided at a later date. 

3. Site Specific Management and Response 

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 

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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 (see the Community Outreach and 

Education Programs section) to first responders in high-fumigant use areas and areas with 

significant interface between communities and fumigated fields. In addition, for situations in 

which people, homes, or other structures are in 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. 

 

a. First Responder Education 

EPA is requiring registrants through their community outreach and education programs 

see Community Outreach and Education Programs 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. 

b. Emergency Preparedness and Response 

Emergency Preparedness and Response Considerations for the 2008 RED 

Prior to the 2008 RED 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 

114 
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. 

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 or 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, e.g., residential properties 

and businesses, not under the control of the owner/operator of the application block may be to 

the buffer zone. 

115 
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 amended RED 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 certain 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 

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, which 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 generally 

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, the EPA has included an exception for 

application blocks so fields with the smallest required buffer (25 feet) 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 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 concentrations. 

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. 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 

116 
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. 

While the Agency is modifying the procedures for monitoring buffer zones because of 

technological limitations of currently available devices for chloropicrin that are not practical or 

reliable for field use, the Agency does 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 will rely on sensory 

indicators (e.g., eye and/or nasal irritation) to trigger a response instead of using tubes. 

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 minimum buffer zone size, then the Emergency 

Preparedness and Response requirements are not applicable. Also, if all of the land within 300 

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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. 

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 three 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. 

• The person(s) 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(s) 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 any 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 

below 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: 

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o The general location of the application block, 

o Fumigant(s) applied including the active ingredient, name of the fumigant 

product(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 who to call if you believe you 

are being exposed (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: 

• 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. 

 

Figure 7. Example Site Map for Informing Neighbors 

Treated field 

Buffer zone 

45 ft 

288 ft 

100 ft 

125 ft 

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 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. 

4. 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 also how and when these 

agencies want applicators to provide to them the following information: 

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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 

 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. 

5. Soil Fumigation Training for Applicators and 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 

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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 

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, training 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, 

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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. 

Pesticide labels will state that “Before applying the product, the certified applicator 

supervising that application must successfully complete, within the last 36 months, a chloropicrin 

training program made available by the registrant. The FMP (see details elsewhere on this label) 

must document when and where the training program 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.” 

a. 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, American 

Association of 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 

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the DCI that accompanies this amended 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 

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 

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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. 

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.

b. 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 following 

language must be added to labels. 

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“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.” 

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. 

6. 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 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. This outreach and education will 

address the risk of acute bystander exposure by educating community members in high-use areas 

about buffer zones and their characteristics and purpose; the importance of not entering these 

zones; how to recognize early signs of fumigant exposure, and how to respond appropriately in 

case of an incident. The first responder education discussed in the First Responder Education 

section is a significant part of this program. 

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 

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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 

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 chloropicrin, (4) appropriate steps to take to mitigate 

exposures to chloropicrin, (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 amendment, 

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 

127 
proposals for identifying high soil fumigant-use areas, based on additional data sources and 

alternate approaches identified by the registrant(s) and other stakeholders. 

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 both 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 first responder 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 

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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 chloropicrin fumigant exposure, (2) how to treat 

chloropicrin fumigant exposures, and (3) how chloropicrin fumigant exposures differ from other 

pesticide exposures as well as (4) copies of material safety data sheet(s) for the fumigant applied. 

Training materials can take a number of forms, including: brochures, fact sheets, CDs, videos, 

web-based training materials, etc., 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 

process described below. 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 chloropicrin 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 chloropicrin have been 

identified by the Agency using EPA proprietary data. [Although state-level data are available 

from USDA’s National Agricultural Statistics Service (NASS), EPA proprietary data are more 

robust.] Second, the high-use counties for chloropicrin 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 Chloropicrin: The Agency is defining states with 

high usage of chloropicrin as those states where, on average, more than 100,000 lbs of 

chloropicrin or methyl bromide. (Since chloropicrin is often used with methyl bromide for preplant soil uses, the states with greater than 100,000 lb of methyl bromide applied annually are 

also included in the list.) To determine those states where, on average, more than 100,000 lbs of 

chloropicrin or methyl bromide have been applied annually, the Agency obtained data on the 

average number of pounds of both chloropicrin and methyl bromide 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 following memo, “Process for Defining High-Use Fumigation Areas at the 

State and County Levels (DP# 364647)” May 14, 2009 and supporting documentation located in 

the chloropicrin docket. The states identified for chloropicrin and methyl bromide are 

Washington, Oregon, Idaho, South Carolina, Georgia, North Carolina, California, Florida, and 

Michigan. 

Step 2: Identifying Counties with High Use of Chloropicrin: 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 chloropicrin 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 

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sites of chloropicrin from the publicly available 2007 USDA Census of Agriculture. Crop 

acreages for each of the major use sites for chloropicrin should be obtained for each the major 

use sites for chloropicrin and then summed by county. All counties making up at least the top 

90% of acreage in a state are considered high-use areas. 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 1,000,000 lb of chloropicrin applied annually. The 

crops identified for chloropicrin are cantaloupes, peppers, squash, strawberries, sugar beets, 

tobacco, 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 chloropicrin 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 Agency’s memo “Process for Defining 

High-Use Fumigation Areas at the State and County Levels (DP# 364647)” May 

14, 2009, which is located in the chloropicrin at docket. 

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 Agency’s memo 

“Process for Defining High-Use Fumigation Areas at the State and County Levels 

(DP# 364647)” May 14, 2009, which is located in the chloropicrin at docket. 

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 

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appropriate first responder entities are being targeted and that the information being provided to 

first responders is both useful and presented appropriately. 

iii. Environmental Risk Mitigation 

In the July 2008 RED, EPA addressed the concerns for both aquatic and terrestrial risks 

which are mentioned in Section III.C. 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. 

 

The July 2008 RED discussed EPA’s concern regarding chloropicrin’s potential to leach 

into ground and surface water. Since chloropicrin has been detected in ground water, the Label 

Review Manual indicates that the following language should be added to chloropicrin labels, 

“Chloropicrin is known to leach through soil into ground water under certain conditions as a 

result of label use. This chemical may leach into ground water if used in areas where soils are 

permeable, particularly where the water table is shallow.” In the July 2008 RED, EPA deviated 

from the Label Review Manual language because dissipation of chloropicrin 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 chloropicrin’s most important route of dissipation, EPA required the following 

language in the July 2008 RED taking these factors into consideration, “While chloropicrin has 

certain properties and characteristics in common with chemicals that have been detected in 

groundwater (chloropicrin 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 chloropicrin’s volatility. 

While the Agency believes that volatilization is this chemical’s most important route of 

dissipation, it is being removed from the ground water statement because volatilization is 

addressed in other areas of the mitigation package. The new language will state, “Chloropicrin 

has certain properties and characteristics in common with chemicals that have been detected in 

groundwater (chloropicrin is highly soluble in water and has low adsorption to soil).” 

 EPA also discussed, in the July 2008 RED, the potential for chloropicrin to leach into 

ground water when tarps are used in broadcast applications. Falling temperatures typically found 

in the late afternoon and evening would not promote dissipation of remaining chloropicrin under 

the perforated tarp and rainfall may cause remaining chloropicrin under the perforated tarp to 

leach into ground water. 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 chloropicrin 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 

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keeping this requirement in the amended RED. The language is included in the Tarp Perforation 

and Removal section of this document. 

 The July 2008 RED also discussed the potential for chloropicrin to leach into ground 

water and surface water if a rainfall event occurs after an untarped application. Chloropicrin 

may impact surface water quality due to runoff of rain water. This is more likely for poorly 

draining soils and soils with shallow ground water. Chloropicrin triggers the following language 

according to the Label Review Manual, 

“Chloropicrin is known to leach through soil into ground water under certain conditions 

as a result of label use. This chemical may leach into ground water if used in areas where 

soils are permeable, particularly where the water table is shallow. Chloropicrin may also 

impact surface water quality due to runoff of rain water. This is especially true for poorly 

draining soils and soils with shallow ground water. This chemical is classified as having 

high potential for reaching surface water via runoff several days after application. 

Leaching and runoff of this product will be reduced by avoiding applications when 

rainfall is forecasted to occur within 48 hours.” 

 The Agency modified this language in the July 2008 RED due to the importance of soil 

moisture and chloropicrin’s volatility. The Agency required the following language in the July 

2008 RED, “For untarped applications of chloropicrin, potential leaching into ground water 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 

poorly draining soils. The revised statement is based on information presented in a 2007 article 

by Zhang and Wang.17

EPA received also comments from the CMTF during the post-RED comment period. 

The comments have been addressed in the following documents: “Further Response to Public 

Comments on the 7/9/08 Completed Chloropicrin RED” (March 3, 2009) and “Evaluation of, 

‘Probabilistic Modeling of Chloropicrin Exposure to Aquatic Nontarget Organisms’” (March 3, 

2009). 

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 the revised label statements and for details on the studies. 

 

17 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. 

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b. Residential Structure Warning Agent Use Mitigation 

Details on chloropicrin’s use as a warning agent prior to sulfuryl fluoride applications are 

included in the Agency’s revised human health risk assessment as listed in Section III.B of this 

document. 

