Site Specific Fumigant Management Plan And Post Application Summary Joel Kangiser WSDA

1. Site Specific Fumigant Management Plan And Post Application Summary Joel Kangiser WSDA

2. Site-specific management plan before fumigation begins. FMPs help to… • Ensure fumigators successfully plan all aspects of a safe and effective fumigation • Prevent accidents, ensure label compliance, and identify appropriate procedures in case of accidents or unforeseen events • Demonstrate compliance with label requirements and are a tool for verifying compliance.

3. Preparation and Verification Grower, crop consultant or others may prepare the FMP, but Certified Applicator must verify accuracy in writing (sign and date)

4. Farm-wide FMP is an option • Common information captured once • Applicator and handler information, emergency plans, etc. • Information unique to each block captured separately. • Block location, map, buffers, application dates, weather conditions, etc.

5. FMP requirements based upon requirements of respective labels (2010 vs. 2011 labels) 2010 Requirements… General Site and Applicator Information Application Procedures Measurements for GAP compliance Worker Protection Information (PPE to be worn by handlers, etc)

6. 2010 Requirements (Cont’d) • Air Monitoring and Hazard Communication • Posting (treated area) and record-keeping procedures • Emergency plans and procedures • Safe handling information provided • Post-application summary report

7. 2011 Requirements How buffers were determined, including credits Site map or sketch Measurements taken to verify credits warranted Buffer zone posting procedures

8. 2011 Requirements (Cont’d) • Emergency preparedness and response procedures (if required for a site) • Applicator training records • State notification record (if required by the state)

9. FMP Versions EPA Templates Currently Have Methyl Bromide Templates Turbo Tax In Progress Dealer/Consultant Versions In Progress Roll Your Own

10. FMP Sample Template 10 10

11. Figure 1. Example of Introductory Screen 11 11

12. Figure 2. Example of screen illustrating applicator and other general information 12 12

13. Figure 3. Example of screen illustrating general site information 13 13

14. Figure 4. Example of screen illustrating general application information 14 14

15. FMP Must be Available to… Handlers involved in the application for viewing on site. Enforcement personnel, upon request. Emergency response personnel, in case of an emergency.

16. Post Application Summary Documents any deviations from the FMP, such as weather conditions, actual application dates, etc. • Completed within 30 days of the application; keep with FMP • Not necessary if there are no changes from FMP

17. FMP Record Keeping • FMPs & Post Application Summaries - 2 years by • The supervising certified applicator and • The owner/operator (if not the certified applicator) • Along with other records required for application of RUPs • Possibly combine FMP and Application Record? 17

18. Comments and Concerns Realistic to bring all applicators to level of large operations that have resources to create FMPs? Will it be counter-productive – eg, will applicators not comply because the requirements are too extensive? What good will it be to Hispanics who cannot read English and are very likely at a low literacy level in their native Spanish?

19. Comments/Concerns… • Commercial Applicators will need to become much more familiar with a farm • Keep it simple – Can a typical soil fumigator understand what the label requires in the FMP? And finally… • Patience, Patience, Patience – Will need to provide much technical assistance.

20. Questions ???