Methyl Bromide for Post Harvest Uses Anticipated Label Changes - - PowerPoint PPT Presentation

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

Methyl Bromide Reregistration

Pre-plant Uses

• Amended labels – late 2010
• Further amendments in 2011

Methyl Bromide Reregistration

Post Harvest Uses

• Amended labels – 2011 or 2012

Post Harvest Label Changes

• Tolerances
• Fumigation Management Plans
• Buffer Zones
• Posting and Notification
• Record Keeping
• Respiratory Protection
• Monitoring
• Minimum Aeration Times

Tolerances

• Based on residue studies conducted in the mid-

1990’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.

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

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.

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

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.)

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
• r alternate methods
• Minimum buffer zone – 10 feet
• Exceptions
• Occupied structures, if monitored
• Non-occupied structures
• Transit – roads and railroads

Internal Concentration Data 24 hours

Aeration begins Gas Release

Treatment Aeration

ppmv

Fumigation Concentration Profile

Example Buffer Zones

Treatment buffer zone Aeration buffer zone

Buffer Zone Table - Example

Buffer Zones (m) During Treatment Period of 24 Hours or Greater App Rate (lbs/1,000 ft3) % Release Volume (1,000 ft3) 10 25 50 100 250 500 750 1,000 1 25 0† 0† 0† 0† 15 35 55 70 2 25 0† 0† 0† 20 45 80 110 135 3 25 0† 0† 5 30 70 115 155 185 4 25 0† 0† 15 45 90 145 195 230 Buffer Zones (m) During Aeration Period of 8 Hours or Less Application Rate lb/1000ft3 % Release Volume (1,000 ft3) 10 25 50 100 250 500 750 1,000 1 75 0† 0† 0† 0† 60 115 160 195 50 0† 0† 0† 0† 0† 65 90 115 2 75 0† 0† 0† 40 135 225 345 455 50 0† 0† 0† 0† 85 155 210 265 3 75 0† 0† 0† 85 195 360 550 710 50 0† 0† 0† 40 135 225 345 455 4 75 0† 0† 40 120 255 495 715 910 50 0† 0† 0† 70 175 315 485 635

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

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

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

• n-site personnel.
• Records must be available on request to
• Local, state, tribal, or Federal pesticide enforcement officials
• Any interested individuals in the community.

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

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.

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.