MITC Generators

Handler Training 2010 Label

http://www.epa.gov/pesticides/reregistration/soil_fumigants/

2010 Label Changes

Becomes Restricted Use Personal Protective Equip changes Site Monitoring Posting Requirements 5 day re-entry Good Agricultural Practices Fumigation Management Plans Handler/Applicator Training

Changes to the Metam Labels

Change is inevitable

Metam Sodium/Potassium 2010 Label Changes

Dec. 1, 2010 scheduled date of implementation.

No changes yet. Operate on 2009 label until EPA & State approval of new labels. New labels were submitted Sept. 30, 2009.

2011 proposed requirements: Buffer zones, Buffer credits, Buffer monitoring, Overlap restrictions.

Today we will look at Safe Handling of Metam, and a summary of changes on the labels submitted to the EPA.

Safe Handling of Metam

First Aid

Personal Protective Equipment requirements

Stop and Start work triggers

For additional info refer to the Certified Applicator, Label, Fumigation Management Plan, and MSDS sheet. Read and follow all label instructions.

Safe Handling of Metam Only properly trained and equipped handlers may enter the

fumigation block during the restricted entry period (restricted period: during the application and 5 days following)*

Wear proper Personal Protective Equipment (PPE) for the situation and task

Clean (per manufacturer’s instructions) PPE after use

Store PPE outside of cab

Wash your hands prior to eating or drinking, chewing gum, using tobacco, or using the toilet

*Per the 2010 submitted label.

Safe Handling of Metam Only Trained Handlers are authorized to perform the following:1

*Load/unload trucks (transfer product)

*Repair equipment

*Start/Stop chemigation equipment (supervised by certified applicator)

*Calibrate chemigation (supervised by certified applicator)

*Monitor chemigation applications (supervised by certified applicator)

*Clean up spills

* Operate application equipment (supervised by certified applicator)

*Scout fields (post application, during Restricted Entry Period)

1) Per 2010 submitted label

What is a “Certified Applicator?”

For the 2010 label a CA must be either a State Licensed Private Applicator or Commercial Applicator

For the 2011 label there will be a new certification program in place

Personal Protective EquipmentThe trigger for respirator use is sensory irritation (tearing,

burning of the eyes or nose)

All handlers who use a respirator must: *be fit-tested and fit-checked conforming with

OSHA requirements

*Trained using OSHA conforming program

*Examined by a qualified medical practitioner to ensure the handler’s physical ability to wear respirators

Personal Protective Equipment

Handlers wearing chemical resistant suit are limited to 30 min. in any 60 min. period *

Protective eyewear are to be of the sealing, non-venting type

Full face respirator at least NIOSH approved with either:

* organic-vapor removing cartridge with pre-filter approved for pesticides (NOISH approval # prefix TC-23C) or

*canister approved for pesticides (NOISH approval # TC-14G)

*per 2010 submitted label

Personal Protective Equipment

For handlers who may be exposed to liquid spray: 1

*Chemical resistant coveralls over long-sleeve shirt and long pants

*Chemical resistant gloves *Chemical resistant footwear plus socks *Chemical resistant headgear *Protective eyewear *Respirator 1) Per 2010 submitted label

Personal Protective Equipment

For handlers who transfer product, repair equipment, clean up spills: 1

*Coveralls over long sleeve shirt and long pants

*Chemical resistant gloves

*Chemical resistant footwear plus socks

*Chemical resistant apron

*Protective eyewear

*Respirator (if triggered)1) Per 2010 submitted label

Presonal Protective Equipment

For Handlers who calibrate chemigation equipment: 1

*Long sleeve shirt and long pants

*Shoes plus socks

*Protective eyewear

*Respirator (if triggered)1) Per submitted label

Personal Protective Equipment

For all other handlers 1

*Long sleeve shirt and long pants

*Shoes plus socks

*Respirator (if triggered)1) Per 2010 submitted label

First Aid if on skin or clothing

Remove contaminated clothing

Rinse affected area with plenty of water for 15 to 20 minutes

Call poison control center or doctor (have label or MSDS)

First Aid if in eyes

Hold eye(s) open and rinse slowly and gently with water for 15-20 minutes

Remove contact lenses, if present within the first 5 minutes

Call poison control center or doctor (have label or MSDS)

First Aid if Inhaled

Move person to fresh air

If not breathing, call 911/ambulance, give artificial respiration

Call poison control or doctor (have label or MSDS)

First Aid if Swallowed

Call poison control or doctor immediately (have label or MSDS)

