Site SpecificFumigant Management Plan

And

Post Application Summary

Joel KangiserWSDA

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.

Grower, crop consultant or others may prepare the FMP, but

Certified Applicator must verify accuracy in writing (sign and date)

Preparation and Verification

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.

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)

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

2011 Requirements

How buffers were determined, including credits

Site map or sketch

Measurements taken to verify credits warranted

Buffer zone posting procedures

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)

FMP VersionsEPA Templates

Currently Have Methyl Bromide Templates

Turbo TaxIn Progress

Dealer/Consultant VersionsIn Progress

Roll Your Own

1010

FMP Sample Template

1111

Figure 1. Example of Introductory Screen

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

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Figure 3. Example of screen illustrating general site information

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Figure 4. Example of screen illustrating general application information

FMP Must be Available to…

Handlers involved in the applicationfor viewing on site.

Enforcement personnel, upon request.

Emergency response personnel, in case of an emergency.

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

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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?

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?

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.

Questions ???