Training and Development

Fumigation Information for Tarp Fumigation Customers

There are new EPA regulations regarding the application of fumigants under tarp that you need to be aware. Trident will assist you in understanding and complying with these new regulations. Some of the highlights are as follows-

1. New EPA labeling requires substantially more record keeping and information. Fumigation Management Plans are a new item that Trident will review with you. These detailed records include items such as documentation of customer-provided worker training and respirator information, site specific information, tarp repair and removal plans, air monitoring requirements, Post-Fumigation summary, and Emergency Evacuation procedures. These records must be kept by the customer for a minimum of 2 years.
2. EPA regulations stipulate that all handlers (including customer-provided workers) assisting in tarp applications be trained annually. Trident will provide training materials in this regard. EPA has provided a 2 page summary of the fumigation process (English and Spanish) and also has available other presentations on their website.
   • http://www.epa.gov/pesticides/reregistration/soil_fumigants/soil-fum-handlers.html
3. Handlers (including customer-provided workers) need to be fit-tested annually and provided full-face respirators. Trident can review handler definitions and who should have respirators. A one-time medical evaluation will be required for each respirator user. An account can be set up for Online Medical Evaluations at www.respexam.com. Some useful information from Oregon OSHA or Washington DLI/WISHA respiratory program requirements can be found listed below.
   • http://www.orosha.org/subjects/respiratory_protection.html
   • http://www.lni.wa.gov/wisha/Rules/respirators/default.htm

   Each product label has specific qualifiers for when a respirator needs to be worn. In general, respirators will not be routinely needed, but in order to comply with certain instances (sensory irritation, tarp repair, early tarp removal) and to avoid stop-work triggers (application/tarp repair/removal delays) it is necessary that trained handlers have respirators available on site. Once Trident leaves the site after application, it is imperative that there be fit tested and trained personnel available to the customer.

   Trident currently uses 3M 6800 Full Face respirators equipped with Model 60928 cartridges for products with Methyl Bromide and 60921 cartridges for products with Telone®. The 3M website further provides e-tools to help you comply with Medical Evaluations, Fit Testing, and Training (www.3M.com/fittest).

4. Buffer Zones are now officially implemented with fumigants. Trident has been studying the latest information and will review your best options available to comply with EPA regulations.