Have the person sip a glass of water

Do Not induce vomiting unless directed by poison control or doctor

Do not give anything by mouth to an unconscious person

Stop and Start work Triggers

If a handler experiences sensory irritation then:

*leave the area or

*a respirator must be worn by all handlers or

*Cease operations and leave the area

*Monitor MITC levels if work continues

Resuming operations Respirators may be removed when 2 consecutive air samples

taken at least 15 min. apart (at the site of irritation) are less than 600 ppb MITC providing handlers no longer experience sensory irritation

When wearing respirator air samples must be collected at least every 2 hours

If a handler wearing a respirator experiences sensory irritation or air sample is 6000ppb or greater then handlers must leave area

Work may resume if 2 consecutive air samples are less than 6000ppb and respirator (with new cartridges) is worn and sensory irritation is not experienced

Direct read monitoring devices such as Draeger is approved

Site Monitoring

Ground applications: The certified applicator must be at the site, in line of sight of the application and directly supervise all handlers at all times.

Pivot applications: The certified applicator must be at the site in the line of sight of the application to start the application including set up, calibration, and start. May leave after start up but must return every 2 hours to monitor. A trained handler may perform the monitoring functions if under the supervision of certified applicator & able to be in direct communication with the certified applicator at all times.

Posting Requirements Fumigant Treated Area sign:

*DANGER/PELIGRO,

*Area under fumigation, DO NOT ENTER/NO ENTRE,

*Metam Sodium Fumigant in Use,

*Date and Time of fumigation,

*Date and time restricted period is lifted,

*Brand name of this product

*Name, address, phone # of the certified applicator in charge. *Follow all Worker Protection Standards regarding location, legibility, size,

timing of posting and removal.

Posting Requirements Irrigation system posting requirements:

Posting is required when: Any portion of treated area is within 300 ft. of residences, businesses, labor camps, day cares, hospitals, clinics, nursing homes, public schools, parks, playgrounds, not including public roads.

Signs to be posted at usual points of entry and likely routes of approach.

Printed side facing away from the treated field. Printed in English.

Must be posted prior to application and remain up at least until foliage has dried and surface water has disappeared.

All words must be at least 2.5 inches tall containing the words KEEP OUT followed by a stop sign symbol at least 8 inches in diameter. PESTICIDES IN IRRIGATION WATER shall be below the stop sign.

This sign is in addition to other posting required by Worker Protection Standard.

What are GAPs?

Good Agricultural Practices (GAPs) are now mandatory label provisions.

They are practices you are already performing.

GAP’s look at Environment, soil, and equipment considerations.

We will look at the GAPs for Center Pivot & Shank applications today.

We will see how the GAPs are tied to the Fumigation Management Plans (FMP)

Weather conditionsFor applications

Wind Speed for Pivot: 2-10 mph for mid, high, and end gun aps. (Solid Stream up to 25 mph)

Wind Speed for Ground: Min. of 2mph or forecasted to reach at least 5mph.

Do not apply if unfavorable conditions exist or are forecasted for the 48 hr. following.

Do not apply if shallow, compressed temp. inversion exists or is forecast.

Do not apply if air stagnation advisory has been issued by National Weather Service.

Preferred weather source: www.nws.noaa.gov

Soil Conditionsfor applications

Must be in good tilth and free of large clods Break up hardpans Plant residue must not interfere with ap or soil

seal Do not allow plant residue to become a

“chimney” (conduit really) Soil temp. max of 90° F @ 3 inches If air temp has been 100° in any of 3 days prior,

then soil temp must be recorded in FMP

Soil Conditions(cont.)

Soil Moisture in top 6 inches 60-80% of field cap.

Moisture meter or the feel method are allowed.

In fields with multiple soil types, use the lightest texture for the moisture test

Equipment Considerations(for Pivot Application GAPs)

Anti-siphon and back-flow devices must be installed and in working order

Tanks, hoses, fittings, valves must be of approved materials, serviceable, sealed and not leaking.

Systems must contain a functional check valve, vacuum relief valve, inspection port, and low pressure drain to prevent water source contamination from backflow

Equipment Considerations(Pivot aps. cont.)

The system must have function interlock controls to automatically shut off the injection pump when the pivot shuts down

The irrigation system must include a functional pressure switch to stop the system when the pressure decreases when distribution is adversely affected

A metering pump such as a positive displacement injection pump equipped with system interlock must be used

Injection & Irrigation systems must be flushed after the application is complete

Equipment Considerations(for pivot aps. cont.)

The injection pipeline must contain a functional, automatic, quick-closing check valve to prevent back-flow to the injection pump

The injection pipeline must also contain a normally-closed, solenoid-operated valve located on the intake side of the injection pump, connected to the system interlock to prevent fluid from being withdrawn from the supply tank when the system is shut down.

