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On The Fumigant Front

By J.W. Noling | Andrew MacRae|August 17, 2011

When the new fumigant labels appeared in January, every fumigant applicator in the state was confronted with a variety of new compliance requirements, which would redefine the way they would use fumigants on the farm.

The new labels include a new requirement to prepare a site-specific fumigant management plan (FMP) before beginning a fumigant application in the field on any given day. The FMP requires applicators to document (in writing) how they intend to comply with all of the new fumigant label changes and requirements. For example, the FMP will require a description of how the certified applicator plans to comply with label requirements for mandatory good agricultural practices, air monitoring, worker training, and personal protective equipment (PPE) certifications. The FMPs also will require the applicator to identify the names and addresses of all handlers participating in the fumigation prior to the event, including a description of the tasks each are trained and authorized to perform, PPE requirements for each, and dates of PPE and safety training certification. For some growers who maintain a large permanent staff of field workers, this will not represent a significant obstacle. But for other growers whose labor force is determined by the number of workers a labor crew leader was requested to bring to the field on the day of fumigation, this will represent a pretty significant challenge to document and train the workers prior to fumigation.

This time-dated practice of adding labor the day of is going to have to change if applications are to be compliant and fumigants are to be used. Videos from fumigant registrants are available now that could be shown on site or in transit (if necessary) to expedite the handler training process. In this way, the video — in combination with other hard copy training documents — could be used and distributed quickly to generate an updated list of trained handlers prior to the start of fumigation activities to ensure label compliance and accuracy of the FMP.

Lessons Learned

In the process of educating growers on the new fumigant label requirements, we have come to learn what we believe are other significant challenges growers report to us with the new fumigant regulations. In recent years, regulatory requirements, which Florida growers must address (water, labor, food safety, pesticide use, nutrient management, worker health, safety, immigration status), have all broadened in scope and have become more stringent, each with their own time consuming reporting requirement. So, it should come as no surprise to hear the biggest challenge we hear from audiences of growers and applicators is finding the time to complete the FMP and to keep it updated for each day’s fumigation. To achieve this, many growers/certified applicators are now coming to the conclusion to efficiently prepare and update the FMP will require computer assistance, a skill at least some applicators will have to newly acquire. There are a number of new electronic templates that can be downloaded at www.EPA.gov and used by applicators to provide guidance and instruction to help streamline the new reporting process.

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Authority Figures

There is another very important challenge growers and applicators repeatedly identify at the fumigation meetings we conduct, and that is the requirement of the certified applicator/restricted pesticide license holder to be at the application site from the beginning to the end of fumigant application in the field. This will represent a significant challenge for many of our growers and certified applicators to consider how they will satisfy this new fumigant label requirement for shank applications where the certified applicator must be “in the line of sight of the application and providing direct supervision of all persons performing handling activities from the very beginning to the very end of dispensing shank applied fumigants in the field.” This will surely be a problem if the operation has multiple locations with multiple fumigation crews making daily applications and having only one person holding a pesticide license or the person that holds the license is not dedicated to being on the farm at all times.
Clearly, to resolve such a problem will require licensing of new certified applicators to assume responsibilities for supervision of fumigant applications when either the primary applicator cannot remain at the site, or when fumigations are proceeding simultaneously at multiple sites.

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Joseph W. Noling is with the UF/IFAS Citrus Research and Education Center in Lake Alfred.

See all author stories here.

Andrew MacRae is with the Gulf Coast Research and Education Center in Balm.

See all author stories here.