 The Agency reviewed monitoring studies completed by the California Air Resources 

Board (CARB) of the California Environmental Protection Agency. These studies directly 

monitored chloropicrin. The results of these studies are below the Agency’s level of concern for 

bystanders. 

i. Occupational Risk Mitigation 

1. Respiratory Requirements 

 When chloropicrin is used as a warning agent prior to sulfuryl fluoride fumigations the 

July 2008 RED required that handlers wear respiratory protection, and that each handler was 

were fit tested, trained, and medically examined. The July 2008 RED, did not require 

monitoring because the Agency did not anticipate that the level of chloropicrin would exceed 1.5 

ppm based on conservative estimates of labeled use rates. 

 The Agency received comments requesting that this use be reviewed during the 

Registration Review of sulfuryl fluoride, and also that additional mitigation for chloropicrin was 

not necessary for this use. Other commenters asked EPA to clarify the type of respiratory 

protection needed for this use. 

 Based on current data EPA is not changing the mitigation required in the July 2008 RED. 

Respiratory protection is still required and handlers must be fit-tested, trained and medically 

examined. The Agency has listed acceptable respiratory protection devices and cartridges in the 

label table in Section V of this document. 

c. Chloropicrin Antimicrobial Use Mitigation 

For details on the chloropicrin human health risk assessment for antimicrobial uses, 

please refer to the revised occupational and residential/bystander assessment described in Section 

III.B of this document. 

The July 2008 RED required that the antimicrobial uses of chloropicrin are subject only 

to the mitigation listed below. The Agency is only making one change to the Air Concentration 

section below to make the concentration level consistent with the 0.15 ppm level discussed in the 

Respiratory Requirements section. The rest of the mitigation remains the same as the July 2008 

RED. 

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i. Bystander Risk Mitigation 

 The revised risk assessment indicates the potential for acute bystander exposure to 

chloropicrin when it is used for remedial wood treatment. The Agency believes that requiring 

the following will reduce this potential below the Agency’s level of concern: 

• Plug the pre-drilled holes immediately after chloropicrin applications; 

• Do not treat structures/beams indoors; and 

• Do not drill an application hole through seasoning checks to apply product. If the hole 

intersects a check, plug the hole and drill another. If more than 2 treatment holes 

intersect an internal void or rot pocket, redrill the holes farther up the pole into relatively 

solid wood. 

ii. Occupational Risk Mitigation 

The Agency’s revised risk assessment indicates the potential for handler inhalation 

during the transfer of chloropicrin into vials and during the pouring/injection of chloropicrin into 

pre-drilled holes. To mitigate these risks, the Agency is requiring that applicators and handlers 

wear a full face tight-fitting or loose-fitting helmet or hood style NIOSH/MSHA approved 

respirator at all times when handling chloropicrin during the transfer of the product into vials and 

during the pouring/injecting of chloropicrin into pre-drilled holes. However, use of a respirator 

is not being proposed for application of the vials once they are filled. 

1. Air Concentration 

 If a spill or leak were to occur, some of the current labels require respiratory protection if 

air concentrations of chloropicrin exceed 0.3 ppm at any time, while others require respiratory 

protection if the air concentrations exceed 0.1 ppm. To rectify these differences, the Agency is 

requiring that unprotected persons not be permitted entry into a spill area or clean-up area until 

the concentration of chloropicrin is measured with a device to be less than 0.15 ppm. 

2. Respiratory Requirements 

 Applicators and handlers that directly pour or inject chloropicrin into timbers or fill vials 

must wear a full-face tight-fitting, or loose-fitting helmet or hood style NIOSH/MSHA approved 

respirator when handling chloropicrin. Since the Agency is requiring a full-face respirator and 

eyes are covered, and not a half-face respirator, all references to wearing goggles and/or full face 

shields for this application use must be removed from the labels. 

Applicators and handlers that are involved in the vial application method are not required 

to wear a respirator (as the vials are already filled and capped). However, at least one air rescue 

device (e.g., SCBA) and air-purifying respirators and cartridges for each handler must be 

immediately available on-site in case of a spill or an emergency. 

In order to ensure that the respiratory protection EPA is assuming is being achieved for 

this use, respiratory requirements for chloropicrin will include fit testing, respirator training, and 

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annual medical evaluation. These requirements are the same as detailed in the Respiratory 

Protection section for pre-plant soil fumigation. 

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 

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, chloropicrin may be subjected to additional screening and/or testing to 

better characterize effects related to endocrine disruption. 

3. Endangered Species Considerations 

 The Agency has completed an endangered species risk assessment of the potential effects 

of chloropicrin on the Federally-listed threatened California red-legged frog. After completing 

the analysis of the effects of chloropicrin on the California red-legged frog, the Agency 

concluded that chloropicrin is “likely to adversely effect” this species.18 Following a Biological 

Opinion by the U.S. Fish and Wildlife Service, the Agency may require additional mitigation. 

D. Conclusions 

The Agency has determined that products containing chloropicrin are eligible for 

reregistration 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. 

 

18 http://www.epa.gov/espp/litstatus/effects/redleg-frog/index.html#chloropicrin 

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V. What Registrants Need to Do 

EPA recognizes that the extent of the mitigation needed for chloropicrin 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 Chloropicrin 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: GAPs, rate reductions, 

limitations on use sites, new handler protection measures, tarp cutting and 

removal restrictions, extended worker re-entry restrictions, 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 chloropicrin 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. 

136 
 A. Manufacturing Use Products 

 

 1. Additional Generic Data Requirements 

The generic data base supporting the reregistration of chloropicrin 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. Data Requirements for Chloropicrin Soil Uses 

 i. Human Health 

 1. Toxicity

There are no data requirements. 

 2. Residue Chemistry

There are no data requirements. 

 3. Occupational and Residential Exposure

See chart below. 

OPPTS Guideline 

Number 

Data Requirement Study type 

835.8100 

Field volatility from soil, to determine 

flux for modeling purposes for 

applications using water seals ORE 

835.8100 

Field volatility from soil, to determine 

flux for modeling purposes for untarp 

bed shank applications. ORE 

835.8100 - Field volatility from soil

Volatility studies are required for chloropicrin’s soil uses to determine flux for modeling 

purposes. These studies will allow the Agency determine appropriate buffer zones when water 

seals are used. Data for the untarp bed shank application will enable a more refined inhalation 

risk assessment to be completed for buffer zone determinations. 

137 
 ii. Environmental Fate and Ecological Effects 

 1. Environmental Fate 

There are no data requirements. 

 2. Ecological Effects 

See chart below. 

OPPTS Guideline 

Number 

Data Requirement Study type 

Special Study Avian Acute Inhalation ECO 

870.1300 Acute Inhalation Toxicity Test-Rat TOX 

850.1075 Acute Fish Toxicity-bluegill and 

rainbow trout ECO 

850.1010 Acute Aquatic Invertebrate Toxicity ECO 

850.1075 Acute Marine/Estuarine Fish ECO 

850.1025 Acute Marine/Estuarine Mollusk ECO 

850.1035 Acute Marine/Estuarine Shrimp ECO 

850.4225 Seed Germination/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 

Special Study—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. Since the risk assessment for terrestrial 

wildlife is focused on inhalation and this study will provide actual inhalation data rather than an 

estimation based on acute oral data, it is of even higher priority than the acute oral study. 

870.1300—Acute inhalation toxicity test – rat. 

The existing study (MRID 45117902) is classified by HED as Acceptable/Non-guideline. The 

7/25/00 DER and 1/31/05 Revised HED Human Health Risk Assessment state: “The LC50 

calculated for the study should not be considered to be a true LC50 for chloropicrin. Due to the 

sacrifice of all live animals at day 3 of the study instead of day 14, and too large of exposure 

particle sizes, the true LC50 could be lower.” Thus, a new study will enable an improved wild 

mammal risk assessment with reduced uncertainty. 

138 
850.1075—Acute Fish Toxicity – bluegill and rainbow trout. 

The risk assessment is currently relying on supplemental data. Flow-through studies with 

measured concentrations will greatly reduce uncertainty. 

850.1010—Acute aquatic invertebrate toxicity. 

The risk assessment is currently relying on supplemental data. Flow-through studies with 

measured concentrations will greatly reduce uncertainty. 

850.1075—Acute Marine/Estuarine Fish. 

Given the use patterns of chloropicrin, marine/estuarine species could be exposed. This study 

will enable a risk assessment specific for marine/estuarine species exposure. 

850.1025—Acute Marine/Estuarine Mollusk. 

Given the use patterns of chloropicrin, 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. 

850.1035—Acute Marine/Estuarine Shrimp. 

Given the use patterns of chloropicrin, marine/estuarine species could be exposed. This study 

will enable a risk assessment specific for marine/estuarine species exposure. One toxicity value 

is available from a study published in the scientific literature, but it is from a static study without 

measured concentrations. 

850.4225—Seed Germination/Seedling Emergence – Tier II. 

Chloropicrin 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. 

850.4250—Vegetative Vigor – Tier II. 

Chloropicrin has at least some phytotoxicity on the treatment site, based on label and open 

literature information. This study will enable the assessment of risk to non-target terrestrial 

plants off-site. 

850.4400—Aquatic Plant Growth – Tier II. 

