Methyl Bromide for Post Harvest Uses Anticipated Label Changes

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1 Methyl Bromide for Post Harvest Uses Anticipated Label Changes Methyl Bromide and Alternatives in Food Plants Kansas State University May 11-13, 2010 David L. McAllister Chemtura Corporation

2 Methyl Bromide Reregistration Pre-plant Uses Amended labels late 2010 Further amendments in 2011

3 Methyl Bromide Reregistration Post Harvest Uses Amended labels 2011 or 2012

4 Post Harvest Label Changes Tolerances Fumigation Management Plans Buffer Zones Posting and Notification Record Keeping Respiratory Protection Monitoring Minimum Aeration Times

5 Tolerances Based on residue studies conducted in the mid s by the Methyl Bromide Industry Panel Will be expressed as methyl bromide instead of bromide ion Will be based on crop groupings rather than individual crops.

6 Tolerances - 2 A few tolerances will be revoked, and some uses will be removed from the label. Commodity Tolerance Disposition Alfalfa Hay Revoke Remove Use Cottonseed Revoke Remove Use Cumin Seed Revoke Not currently registered Mangoes Revoke Not currently registered Papayas Revoke Not currently registered Pomegranates Revoke Not currently registered Timothy Hay Revoke Not currently registered Fermented malt beverage Revoke Not currently registered Dog food Revoke Tolerance not required Ginger roots Revoke Not currently registered Cereal grains Revoke Not currently registered

7 Fumigation Management Plan A Fumigation Management Plan (FMP) will be required for all fumigations FMP is the responsibility of the person supervising the fumigation No requirement for review or approval by regulatory authorities Must be retained for 2 years Similar to the FMP now required for phosphine fumigations.

8 Fumigation Management Plan - 2 Required Elements of the FMP General site information Fumigator/Applicator information Treatment and aeration procedures Buffer zones Authorized on-site personnel Personal protective equipment Posting and notification plans and records Record keeping Emergency procedures Site Security Hazard communication

9 FMP Details General site information (site address, site operator/owner, phone number) Type of fumigation (e.g., quarantine, structural, mill, ship) Description of enclosure/chamber/structure (map or sketch of the facility, volume of treatment area, enclosure materials, commodities fumigated, maximum rates and dosage times, local exhaust ventilation systems, MeBr destruction/capture systems, proximity to other structures and common walls) Estimate of loss/retention rate (methods for evaluating and documenting) Descriptions and locations of control rooms, storage areas, restricted areas, other work areas, and sensitive surrounding sites (such as homes, schools, hospitals, employee housing centers) Fumigator/applicator information (license #, address, phone, contact information for person supervising the fumigation, i.e., the responsible party) Treatment and aeration procedures Maximum rates and dosage for each commodity Location of gas introduction site (including map and description) Leak testing procedures Interior and perimeter air monitoring of treated areas (methods, procedures, and equipment) Buffer zones (see below for method to calculate treatment and aeration buffer zones based on Agency look-up tables or alternate methods) Authorized on-site personnel Fumigators (fumigation workers must be certified applicators, or be working under the direct supervision of a certified applicator) Other on-site workers Personal protective equipment (selection, fit-testing, maintenance, storage procedures) Posting and notification (plans, procedures, record of notifications) Record keeping Emergency procedures (evacuation routes, emergency utility shut-offs, locations of telephones, emergency company, local/state/federal contacts, key personnel and emergency responsibilities in case of an incident, equipment failure, or other emergency). Site security Hazard communication (product labels, material safety data sheets, etc.)

10 Buffer Zones Only persons performing or supervising a fumigation are permitted inside the buffer zone Two buffer zones for commodity fumigation: Treatment while fumigation is in progress Aeration until air discharged from fumigated area contains <5 ppm methyl bromide Buffer zone distances based on EPA look-up tables or alternate methods Minimum buffer zone 10 feet Exceptions Occupied structures, if monitored Non-occupied structures Transit roads and railroads

11 Fumigation Concentration Profile Treatment Aeration ppmv Aeration begins Gas Release 24 hours Internal Concentration Data

12 Example Buffer Zones Treatment buffer zone Aeration buffer zone

13 Buffer Zone Table - Example App Rate (lbs/1,000 ft 3 ) Buffer Zones (m) During Treatment Period of 24 Hours or Greater % Release Volume (1,000 ft 3 ) , Application Rate lb/1000ft Buffer Zones (m) During Aeration Period of 8 Hours or Less Volume (1,000 ft 3 ) % Release ,

14 Buffer Zone Alternate Methods Site-specific modeling Use local volumes and ventilation rates Models specified by EPA One model run could be used for a given facility, as long as conditions do not change Site-specific air monitoring According to EPA criteria Number and extent of samples may be practically prohibitive Emission mitigation may reduce buffer zones Improved sealing Exhaust scrubbers

15 Posting and Notification Exterior of containers of fumigated commodities must be identified as having been fumigated Fumigator must provide access to MSDS for workers who handle the fumigated commodity Fumigators must notify all residences and businesses adjacent to sites where fumigation takes place and tell them how they can access the FMP Annual notification Notify by mail, radio, TV, newspapers, postings in public places Fumigant groups are working with EPA to devise acceptable notification schemes

16 Record Keeping Certified applicator must maintain records that show: Dates of fumigation Results of any air monitoring Records must be maintained for 2 years, and must be readily available to fumigation workers and other on-site personnel. Records must be available on request to Local, state, tribal, or Federal pesticide enforcement officials Any interested individuals in the community.

17 Respiratory Protection Respiratory protection is required for all persons in the treatment area or buffer zones Greater than 5 ppm supplied air or SCBA Between 1 ppm and 5 ppm supplied air, SCBA, or cartridge type respirator Below 1 ppm for an 8 hour TWA no respiratory protection required. EPA is considering changes that will require respiratory protection at concentrations above an 8 hour TWA of 0.15 ppm

18 Air Monitoring Air concentration must be monitored using a direct reading monitoring device Label will provide detailed procedures which must be followed in order to discontinue respiratory protection. Monitoring must be continued at least hourly after respiratory protection is discontinued.

19 Minimum Aeration Times Four hours if mechanically ventilated using fans Twelve hours if passively ventilated using windows and doors only Exceptions In a vacuum chamber that provides at least 4 air changes per hour, ventilation can be discontinued after 10 air changes Detection devices with a detection limit of 0.5 ppm or lower can be used to demonstrate that ventilation time can be shortened Fumigated commodities can be moved to a storage if the methyl bromide concentration between the stacks is 5 ppm or less, and at least 10 air changes have been completed.

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