Ground Equipment and Application Considerations

Do not apply or allow fumigant to drain or drip on the soil surface.

All tanks, hoses, fitting, valves and connections must be serviceable and not leaking.

Dry connect fittings must be installed on all tanks and transfer hoses.

Sight and pressure gauges must be working.

Ground Equipment cont.

Nozzles and metering devices must be correct size, sealed and unobstructed.

Use only tanks, hoses and fittings designed to withstand the pressure of the system and resistant to Metam.

Each nozzle must be equipped with a flow meter.

Do not use aluminum, brass, copper, galvanized iron, and zinc materials.

Ground Equipment cont.

Use proper filters and a check valve that is visible to the operator to prevent backflow.

All rigs must include a flow meter or monitoring device.

All rigs must have a constant pressure system w/orifice plates to ensure proper rate is applied.

Valves, vacuum relief valves, and low pressure drains must be in place, operational and leak free.

Ground Equipment cont.

Interlocking controls must be installed and functioning.

Use only positive displacement pumps. Do not use impellers made of brass, aluminum, or galvanized material.

Site-specific Fumigation Management Plan

The certified applicator must verify that a FMP exist for each application block prior to application

Execute a FMP summary after application within 30 days

Multiple application blocks may be captured in a format that all common info is captured once and unique info can be recorded in separate sections

FMP(cont.)

Applicator info: Name, phone, applicator license #, employer name & address

Site info: Location of application block (county, township, range, quadrant or address or GPS coordinates, Google Earth recommended)

Application info: Target date, Target rate, Brand of product, EPA registration number

Soil conditions & method used to determine

FMP(cont.)

Forecasted Weather conditions: (include summary of forecasted conditions & the 48 hr following the ap) Wind speed, Inversion?, Air stagnation advisory?

PPE (What equipment was made available. Was it up to date? Was it fit tested?)

Emergency procedures: Evac routes, phones available? Contact info for first responders. Local/state/tribal contacts. Key personnel, emergency procedures & responsibilities.

Example of Emergency Procedure for

Off gassing during application Don appropriate PPE Stop Application Notify at risk population (nearby residences,

occupied buildings, nearby workers, etc.) Seal the soil in the area where fumigant is

already applied a) Run water seal with straight water or b) Run tractor with roller/packer (have

tractor set up and ready)

FMP(cont.)

Posting procedures: Who will post and remove (name, address, phone) location of signs

Communication plan between applicator, owner/operator, and other on site handlers (name and phone of people contacted & date contacted)

FMP(cont.)

Authorized on site personnel (Company & Producer)

*Name, addresses, phone # of handlers *Name, address, phone # of handler employer *Tasks each handler is authorized and trained

to perform (Pest. Lic. Number) *Date of Fumigation safe handling training *Date that handlers were medically qualified for

air-purifying respirator *Date of respirator training and fit testing

FMP(cont.)

Air Monitoring Plan of work site Sensory irritation is the trip trigger Will operations continue with respirator

or shut down? If operations are to cease who (name,

address, phone) will monitor air conditions prior to resuming

Air monitoring equipment to be used

FMP(cont.)

Description of applicable GAPs (soil temp, moisture, tilth, crop residue, forecasted weather conditions, equipment up to snuff?)

Description of hazard communication (posted?, labels, FMP & MSDS on site & available?)

FMP kept for 2 yrs (both owner/operator and certified applicator must keep a signed copy)

FMP(cont.)

Now the application can begin!!!

The FMP must be at the fumigation site during the application

The FMP must upon request be available to: handlers, federal, state, local, tribal enforcement personnel, or local emergency responders

FMP(cont.)

Post application summary must be completed by the certified applicator within 30 days after the application

The summary must include:

*Actual date of application, rate of product & size of application block

*summary of weather at application & the

48 hrs following

FMP(cont.)

Summary cont:

*Complaint details (if applicable): who complained, when, control measures employed

*Description of incidents, i.e. equipment failures, or other emergency and procedures followed to rectify

FMP(cont.)

Details of elevated air concentrations (if applicable)

*location of elevated levels

*date and time of sensory irritation

*who experience sensory irritation

*what task was the handler involved in

*resulting action (cease operation, leave area, continue with respirator)

FMP(cont.)

Details of elevated air concentrations cont.

*When using a direct read instrument:

*date, time & place sample was taken

*handler task

*air concentration observed

*sampling method

http://www.epa.gov/oppsrrd1/reregistration/soil_fumigants/