Chloropicrin has at least some phytotoxicity on the treatment site, based on label and open 

literature information. This study will enable the assessment of risk to non-target aquatic plants 

off-site. 

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850.3020—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. 

 iii. Other 

OPPTS Guideline 

Number 

Data Requirement Study type 

Special Community Outreach and Education 

Programs Special 

Special Training for Applicators Supervising 

Fumigations Special 

Special Training Materials for Handlers Special 

Special Buffer Zone Posting Signs Special 

Special Study - Community Outreach and Education Programs 

The Agency is requiring registrants to develop and implement community outreach and 

education programs, including programs for first responders, to address these needs. Community 

outreach and education 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, and (7) 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. 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. 

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 

140 
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 

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 (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: 

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The buffer zone sign must include the 

following: 

-- Do not walk sign 

-- "DO NOT ENTER/NO ENTRE," 

-- “Chloropicrin 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. 

b. Chloropicrin Warning Agent Uses 

There are no data requirements. 

 c. Antimicrobial Uses 

There are no data requirements.

2. Labeling for Manufacturing-Use Products 

 To ensure compliance with FIFRA, manufacturing use product (MUP) labeling must be 

revised to comply with all current EPA regulations, PR Notices, and applicable policies. 

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 

142 
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. 

143 
Labeling Changes Summary Table for Chloropicrin 

 In order to be eligible for reregistration, all product labels must be amended to 

incorporate the risk mitigation measures outlined in Section IV. Also, various use and safety 

information will be included in the labeling of all end-use products containing chloropicrin. The 

following tables describe how language on the labels should be amended. 

Table 19: Summary of Labeling Changes for All Chloropicrin Uses (except antimicrobial 

use) 

Description Amended Labeling Language Placement on 

Label 

Manufacturing Use Products 

For all 

Manufacturing Use 

Products 

 

“Only for formulation into a fumigant for the following uses: pre-plant soil fumigant in 

agricultural fields and commercial greenhouses, tree replant, warning agent prior to 

sulfuryl fluoride residential structure fumigations, and remedial wood treatment.” 

Structural greenhouse and/or enclosed space fumigation uses have been cancelled and must 

be deleted from end-use product labels. On end-use product labels, the directions for use 

when chloropicrin is used as a warning agent before sulfuryl fluoride structural 

fumigations must be kept separate from the directions for use for the pre-plant soil use. 

“Chloropicrin 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.” 

“Chloropicrin cannot be formulated into end-use products labeled for pre-plant or pretransplant 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.” 

. 

Directions for Use 

144 
Contents of Sign

-- "DO NOT ENTER/NO ENTRE," 

-- "Chloropicrin [Name of Product] 

Fumigant BUFFER ZONE,” 

-- 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 

pre-plant soil and 

structural warning 

agent 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 

chloropicrin 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; 

In the 

Precautionary Use 

Section 

145 
• 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 

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).” 

When chloropicrin is 

used as a warning 

prior to sulfuryl 

fluoride residential 

structure 

fumigations. 

 

Fumigation Handlers 

“All persons participating in the application of chloropicrin when it is used as a warning 

agent prior to sulfuryl fluoride residential structure fumigations are pesticide handlers.” 

In the 

Precautionary Use 

Section 

For pre-plant soil 

use. 

Supervision of 

Handlers 

 “For all applications except water run: 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 water-run applications (e.g., drip), the certified applicator must be at the fumigation 

site to start the application including set-up, calibration, and initiation of the application. 

The certified applicator may leave the site but must return at least every two hours to 

visually inspect the equipment to ensure proper functioning and must directly supervise all 

WPS-trained handlers on-site until the fumigation has stopped being delivered/dispersed 

into the soil. WPS-trained handlers may perform the monitoring functions in place of the 

certified applicator, but must be under the supervision of the certified applicator and be 

able to communicate with the certified applicator at all times during monitoring activities 

via cell phone or other means. The results of monitoring activities must be captured in the 

FMP’s post-application summary report. 

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 

Directions for Use 

Under the section 

“protection for 

handlers” 

146 
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.” 

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” 

When chloropicrin is 

used as a warning 

prior to sulfuryl 

fluoride residential 

structure fumigations 

“The employer of any handler participating in chloropicrin application prior to sulfuryl 

fluoride residential structure fumigation 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” 

Air-rescue device 

availability for preplant soil uses. 

“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 must have the appropriate respirator and cartridges available 

and these handlers must be fit-tested, trained, and medically examined.” 

Directions for Use 

Under the section 

“protection for 

handlers” 

Respirator 

availability when 

chloropicrin is used 

as a warning agent 

prior to sulfuryl 

fluoride residential 

structure 

fumigations. 

“The fumigation handler employer must make sure that enough air-purifying respirators 

and appropriate cartridges of the type specified in the PPE section of this labeling are 

immediately available to all persons performing fumigant handling activities.” 

Directions for Use 

Under the section 

“protection for 

handlers” 

PPE Requirements 

Established by the 

RED for all 

Chloropicrin 

formulations except 

those formulated 

with methyl bromide 

or iodomethane and 

except when 

chloropicrin is used 

“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 application block, 

• Shoes and socks for all other handlers, 

• Chemical-resistant gloves when handling liquid, 

Immediately 

following/below 

Precautionary 

Statements: 

Hazards to 

Humans and 

Domestic Animals 

147 
as a warning prior to 

sulfuryl fluoride 

residential structure 

fumigations. 

(for formulations that 

contain methyl 

bromide see the 

amended methyl 

bromide RED and for 

iodomethane see 

approved labels)

• 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 at minimum either: 

• a full-face respirator with an organic-vapor-removing cartridge with a prefilter 

approved for pesticides (MSHA/NIOSH approval number prefix TC-23C), or 

• a full-face respirator with a canister approved for pesticides (MSHA/NIOSH 

approval number prefix TC-14G). 

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.” 

PPE Requirements 

Established by the 

RED when 

chloropicrin is used 

as a warning prior to 

sulfuryl fluoride 

residential structure 

fumigations 

“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 application block, 

• 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) 

• At least a half-face, full-face, or helmet/hood style respirator with 

o an organic-vapor-removing cartridge with a prefilter approved for 

pesticides (MSHA/NIOSH approval number prefix TC-23C), or 

o a canister approved for pesticides (MSHA/NIOSH approval number 

prefix TC-14G).” 

Immediately 

following/below 

Precautionary 

Statements: 

Hazards to 

Humans and 

Domestic Animals 

For pre-plant soil 

use. 

Respiratory 

Protection and Stop 

Work Triggers for all 

Chloropicrin 

Formulations except 

methyl bromide or 

iodomethane (for 

formulations with 

methyl bromide see 

the Amended RED, 

or iodomethane see 

approved labels. 

“Respiratory Protection and Stop Work Triggers: The following procedures must be 

followed to determine whether respiratory protection is required or if operations must 

cease for any person performing a fumigant handling task as stated in this labeling. 

• If at any time any handler experiences sensory irritation (tearing, burning of the 

eyes or nose) then either : 

o An air-purifying respirator 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 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 using monitoring devices to monitor air concentration levels, a direct 

reading detection device, such as a Matheson-Kitagawa, Dräger, or Sensidyne 

device must be used. The devices must have a sensitivity of at least 0.15 ppm for 

chloropicrin. 

• When respirators are worn, then 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 

Directions for Use 

148 
respirator, or (2) an 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 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 can resume if the following conditions exist provided that the 

appropriate respiratory protection is worn: 

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 but are 

greater than 0.15 ppm, 

o Handlers do not experience sensory irritation while wearing the airpurifying respirator, and 

o Cartridges have been changed. 

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.” 

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 

other laundry.” 

“Discard clothing and other absorbent materials that have been drenched or heavily 

contaminated with this product’s concentrate. Do not reuse them.” 

Precautionary 

Statements: 

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 who 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” 

PPE Requirements 

Established by the 

RED

When chloropicrin is 

used as a warning 

prior to sulfuryl 

fluoride residential 

structure 

“Respirator fit testing, medical qualification, and training 

Employers must ensure that all fumigant handlers are: 

• 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 

Directions for Use 

Under the section 

“Protection for 

Handlers” 

149 
fumigations. 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.” 

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 Activities 

sections. 

• If tarps will be removed before planting, tarp removal must not begin until at least 

2 hours after tarp perforation is complete. 

• 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–application 

summary report 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.” 

Directions For Use 

150 
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 Entry Restricted 

Period and Notification sections 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 

14 days after application. 

NOTE: see Tarp Perforation and Removal section on this labeling for requirements about 

when tarps are allowed to be perforated.” 

Directions for Use 

under the heading 

“Entry Restricted 

Period and 

Notification” 

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," 

-- "Chloropicrin 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)” 

Directions 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 (when tarps are used in chloropicrin applications) 

• A written tarp plan must be developed and included in the FMP. The plan must 

include: 

Directions for Use 

under “Mandatory 

Good Agricultural 

Practices” 

151 
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 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. 

• 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 offsite 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 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 

152 
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 of 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.

Chloropicrin Bedded and Broadcast Shank Applications: Additional GAPs

In addition to the GAPs required for all chloropicrin soil fumigation applications, the 

following GAPs apply for injection applications: 

Tarps (when tarps are used in chloropicrin applications) 

• 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. 

