January 18, 2007

Public Information and Records Integrity Branch (PIRIB) 

Office of Pesticide Programs (OPP)

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW.

Washington, DC  20460-0001			

Re: Soil Fumigant Cluster Risk Assessment Supplemental Information

To Whom It May Concern:

The following information is being provided to supplement comments
submitted to the Agency on Oct 12, 2005 in response to Docket No.
EPA-HQ-OPP-2005-0124 and EPA-HQ-OPP-2005-0125 for 1,3-dichloropropene
and metam sodium risk assessments, respectively. 

The Kern County Agricultural Commission’s fumigant permitting
documents* state that metam sodium applications via sprinkler require a
buffer zone of 500 feet from a sensitive area, defined as a residential
area, school, hospital, labor camp, or other area designated by the
commissioner.  Shank injection, flood or drip applications require a
buffer zone of up to 500 feet depending on the season.  For
1,3-dichloropropene, a 100-foot buffer zone is required and, as per the
label, is increased to 300 feet for the next three years.  If a
sensitive area is unoccupied, the field receiving fumigant applications
is exempt from the buffer zone requirements and applications may occur
to the property line.

This being said, we would like to bring to your attention a common
practice employed by the California carrot industry with regard to
fumigant application.  When fields near residences are to be fumigated,
the practice is to offer to arrange for the residents to stay in a hotel
until fumigation has been completed, thereby eliminating the possibility
of exposure.  

We ask that this information be included in the comments previously
submitted for the Soil Fumigant Cluster risk assessment on behalf of the
California Fresh Carrot Advisory Board.

Sincerely,

Robert Schramm

* Metam Sodium/Metam Potassium Kern County Permit Conditions (Revised
September 2003) and Kern County Permit Conditions for using
1,3-Dichloropropene (Telone) Pesticides (Fumigant)’ (Established
September 12, 2002).

 

