The agency agreed with requests from Dow AgroSciences, the Telone registrant, for reduced buffer zones from 300 feet to 100 feet, and refined protective clothing requirements, which created an impediment for soil fumigation workers in warm climates.
These important changes are the culmination of Dow AgroSciences’ efforts to develop new product application technologies and more practical approaches to protecting workers handling these products.
The development of the pre-bed, row (e.g. Yetter Rig) application technology and the generation of updated exposure data ensure the continued safety and effectiveness of Telone products. The new data support the updating of the personal protective equipment (PPE) requirements, which were mandated by EPA, during the FIFRA re-registration process, which ended in 1999.
“The scientific data we have developed during the past four years since reregistration will now result in making Telone brand soil fumigants easier for our customers to use,” said Reid Sprenkel, global business leader for Telone products.
“With the less onerous PPE requirements, concerns about heat stress illness in hot climates should be greatly reduced. And, the reduced buffer zone will mean that Telone products can be used on fields where it may have been impractical before.”
According to the new labels for the three products, when pre-bed, row application is used, product application workers and field workers (e.g. shovelmen and tractor drivers) are no longer required to wear respirators, coveralls and chemical resistant gloves and boots. Instead, they will be required to wear shoes, socks, long pants, loose-fitting long sleeved shirt and eye protection. The previous protective equipment is still required for jobs with potential for liquid contact, such as hooking up the fumigant. These jobs typically are of short duration.
Studies conducted by Dow AgroSciences demonstrate that the pre-bed, row method substantially reduces volatility and emissions into the air so that more restrictive PPE is not necessary. When that application method is used, the fumigant is injected into the soil via deep shanks and immediately covered with more soil as the bed is formed.
Workers then cover the bed with plastic. Volatility and air emissions studies also demonstrated an acceptable level of exposure when the buffer zone was reduced to 100 feet from a treated field.
EPA also modified requirements for broadcast and in-bed application methods. In addition to the PPE required for pre-bed, row applications, a half-face respirator requirement replaces the previously required full-face respirator for Telone C-17 and Telone C-35.
For these two products, no workers are required to wear a full-face respirator, unless air concentrations of chloropicrin exceed 0.1 ppm. For Telone II, a half face respirator is required.
This labeling change is not yet approved for use in all states, but Dow AgroSciences is working with state agencies to implement requirements for review and approval.