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. Soil moisture must be determined 

by one of the following methods: 

o The USDA Feel and Appearance Method for testing. Surface soil generally dries 

rapidly and must not be considered in this determination, or 

o An instrument, such as a tensiometer. 

• 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 

To use the buffers zones tables based on the Wasco, CA data (Tables 5-9 in the Amended 

RED), the soil shall contain at the time of application enough moisture at 9 inches below 

the surface. Soil moisture must either be measured at ≥ 70% with an instrument (e.g., 

tensiometer), or 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) there must be enough 

moisture (75-100 percent available soil water moisture) so that the soil is wet, 

forms a weak ball, loose and aggregated sand grains remain on fingers, darkened 

color, heavy water staining on fingers, will not ribbon. 

153 
• For moderately coarse textured soils (sandy loam and fine sandy loam) there 

must be enough moisture (75-100 percent available soil water moisture) so that 

the soil is wet, forms a ball with a wet outline left on hand, light to medium 

staining on fingers, makes a weak ribbon between the thumb and forefinger. 

• For medium textured soils (sandy clay loam, loam, and silt loam) there must be 

enough moisture (75-100 percent available soil water moisture) so that the soil is 

wet, forms a ball with well-defined finger marks, light to heavy soil/water coating 

on fingers, ribbons between thumb and forefinger. 

• For fine textured soils (clay, clay loam, and silty clay loam) there must be enough 

moisture 75-100 percent available soil water moisture) ) so that the soil is wet, 

forms a ball, uneven medium to heavy soil/water coating on fingers, ribbons 

easily 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, a local extension service or soil 

conservation service specialist or pest control advisor (agriculture consultant) 

should be consulted for assistance. 

If the field capacity is measured to be between 50-69% with a meter or falls into the USDA 

Feel and Appearance Method category of 50-75% then the buffer zones are based on 

Tables 12-16 in the Amended RED. 

• For coarse textured soils (fine sand and loamy fine sand) there must be enough 

moisture (50 to 75 percent available soil water moisture) so the soil is moist, 

forms 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) there 

must be enough moisture (50 to 75 percent available soil water moisture) so the 

soil is moist, forms 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) there must be 

enough moisture (50 to 75 percent available soil water moisture) so the soil is 

moist, forms 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) there must be enough 

moisture (50 to 75 percent available soil water moisture) so the soil is moist, 

forms 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, a local extension service or soil 

conservation service specialist or pest control advisor (agriculture consultant) 

154 
should be consulted for assistance. 

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 Untarped-Bedded Applications: The injection point shall be a minimum of 12 

inches from the nearest final soil/air interface. 

• For Untarped-Broadcast Applications: The injection point shall be a minimum of 10 

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 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). 

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 

155 
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. 

Chloropicrin Drip Applications: Additional GAPs

In addition to the GAPs required for all chloropicrin soil fumigation applications, the 

following GAPs apply for drip applications: 

Soil Preparation 

• Till fields with known plowpans because they can lead to puddling of the fumigant 

due to inadequate soil drainage. 

Product and Dosage 

• Plan the application by calculating the amount of fumigant required at the 

appropriate rate for the crop, acreage and target pest. Fumigant must be metered 

into the water supply line and then passed through a mixing device, such as a 

centrifugal pump or static mixer, to assure proper agitation. 

System Controls and Integrity 

• The irrigation system (main lines, headers, drip tape) must be thoroughly checked 

for leaks before the start of application. Leak detection requires that the irrigation 

system be at full operating pressure. The amount of time needed at full operating 

pressure will vary by irrigation system design. Look for puddling along major 

pipes (holes in pipes or leaky joints), at the top and ends of rows (leaky 

connection, open drip tape), and on the bed surface (damaged drip tape, 

malfunctioning emitters). Any leaks discovered during the pre-application check 

must be repaired prior to fumigant application. 

• To inject fumigant, use a metering system (such as a positive pressure system, 

positive displacement injection pump, diaphragm pump, or a Venturi system) 

effectively designed and constructed of materials that are compatible with the 

fumigant and capable of being fitted with system interlocking controls. Do not 

use containers pumps or other equipment made of aluminum, magnesium or their 

alloys as chloropicrin can be corrosive to such metals. 

• The system must contain: 

o A functional check valve and low-pressure drain appropriately located 

on the irrigation pipeline to prevent water source contamination and 

backflow; 

o A functional, automatic, quick-closing check valve to prevent the flow of 

fluids back toward the fumigant container; 

o A functional, normally closed valve located on the intake side of the 

injection point and connected to the system interlock to prevent the 

fumigant from being withdrawn from the supply tank when the irrigation 

system is either automatically or manually shut down; 

o Functional interlocking controls to automatically shut off the fumigant 

156 
injection when the irrigation water flow stops or decreases to the point 

where fumigant distribution is adversely affected. 

Site of Injection and Irrigation System Layout 

• Site of injection must be as close as practical to the area being treated (such as 

direct injection of fumigant into the header pipe/manifold or into an aboveground 

delivery pipe attached to the header). If the fumigant is injected into a main line, 

make sure the irrigation pipe is able to be cleared of all fumigant as the fumigant 

may pool in low sections of the pipe. Also make sure that valves on lateral lines 

of the main line are closed, if these lateral lines lead to areas not being fumigation 

at the time of the application. 

System Flush 

• After application of the fumigant, continue to drip-irrigate the area with water to 

flush the irrigation system. Do not allow the fumigant to remain in the irrigation 

system after the application is complete. The total volume of water, including the 

amount used for flushing the irrigation system, must be adequate to completely 

remove the fumigant from the lines, but should be less than the amount that could 

over-saturate the beds (bed collapse can occur from over-saturation). If common 

lines are used for both the fumigant application and water seal (if a water seal is 

applied) these lines must be adequately flushed before starting the water seal 

and/or normal irrigation practices. 

Soil Sealing 

• If tarps are used they must be put in place before the fumigation begins. 

• Tarp edges must be buried along the furrow and at the ends of rows. 

Chloropicrin Tree Replant Application: GAPs 

This application method is used when chloropicrin is applied to individual tree sites in an 

existing orchard where shank or drip application are not possible. 

In addition to the GAPs required for all chloropicrin soil fumigation applications, the 

following GAPs apply for chloropicrin tree replant applications: 

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.” 

For pre-plant soil 

use. 

“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 

In the Directions 

for Use for Preplant soil 

157 
Site-Specific 

Fumigation 

Management Plans. 

application block (i.e., a greenhouse or field or portion of a field treated with a fumigant in 

any 24-hour period). In addition, an agricultural 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 chloropicrin training program) 

 General site information 

3⁄4 Application block location, 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 daycare 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 than 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 label (lbs ai/acre) 

3⁄4 Application block size from lookup table on 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, 

fumigation under 

the heading, “SiteSpecific 

Fumigation 

Management Plan 

(FMP)” 

158 
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 (if applicable) 

 Description of who, when, where, and procedures for monitoring buffer zone 

perimeter 

3⁄4 Response information for neighbors (if applicable) 

 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 perforators/removers, irrigators) 

for complying with label requirements (e.g., buffer zone location, buffer zone 

start/stop times, timing of tarp perforation 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: (if applicable) 

 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 

 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 

159 
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). 

The employer of fumigant handlers must make the FMP available to each of their handler 

employees 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 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. The summary must include the actual date of the 

application, application rate, and size of application block fumigated. 

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) 

3⁄4 Person filing complaint (e.g., on-site handler, person off-site) 

3⁄4 If off-site person, name, address, and phone number of person filing complaint 

3⁄4 Description of control measures or emergency procedures followed after 

complaint 

 Description of incidents, equipment failure, or other emergency and emergency 

procedures followed (if applicable) 

 Details of elevated air concentrations monitored on-site (if applicable) 

3⁄4 Location of elevated air concentration levels 

160 
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: 

• Sample date and time 

• Handler task/activity 

• Handler location 

• Air concentration 

• Sampling method 

 Date of buffer zone sign removal 

 Any deviations from the FMP 

The certified applicator who supervised the fumigation and the owner/operator of the 

agricultural establishment where the fumigation took place must keep a signed copy of the 

site-specific FMPs and the post-application summary record for at least 2 years following 

the application and must make them available, upon request, to Federal, state, tribal, and/or 

local enforcement personnel.” 

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 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 Figures A and B for further explanation.) See exception 

provided in the “Buffer zone proximity” section. 

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. 

• To reduce the potential for off-site movement from multiple fumigated fields, buffer 

zones from multiple chloropicrin 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. 

• Emergency preparedness and response measures have been implemented if there are 

In the Directions 

for Use for Preplant soil 

fumigation under 

the heading 

“General Buffer 

Zone 

Requirements” 

161 
homes, businesses, or property not within the control of the fumigator within 300 feet 

of each buffer zone. 

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. 

• Bus stops or other locations where persons wait for public transit are not permitted 

within the buffer zone. 

• See the 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 the 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,

3. The occupants provide written agreement that they will voluntarily vacate the 

buffer zone during the entire buffer zone period, and 

4. Reentry by occupants and other non-handlers must not occur until, 

° The buffer zone period has ended, and 

° Sensory irritation is not experienced. 

• Buffer zones may not include agricultural areas owned/operated by persons other than 

the owner/operator of the application block, UNLESS,

3. 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 

4. 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. 

• 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 

162 
the area. 

4. Applicators must comply with all local laws and regulations. 

• See the Posting Section for additional requirements that may apply. 

For pre-plant soil 

use. 

Buffer Zone 

Distances for 

chloropicrin only 

formulations, 

chloropicrin and 

methyl bromide 

formulations, 

chloropicrin and 

iodomethane 

formulations, and 

chloropicrin and 1,3-

D formulations. 

“Buffer Zone Distances

Buffer zone distances must be calculated using the application rate and the size of the 

application block. 

 

FigureA. Broadcast Application 

Figure B. Bedded Application 

 

In Figures A and B, 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 B is 

fumigated, the rate per treated acre is 400 lbs ai/A for both Figure A and B. The 

broadcast rate for Figure A is 400 lb ai/A but the effective broadcast equivalent rate for 

Figure B is 200 lbs ai/A. The buffer zone distances must be based on the broadcast or 

effective broadcast equivalent rates.” 

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 must be based on look-up tables on product labels. 

25 feet is the minimum buffer distance regardless of site-specific application parameters. 

If the buffer zone distance, after applying all applicable buffer zone credits, is greater than 

1⁄2 mile (2,640 feet) 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. 

For all other applications, the following tables must be used to determine the buffer 

distances. Round-up to the nearest rate and block size, where applicable. 

Buffer Zone Look-up Table for Shank Bed/Strip with Tarps 

[For chloropicrin only, insert both Tables 5 and 12 from the Amended RED. Both tables 

In the Directions 

for Use for Preplant soil 

fumigation under 

the heading 

“Buffer Zone 

Distances” 

163 
should be on the label since the distances vary based on the amount of soil moisture. 

For chloropicrin/methyl bromide formulations. See driver tables 20 and 21 below. 

In Table 20, if methyl bromide is the driver insert Table 4 from Methyl Bromide Amended 

RED. If chloropicrin is the driver insert Table 5 from the Amended RED. 

In Table 21, if methyl bromide is the driver insert Table 4 from Methyl Bromide Amended 

RED. If chloropicrin is the driver insert Table 12 from the Amended RED. 

For chloropicrin/iodomethane formulations, please refer to the Agency for appropriate 

buffer table. 

For chloropicrin/1,3-dichloropropene formulations, insert both Tables 5 and 12 from the 

Amended RED. The buffer zone must meet all of the generic requirements for 

chloropicrin. Also to clarify which buffer must be used, 1,3-D labels that contain 

chloropicrin must delete the current buffer zone language, and replace it with, “The buffer 

zone for 1,3-D is 100 feet. This buffer zone does not apply to soils that have not been 

treated with 1,3-D in the previous 3 years.” If the chloropicrin buffer as listed in Table 5 

or 12 in the Amended RED is greater than 100 feet, the chloropicrin buffer must be used. 

If the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the 

previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the 

previous 3 years, the buffer is determined by either Table 5 or 12 in the Amended RED.] 

Buffer Zone Look-up Table for Shank Bedded without Tarps 

[For chloropicrin only, insert both Tables 6 and 13 from the Amended RED. Both tables 

should be on the label since the distances vary based on the amount of soil moisture. 

For chloropicrin/1,3-dichloropropene formulations, insert both Tables 6 and 13 from the 

Amended RED. The buffer zone must meet all of the generic requirements for 

chloropicrin. Also to clarify which buffer must be used, 1,3-D labels that contain 

chloropicrin must delete the current buffer zone language, and replace it with, “The buffer 

zone for 1,3-D is 100 feet. This buffer zone does not apply to soils that have not been 

treated with 1,3-D in the previous 3 years.” If the chloropicrin buffer as listed in Table 6 

or 13 in the Amended RED is greater than 100 feet, the chloropicrin buffer must be used. 

If the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the 

previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the 

previous 3 years, the buffer is determined by either Table 6 or 13 in the Amended RED.] 

Buffer Zone Look-up Table for Shank Broadcast with Tarps 

[For chloropicrin only, insert both Tables 7 and 14 from the Amended RED. Both tables 

should be on the label since the distances vary based on the amount of soil moisture. 

For chloropicrin/methyl bromide formulations. See driver tables 20 and 21 below. 

In Table 20, if methyl bromide is the driver insert Table 5 from Methyl Bromide Amended 

RED. If chloropicrin is the driver insert Table 7 from the Amended RED. 

In Table 21, if methyl bromide is the driver insert Table 5 from Methyl Bromide Amended 

RED. If chloropicrin is the driver insert Table 14 from the Amended RED. 

For chloropicrin/iodomethane formulations, please refer to the Agency for appropriate 

buffer table. 

For chloropicrin/1,3-dichloropropene combinations, insert both Tables 7 and 14 from the 

Amended RED. The buffer zone must meet all of the generic requirements for 

chloropicrin. Also to clarify which buffer must be used, 1,3-D labels that contain 

chloropicrin must delete the current buffer zone language, and replace it with, “The buffer 

zone for 1,3-D is 100 feet. This buffer zone does not apply to soils that have not been 

treated with 1,3-D in the previous 3 years.” If the chloropicrin buffer as listed in Table 7 

164 
or 14 in the Amended RED is greater than 100 feet, the chloropicrin buffer must be used. 

If the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the 

previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the 

previous 3 years, the buffer is determined by either Table 7 or 14 in the Amended RED.] 

Buffer Zone Look-up Table for Shank Broadcast without Tarps 

[For chloropicrin only, insert both Tables 8 and 15 from the Amended RED. Both tables 

should be on the label since the distances vary based on the amount of soil moisture 

For chloropicrin/1,3-dichloropropene formulations, insert both Tables 8 and 15 from the 

Amended RED. The buffer zone must meet all of the generic requirements for 

chloropicrin. Also to clarify which buffer must be used, 1,3-D labels that contain 

chloropicrin must delete the current buffer zone language, and replace it with, “The buffer 

zone for 1,3-D is 100 feet. This buffer zone does not apply to soils that have not been 

treated with 1,3-D in the previous 3 years.” If the chloropicrin buffer as listed in Table 8 

or 15 in the Amended RED is greater than 100 feet, the chloropicrin buffer must be used. 

If the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the 

previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the 

previous 3 years, the buffer is determined by either Table 8 or 15 in the Amended RED.] 

Buffer Zone Look-up Table for Shank Deep Broadcast without Tarps 

[For chloropicrin only, insert both Tables 9 and 16 from the Amended RED. Both tables 

should be on the label since the distances vary based on the amount of soil moisture 

For chloropicrin/methyl bromide formulations. See driver tables 22 and 23 below. 

In Table 22, if methyl bromide is the driver insert Table 6 from Methyl Bromide Amended 

RED. If chloropicrin is the driver insert Table 9 from the Amended RED. 

In Table 23, if methyl bromide is the driver insert Table 6 from Methyl Bromide Amended 

RED. If chloropicrin is the driver insert Table 16 from the Amended RED. 

For chloropicrin/1,3-dichloropropene formulations, insert both Tables 9 and 16 from the 

Amended RED. The buffer zone must meet all of the generic requirements for 

chloropicrin. Also to clarify which buffer must be used, 1,3-D labels that contain 

chloropicrin must delete the current buffer zone language, and replace it with, “The buffer 

zone for 1,3-D is 100 feet. This buffer zone does not apply to soils that have not been 

treated with 1,3-D in the previous 3 years.” If the chloropicrin buffer as listed in Table 9 

or 16 in the Amended RED is greater than 100 feet, the chloropicrin buffer must be used. 

If the chloropicrin buffer is less than 100 feet, and 1,3-D has been used on the field in the 

previous 3 years, the buffer is 100 feet. If 1,3-D has not been used on the field in the 

previous 3 years, the buffer is determined by either Table 9 or 16 in the Amended RED.] 

Buffer Zone Look-up Table for Drip Irrigation with Tarps 

[For chloropicrin only, insert Table 10 from the Amended RED. 

For chloropicrin/1,3-dichloropropene formulations, insert Table 10 from the Amended 

RED. The buffer zone must meet all of the generic requirements for chloropicrin. Also to 

clarify which buffer must be used, 1,3-D labels that contain chloropicrin must delete the 

current buffer zone language, and replace it with, “The buffer zone for 1,3-D is 100 feet. 

This buffer zone does not apply to soils that have not been treated with 1,3-D in the 

previous 3 years.” If the chloropicrin buffer as listed in Table 10 is greater than 100 feet, 

the chloropicrin buffer must be used. If the chloropicrin buffer is less than 100 feet, and 

1,3-D has been used on the field in the previous 3 years, the buffer is 100 feet. If 1,3-D 

has not been used on the field in the previous 3 years, the buffer is determined by Table 10 

below.] 

Buffer Zone Look-up Table for Drip Irrigation Buried (6 inches) without Tarps 

165 
[For chloropicrin only, insert Table 11 from the Amended RED. 

For chloropicrin/1,3-dichloropropene formulations, insert Table 11 from the Amended 

RED. The buffer zone must meet all of the generic requirements for chloropicrin. Also to 

clarify which buffer must be used, 1,3-D labels that contain chloropicrin must delete the 

current buffer zone language, and replace it with, “The buffer zone for 1,3-D is 100 feet. 

This buffer zone does not apply to soils that have not been treated with 1,3-D in the 

previous 3 years.” If the chloropicrin buffer as listed in Table 10 is greater than 100 feet, 

the chloropicrin buffer must be used. If the chloropicrin buffer is less than 100 feet, and 

1,3-D has been used on the field in the previous 3 years, the buffer is 100 feet. If 1,3-D 

has not been used on the field in the previous 3 years, the buffer is determined by Table 11 

below.] 

Buffer Zone Look-up Table for Pre-Plant Greenhouse Applications with Tarps 

[For chloropicrin only, insert Table 17 from the Amended RED. 

For chloropicrin/1,3-dichloropropene formulations, insert Table 17 from the Amended 

RED. The buffer zone must meet all of the generic requirements for chloropicrin. Also to 

clarify which buffer must be used, 1,3-D labels that contain chloropicrin must delete the 

current buffer zone language, and replace it with, “The buffer zone for 1,3-D is 100 feet. 

This buffer zone does not apply to soils that have not been treated with 1,3-D in the 

previous 3 years.” If the chloropicrin buffer as listed in Table 17 is greater than 100 feet, 

the chloropicrin buffer must be used. If the chloropicrin buffer is less than 100 feet, and 

1,3-D has been used on the field in the previous 3 years, the buffer is 100 feet. If 1,3-D 

has not been used on the field in the previous 3 years, the buffer is determined by Table 17 

below.]” 

For pre-plant soil 

use. 

Buffer Zone Credits 

“Buffer Zone Credits 

The buffer zone distances for chloropicrin 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. 

• 30% reduction in buffer zone distance, IF using Canslit Heatstrip Silver and Canslit 

Metalized. The tarp brand name, manufacturer, lot number, batch number, part 

number, and thickness must be recorded in the FMP. 

• 60% reduction in the 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). The tarp brand name, manufacturer, lot number, batch number, part 

number, and thickness must be recorded in the FMP. 

• 40% reduction in the buffer zone distance, IF the SymmetryTM application system is 

used with either Canslit Heatstrip Silver or Canslit Metalized tarps AND the 

application rate is less than 100 lbs ai/A. 

• 70% reduction in the buffer zone distance, IF the SymmetryTM application system is 

used with 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), or IPM Clear VIF (1.38 mil) tarps AND the application 

rate is less than 100 lbs ai/A. 

• 15% reduction in buffer zone distance, IF potassium thiosulfate (KTS) is applied with 

1⁄4 to 1⁄2 inch of water over a tarp. 

• 15% reduction in buffer zone distance, IF 1⁄4 to 1⁄2 inch of water is applied 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%. 

In the Directions 

for Use for Preplant soil 

fumigation under 

the heading 

“Buffer Zone 

Credits” 

166 
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 soil temperature is measured to be 50°F 

or less at a soil depth of 3 inches. 

• 10% reduction in the 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 

Application Method: Shank, Tarp, Bed

Application Block size: 20 acres

Application Rate: 300 lbs ai/A

Required Buffer Zone from Amended RED Table 5: 209 feet

Use IPM Clear VIF (1.38 mil) tarp: 60% credit. 

New Buffer Zone = required distance from appropriate table * (1-credit)

New Buffer Zone = 209 * (1-0.60) = 83.6 (round up to the nearest whole number to 

determine the buffer zone distance). 

New Buffer Zone = 84 feet”

Application 

Restrictions 

“Restrictions for Schools and Other Difficult to Evacuate Sites

• “Difficult-to-evacuate” sites include schools (preschool to grade 12), state 

licensed daycare centers, nursing homes, assisted living facilities, hospitals, inpatient clinics, and prisons. 

• No fumigant application with a buffer zone greater than 300 feet is permitted 

within 1/4 mile (1320 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. 

• 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.” 

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. 

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 

In the Directions 

for Use for Preplant soil 

fumigation under 

the heading 

“Posting” 

167 
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," 

-- "Chloropicrin 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," 

-- "Chloropicrin [Name of product] 

Fumigant BUFFER ZONE,” 

-- contact information for the certified 

applicator in charge of the fumigation

For pre-plant soil 

use. 

Emergency 

Preparedness and 

Response. 

“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 

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. 

In the Directions 

for Use for Preplant soil 

fumigation under 

the heading 

“Emergency 

Preparedness and 

Response” 

168 
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 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: 

o once, 1 hour before sunset, 

o once, during the night, 

o once, at 1 hour after sunrise, and 

o 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 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 

• The 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 

Tribal Lead Agencies 

“Notice to State and 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. 

Directions for Use 

under “Notice to 

State and Tribal 

Lead Agencies” 

169 
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 Number, 

o Applicator and property owner/operator contact information, 

o Time period that fumigation may occur.” 

For pre-plant soil 

use. 

Application 

Restrictions 

“Maximum Application Rates for Pre-Plant Soil Uses 

• 350 lbs a.i. per acre for tarped, shank injection applications; 

• 175 lbs a.i. per acre for untarped, shank injection applications; 

• 300 lbs a.i. per acres for drip irrigation applications (including greenhouses); 

• 500 lbs a.i. per acre, this is equivalent to 1 lb per 100 square feet, for tree hole 

replant applications (small area).” 

In the Directions 

for Use for Preplant soil 

fumigation under 

the heading 

“Maximum 

Application Rates 

for Pre-Plant Soil 

Fumigation” 

within its own box 

For pre-plant soil 

use. 

Requirements for 

greenhouses. 

“The maximum area that can be treated is 50,000 square feet. 

All greenhouse pre-plant soil fumigations must be tarped.” 

In the Directions 

for Use for Preplant soil 

fumigation under 

the heading 

“Requirements for 

Pre-Plant 

Greenhouse Soil 

Fumigations” 

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. 

Chloropicrin has certain properties and characteristics in common with chemicals that have 

been detected in groundwater (chloropicrin is highly soluble in water and has low 

adsorption to soil). 

For untarped applications of chloropicrin, leaching and runoff may occur if there is heavy 

raninfall after soil fumigation.” 

Precautionary 

Statements 

immediately 

following the User 

Safety 

Recommendations 

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.” 

Precautionary 

Statements 

immediately 

following the User 

Safety 

Recommendations 

170 
BUFFER ZONE DRIVER TABLES 

Table 20

Standard Tarp (no credits)

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 21 

Standard Tarp (no credits)

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 

Table 22 

Deep (≥ 18 inches) Untarp 

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 23 

Deep (≥ 18 inches) Untarp 

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 

171 
Table 24: Summary of Labeling Changes for Chloropicrin Antimicrobial Uses (Remedial Wood 

Treatment) 

Description Amended Label Language Placement 

Add language 

clarifying 

application 

methods 

“For remedial treatment of wooden poles/timbers: 

1. Plug the pre-drilled holes immediately after applications; 

2. Do not treat structures/beams indoors; 

3. Do not drill an application hole through seasoning checks to apply product. If 

the hole intersects a check, plug the hole and drill another. If more than 2 treatment 

holes intersect an internal void or rot pocket, re-drill the holes farther up the pole 

into relatively solid wood.” 

Directions for Use 

For end-use 

products 

containing 

directions for use 

for the pour or 

injection method of 

application (not 

including the vial 

application 

method) 

“Applicators and other handlers must wear a full-face tight-fitting or loose-fitting 

helmet or hood style NIOSH/MSHA approved respirator 

• with an organic-vapor-removing cartridge with a prefilter approved for 

pesticides (MSHA/NIOSH approval number prefix TC-23C), or 

• with a canister approved for pesticides (MSHA/NIOSH approval number 

prefix TC-14G)." 

All references to wearing goggles or a full face shield for eye protection must be 

removed.

Personal Protective 

Equipment 

For end-use 

products 

containing 

directions for use 

for the vial method 

of application 

“For handling activities in enclosed areas, applicators and other handlers 

participating in filling the vials or otherwise exposed to non-encapsulated product 

must wear: 

• a supplied-air respirator with MSHA/NIOSH approval number prefix TC19C, or 

• a self-contained breathing apparatus (SCBA) with MSHA/NIOSH approval 

number TC-13F. 

For handling activities outdoors, applicators and other handlers participating in 

filling the vials or otherwise exposed to non-encapsulated product must wear a fullface tight-fitting or loose-fitting helmet or hood style NIOSH/MSHA approved 

respirator: 

• with an organic-vapor-removing cartridge with a prefilter approved for 

pesticides (MSHA/NIOSH approval number prefix TC-23C), or 

• with a canister approved for pesticides (MSHA/NIOSH approval number 

prefix TC-14G)." 

Personal Protective 

Equipment 

For all 

antimicrobial enduse registrations of 

chloropicrin 

“Do not permit entry into spill area or clean-up area by unprotected persons until 

concentration of chloropicrin is determined to be less than 0.15 ppm." 

This language updates some labels which currently state 0.3 ppm. 

Storage and 

Disposal and 

Personal Protective 

Equipment 

The following 

language must 

appear on the label 

if respirator use is 

required (for liquid 

pour application 

and when filling 

vials):

“Employers must 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 who 

will evaluate the ability of a worker to wear a respirator. The initial 

Directions for Use 

Under the section 

“Protection for 

Handlers” 

172 
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 statue or respirator 

style or use-conditions change.” 

The following 

language must 

appear on the label 

if the use of a 

respirator is not 

required 

(application via 

vial method) but 

needs to be 

available in case of 

spill or emergency. 

“In case of emergency or the need for immediate respiratory protection, the 

fumigation handler employer must make sure that at least one air rescue device 

(e.g., SCBA) is on-site and ready for use in case of an emergency.” 

Directions for Use 

Under the section 

“Protection for 

Handlers” 

For registration 

75340-1, use 

directions for the 

vial method of 

application must be 

incorporated into 

the main label and 

the reference to the 

pour method of 

chloropicrin 

removed (the pour 

method is no 

longer used for this 

registration). 

Vial method of application language to be provided by registrant when revised label 

submitted for review. 

Directions for Use 

173 
Appendix A 

Chloropicrin PC Code 081501 Uses Eligible for Reregistration 

Use Site Formulation Application 

Method 

Maximum 

Application 

Rate/Number of 

Applications 

Use Limitations 

Pre-Plant Soil

Agricultural Crops 

Berries: 

caneberries, 

blackberries, 

boysenberries, 

dewberries, 

loganberries, 

raspberries, 

youngberries, 

blueberries, 

cranberries, 

gooseberries, 

huckleberries. 

 

Small fruits: 

strawberries, currants, 

grapes, kumquat, 

bananas, figs, 

persimmons, 

pineapple, 

pomegranates, 

tree fruits (all), vine 

fruits (all). 

 

Citrus fruits: 

Grapefruit, lemon, 

limes, oranges, 

tangelos, tangerines. 

 

Nut crops: 

almonds, cashews, 

chestnuts, filberts, 

hickory nuts, pecans, 

walnuts, pistachios. 

 

Pome and stone fruits: 

apples, pears, quinces, 

soluble 

concentrate/liquid, 

pressurized gas, 

pressurized liquid, 

emulsifiable 

concentrate, and a 

ready-to-use 

product 

1. Shank injection 

tarped** 

 

2. Shank injection 

untarped 

 

3. Shank injection 

deep (at least 18 

inches) untarped 

 

4. Drip Irrigation 

Tarp 

 

5. Tree hole 

replant 

1. 350 lbs ai/A 

 

2. 175 lbs ai/A 

 

3. 350 lbs ai/A 

 

 

4. 300 lbs ai/A 

 

5. 500 lbs ai/A ( 1 

lb/100 ft2

) 

See applicable 

GAPS from the 

label table. 

174 
Use Site Formulation Application 

Method 

Maximum 

Application 

Rate/Number of 

Applications 

Use Limitations 

apricots, cherries, 

nectarines, peaches, 

plums, prunes, dates. 

 

Cucurbits: 

Melons (all), 

cantaloupes, casaba 

melons, crenshaw 

melons, honeydew, 

muskmelons, persian 

melons, watermelon, 

cucumbers, pumpkins, 

squash (summer and 

winter), mango 

melons. 

 

Vegetables: asparagus, 

eggplant, peppers, 

pimentos, tomatoes, 

cole crops, broccoli, 

brussels sprouts, 

cabbage, cauliflower, 

collards, kale, 

kohlrabi, endive, 

lettuce (all), mustard, 

spinach, Swiss chard, 

carrots, garlic, leeks, 

okra, onions, parsnips, 

potatoes, radishes, 

rutabagas, salsify, 

shallots, sweet potato, 

yams, popcorn, 

garden beets, celery, 

turnips, vegetables 

(all). 

 

Field crops: 

beans (all), peas (all), 

kenaf, forage-fodder 

grasses (all), pastures, 

alfalfa, clover, 

lespedeza, vetch, 

175 
Use Site Formulation Application 

Method 

Maximum 

Application 

Rate/Number of 

Applications 

Use Limitations 

birdsfoot trefoil, 

barley, 

corn, oats, rye, 

sorghum, 

wheat, sugarcane, 

buckwheat, tobacco, 

safflower, cotton, flax, 

peanuts, soybeans, 

millet. 

 

Ornamentals: 

golf course turf, 

ornamental turf, forest 

trees (all), herbaceous 

plants (all), woody 

plants (all), flowering 

plants (all). 

 

Miscellaneous: hops, 

horseradish, mint, 

olives, 

greenhouse soils, 

mushroom house soils. 

Warning Agent Prior to Sulfuryl Fluoride Residential Fumigations

Residential Structures Ready-to-Use Chloropicrin is 

then placed in the 

center of the 

structure in either 

a shallow pan or 

onto absorbent 

material. A fan is 

then placed to 

direct the air 

stream over the 

pan or absorbent 

material to 

accelerate the 

chloropicrin’s 

evaporation. 

1 fluid ounce ai of 

chloropicrin is 

used per 10,000-

15,000 cubic feet. 

Remedial Wood Treatment

Wood poles, timbers, Ready to use There are two Pole Do not treat 

176 
Use Site Formulation Application 

Method 

Maximum 

Application 

Rate/Number of 

Applications 

Use Limitations 

pilings, and gluelaminated beams. methods for 

application of 

chloropicrin for 

remedial wood 

treatment. One 

method involves 

using 

encapsulated vials. 

Applicators pour 

liquid chloropicrin 

into vials and cap 

them. After the 

applicator has 

reached the area 

to be treated, the 

cap is removed 

and the vial 

inserted into the 

holes that have 

been pre-drilled 

into the timber. 

The hole is then 

capped. The other 

method involves 

pouring/injecting 

liquid chloropicrin 

into holes that 

have been predrilled. The hole 

is then capped. 

Circumference in 

inches and 

amount of 

solution to be 

applied : 

 

22-29in, use 1⁄4 

pint 

30-38in, use 1⁄2 

pint 

39-56in, use 1.0 

pint 

57-65in, use 1 1⁄4 

pint 

structures/beams 

indoors. 

 

Do not drill an 

application hole 

through seasoning 

checks to apply 

product. If the 

hole intersects a 

check, plug the 

hole and drill 

another. If more 

than 2 treatment 

holes intersect an 

internal void or 

rot pocket, re-drill 

the holes farther 

up the pole into 

relatively solid 

wood. 

 

 

**The application method matches up with the same number for the maximum application rate. 

For example, the maximum application rate for shank bedded tarped applications is 350 lbs ai/A. 

177 
Appendix B 

Table of Generic Data Requirements and Studies Used to Make the Reregistration Decision 

This section is currently not available. 

178 
Appendix C. 

Technical Support Documents 

Additional support of this RED is maintained in the OPP docket EPA-HQ-OPP-2007-0350. This 

docket may be accessed in the OPP docket room located at S-4900, One Potomac Yard 2777 S. 

Crystal Drive, Arlington, VA. It is open Monday through Friday, excluding federal holidays, 

from 8:30-4:00 pm. All documents may be view in the OPP docket room or downloaded or 

viewed via the internet at http://www.regulations.gov. 

Health Effects Support Documents 

• 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) 

• Chloropicrin: Third Revision of the HED Human Health Risk Assessment. April 30, 

2009 (DP Barcode 348637). 

• EPA-HQ-OPP-2007-0350-0170, RESPONSE TO PUBLIC COMMENTS. The Health 

Effects Division’s Response to Comments on the Agency’s April 12, 2007 document, 

Chloropicrin: Revised HED Human Health Risk Assessment for Phase 5 (Docket EPAHQ-OPP-2007-0350). DP Barcode 348676. 

• EPA-HQ-OPP-2007-0350-0172, MOA Mode of Action, Eye Irritation, and the IntraSpecies Factor: Comparison of Chloropicrin and MITC. June 25, 2008. DP Barcode 

293356. 

• EPA-HQ-OPP-2007-0350-0173, Factors Which Impact Soil Fumigant Emissions - 

Evaluation For Use In Soil Fumigant Buffer Zone Credit Factor Approach. June 9, 2008. 

(DP Barcode 306857) 

Environmental Fate and Ecological Effects Support Documents 

• Further Response to Public Comments on the 7/9/08 Completed Chloropicrin RED. 

(March 3, 2009) 

• Evaluation of “Probabilistic Modeling of Chloropicrin Exposure to Aquatic Nontarget 

Organisms” (March 3, 2009). 

• Response to Comments from Dow Agrochemicals Regarding EPA’s Review of the 

Chain-2D Model (March 3, 2009). 

• EPA-HQ-OPP-2007-0350-0174, Response to Phase 5 Public Comments on the Phase 4 

Chloropicrin Reregistration Risk Assessment. April 16, 2008. DP Barcode 348669. 

• EPA-HQ-OPP-2007-0350-0175, Revised Screening Ecological Risk Assessment for the 

Reregistration of Chloropicrin. DP Barcode 348669. April 16, 2008. 

Biological and Economical Analysis Support Documents 

• 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. 

179 
• Analysis of Soil Fumigant Risk Management Requirements using Geographic 

Information Systems: Case Studies based on a Forest Seedling Nursery (DP#363546). 

May 13, 2009. 

• Process for Defining High-Use Fumigation Areas at the State and County Levels 

(DP#364647) May 14, 2009. 

• EPA-HQ-OPP-2007-0350-0168, 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. June 25, 2008. DP Barcode 353940. 

• EPA-HQ-OPP-2007-0350-0169, 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. 

• EPA-HQ-OPP-2007-0350-0017, Summary of the Benefits of Soil Fumigation with 

Chloropicrin in Crop Production. 

• EPA-HQ-OPP-2007-0350-0018, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam Sodium in Cucurbit Production. 

• EPA-HQ-OPP-2007-0350-0019, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam Sodium in Eggplant Production 

• EPA-HQ-OPP-2007-0350-0020, Assessment of the Benefits Soil Fumigants (Methyl 

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

Nurseries. 

• EPA-HQ-OPP-2007-0350-0021, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin, Dazomet, and Metam Sodium for Use in Raspberry 

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

California. 

• EPA-HQ-OPP-2007-0350-0022, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin and Metam-sodium in Onion Production. 

• EPA-HQ-OPP-2007-0350-0023, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin, and Metam Sodium in Grape Production. 

• EPA-HQ-OPP-2007-0350-0024, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin and Metam Sodium in Tree Nut Production. 

• EPA-HQ-OPP-2007-0350-0025, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin and Metam Sodium in Pome Fruits Production. 

• EPA-HQ-OPP-2007-0350-0026, Assessment of the Benefits of Soil Fumigation with 

Methyl Bromide, Chloropicrin, and Metam Sodium in Stone Fruit Production. 

• EPA-HQ-OPP-2007-0350-0027, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam Sodium in Bell Pepper Production. 

• EPA-HQ-OPP-2007-0350-0028, Assessment of the Benefits of Soil Fumigation with 

Metam Sodium in Potato Production. 

• EPA-HQ-OPP-2007-0350-0029, Assessment of Soil Fumigation with Chloropicrin, 

Methyl Bromide and Metam-sodium in Strawberry Production. 

• EPA-HQ-OPP-2007-0350-0030, Assessment of the Benefits of Chloropicrin, Methyl 

Bromide, Metam-sodium and Dazomet Use In Strawberry Nursery Runner Production. 

• EPA-HQ-OPP-2007-0350-0031, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam-sodium on Sweet Potato Production. 

180 
• EPA-HQ-OPP-2007-0350-0032, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin in Tobacco Production. 

• EPA-HQ-OPP-2007-0350-0033, Assessment of the Benefits of Soil Fumigation with 

Chloropicrin, Methyl Bromide, and Metam Sodium in Tomato Production. 

• EPA-HQ-OPP-2007-0350-0034, Assessment of the Benefits of Soil Fumigation with 

Metam-Sodium in Carrot Production. 

• EPA-HQ-OPP-2007-0350-0035, Assessment of the Benefits of Soil Fumigation with 

Metam Sodium in Peanut Production. 

• EPA-HQ-OPP-2007-0350-0036, Assessment of the Benefits of Soil Fumigation with 

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

• EPA-HQ-OPP-2007-0350-0037, BEAD's Planned Impact Assessments on Agricultural 

Sites with Significant Use of Soil Fumigants (Chloropicrin, Dazomet, Methyl Bromide, 

Metam Potassium, and Metam Sodium. 

 

Antimicrobial Assessment Support Documents 

• EPA-HQ-OPP-2007-0350-1065, Revised Occupation and Residential/Bystander 

Assessment of the Antimicrobial Use (Remedial Wood Treatment) of Chloropicrin for 

the Reregistration Eligibility Decision (RED) Document. (Phase 3 Comment). PC Code 

081501, DP Barcode 314399. 

• EPA-HQ-OPP-2007-0350-1066, Phase 6 Response to Substantive Public Comments on 

Antimicrobials Division’s Occupational and Residential Assessments for the 

Reregistration Eligibility Decision (RED) Documents for the following chemicals: 

Methylisothiocyanate (MITC), Metam Sodium, Dazomet, and Chloropicrin. 

• EPA-HQ-OPP-2007-0350-1067, Updated Label Language for the Antimicrobial Uses of 

Chloropicrin (PC Code 081501) for the Reregistration Eligibility Decision Document. 

Buffer Zone Credits Support 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. May 14, 2009 

• EPA-HQ-OPP-2007-0350-1073, Factors Which Impact Soil Fumigant Emissions - 

Evaluation for Use in Soil Fumigant Buffer Zone Credit Factor Approach. Dawson, J. 

and Smith, C.; D306857; June 9, 2008.. 

• EPA-HQ-OPP-2007-0350-1078, Health Effects Division Recommendations for Fumigant 

Data to Refine Exposure Assessments. DP Barcode 353724. 

Risk Management Support Documents 

• EPA-HQ-OPP-2007-0350-1077, SRRD’s Response to Phase 5 Public Comments for the 

Soil Fumigants. Rice, M. and McNally, R.; July 2008. 

• EPA-HQ-OPP-2007-0350-0003, Risk Mitigation Options to Address Bystander and 

Occupational Exposures from Soil Fumigant Applications. 

• SRRD’s Response to Post-RED Comments for the Soil Fumigants. May 27, 2009. 

181 
Appendix D 

PERFUM Model Inputs and Outputs 

Version 2.1.4 of the Probabilistic Exposure and Risk model for Fumigants (also called 

the PERFUM model) combined with monitoring data and incident data were used to characterize 

the risk for specific buffer zone distances corresponding to the range of application scenarios 

anticipated. A CD containing all of the PERFUM input/output files and files with the PERFUM 

MOE/air concentration analysis that were considered for this decision are available upon request 

at the OPP Docket Office. Additional information on the PERFUM inputs and outputs can be 

found in the Agency’s risk assessment3, in a June 2006 a peer-reviewed article describing the 

model (http://www.sciencedirect.com/science/journal/13522310), and/or the PERFUM user’s 

guide which can be download from the internet (http://www.exponent.com/perfum/) 

The major input parameters for the PERFUM model were: application rates, application 

block sizes, application method emission studies, weather conditions, and target air concentration 

(based on acute inhalation endpoint and uncertainty factors). The following summarizes the key 

points for each of these input parameters. 

 Rates 

o Agricultural Field 

Although labels currently allow higher rates, the Agency modeled the maximum rates 

supported by the CMTF. These rates are listed in Section II B. Buffer zones were determined 

for the maximum rates as well as increments less than the maximum application rate. This was 

done to allow flexibility in the buffer approach while taking into consideration current typical 

use patterns. According to 2007 Agency proprietary data about 93% of chloropicrin usage is at 

rates less than 125 lbs ai/A. The Agency completed a series of benefit assessments by crop and 

region that include a more detailed analysis of use rates. 

o Greenhouse 

 The maximum application rate for greenhouse drip applications is 300 lbs ai/A. This is 

the same rate used in outdoor agricultural field drip applications. 

Rates for bedded or strip applications (lb ai per treated area) were converted to broadcast 

equivalent application rate to determine the minimum buffer zone distance. In Figures 8 and 9 

(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 untreated portion of the field. 

Assuming both fields are 10 acres, and only 50% of field in Figure 9 is fumigated, the rate per 

treated acre is 400 lbs ai/A for both Figure 8 and 9. The broadcast rate for Figure 8 is 400 lb 

ai/A but the effective broadcast equivalent rate for Figure 9 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. 

182 
Figure 8. Broadcast Application Figure 9. Bedded Application 

 Block Size 

o Agricultural Field 

The Agency has limited information regarding the size of the application blocks typically 

treated in a given day, but estimates that each crew or application rig treats less than 40 acres for 

most scenarios. However several commercial applicators have indicated that they sometimes use 

multiple rigs and crews to treat blocks greater than 80 acres per day. 

 Buffer zone distances were determined for 1, 5, 10, 20, 30, 40, 50, 60, and 80 acres. 

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 8 and 9 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. 

o Greenhouse 

Greenhouse soil fumigations can take place in a wide range of structure sizes. The 

Agency modeled the following 5,000; 10,000; 15,000; 20,000; 25,000; 30,000; 35,000; 40;000; 

45,000; and 50,000 ft2

. 

 Emission Studies and Weather Data 

o Agricultural Field 

This section has been updated and is presented in the New Flux (Emission) Studies

section. 

o Greenhouse 

A flux study was not used. Instead a 24-hour continuous single emission was used in the 

modeling runs. This is based upon current California permit conditions. Ventura, CA weather 

data was used. 

 

 Target Air Concentration 

183 
o Agricultural Field and Greenhouse 

Based on several factors including the severity and reversibility of the effect, and the 

quality of the hazard database, the buffer zone distance target is to reach an air concentration of 

0.073 ppm which equates to an MOE of 1. At minimum, if the target MOE was not reached, half 

of the target (MOE 0.5), which corresponds to minor, reversible effects, was achieved with the 

buffer zone distance selected. 

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 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 

chloropicrin use when coupled with other mitigation measures.

184 
Appendix E 

Sample FMP for Soil Applications 

(Please note that this example is tailored to methyl bromide and will be refined for chloropicrin 

at a later date). 

185 
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: 

186 
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: 

187 
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: 

188 
189 

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
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
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 

191 
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 

192 
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. 

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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

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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: 

195 
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: 

196 
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

197