Labeling Changes Summary Table					

In order to be eligible for reregistration, amend all product labels to
incorporate the risk mitigation measures outlined in the following
tables. 

  Table 9: Summary of Labeling Changes for Sulfur Dioxide





Description	

Amended Labeling Language	

Placement on Label



For all Manufacturing Use Products	

“Only for formulation for the following use(s): to treat grapes for
the fungus Botrytis cinerea  in warehouse fumigation chambers, trucks,
vans, and trailers, or to treat grapes for the control of black widow
spider in warehouse fumigation chambers.” 	

Directions for Use



One of these statements may be added to a label to allow reformulation
of the product for a specific use or all additional uses supported by a
formulator or user group	

“This product may be used to formulate products for specific use(s)
not listed on the MP label if the formulator, user group, or grower has
complied with U.S. EPA submission requirements regarding support of such
use(s).

This product may be used to formulate products for any additional use(s)
not listed on the MP label if the formulator, user group, or grower has
complied with U.S. EPA submission requirements regarding support of such
use(s).”	

Directions for Use



Environmental Hazards Statements Required by the RED and Agency Label
Policies 	“This product may be toxic to plants.  Do not discharge
effluent containing this product into lakes, streams, ponds, estuaries,
oceans, or other waters unless in accordance with the requirements of a
National Pollutant Discharge Elimination  System (NPDES) permit and the
permitting authority has been notified in writing prior to discharge. 
Do not discharge effluent containing this product to sewer systems
without previously notifying the local sewage treatment plant authority.
 For guidance contact your State Water Board or Regional Office of the
EPA.”	

Precautionary Statements





Restricted Use Classification	“RESTRICTED USE PESTICIDE

Due to inhalation toxicity. For retail sale to and use only by certified
applicators, only for those uses covered by the certified applicator’s
certification.”

	

Identify as a fumigant any methyl bromide end-use product containing
directions for use for commodity fumigation 

   	

Prominently identify the end-use product as a  “  SEQ CHAPTER \h \r 1
Fumigant” 

	

Insert the word “fumigant” as part of the product name or close to
the product name, either as part of the product-type identification or
as a separate word or sentence

Add acceptable air concentration language to any sulfur dioxide end-use
products 	  SEQ CHAPTER \h \r 1 "MONITORING AIR CONCENTRATION LEVELS

The air concentration level must be measured by a direct reading
detection device, such as a Matheson-Kitagawa, Draeger, or Sensidyne. 
If respirator requirements are triggered as specified in the
‘Respirator Requirements’ section of this labeling, respiratory
protection must continue for persons in the treatment area until two
consecutive air concentration samples taken at least 15 minutes apart
indicate sulfur dioxide air concentration levels of 2 ppm or less. If
either of the two samples taken indicate a sulfur dioxide air
concentration level greater than 2 ppm, appropriate respiratory
protection must continue until two additional air concentration samples
taken at least 15 minutes apart indicate that sulfur dioxide air
concentration levels are 2 ppm or less.

 

Recordkeeping:  Records must be kept of all sulfur dioxide air
monitoring."

	  SEQ CHAPTER \h \r 1 In the Hazards to Humans and Domestic Animals
section of the labeling immediately following the precautionary
statements.

PPE requirements established by the RED for sulfur dioxide end use
products 	“PERSONAL PROTECTIVE EQUIPMENT (PPE)

Some materials that are chemical-resistant to this product are
(registrant inserts correct chemical-resistant material).  If you want
more options, follow the instructions for category [registrant inserts
A,B,C,D,E,F,G,or H] on an EPA chemical-resistance category selection
chart.

Applicators and other handlers must wear:

-Long-sleeved shirt and long pants,

-Chemical-resistant apron, 

-Chemical-resistant footwear plus socks, and

-Sulfur dioxide-resistant gloves

In addition, when applying sulfur dioxide or checking connections,
handlers must wear a full-face or hood-style NIOSH/MSHA-approved
respirator with: 

-- a cartridge providing protection against sulfur dioxide (registrant
to provide MSHA/NIOSH approval numbers), or

-- a canister approved for sulfur dioxide (registrant to provide
MSHA/NIOSH approval numbers).

Respirator Requirements: 

After sulfur dioxide has been introduced into an enclosure, do not enter
or allow others to enter warehouse fumigation chambers, trucks, vans,
railcars, or trailers without respiratory protection, until the air
concentration is measured to be 2 ppm or lower.  See the “Monitoring
Air Concentration Levels” section for additional requirements.  The
certified applicator supervising the fumigation must make sure that all
persons in the treatment area and within the aeration buffer zone have
appropriate respiratory protection or are kept out of the exposure area
until the air concentration is measured to be 2 ppm or lower.

Air Concentration of greater than 2 ppm up to 10 ppm

If the air concentration of sulfur dioxide in the fumigation area or
aeration buffer zone is greater than 2 ppm, but not higher than 10 ppm,
all persons working in or remaining in the exposure area must wear the
respirator required for applicators in the PPE section of this labeling.

Air Concentration Greater than 10 ppm   

If the air concentration of sulfur dioxide in the fumigation area or
aeration buffer zone is greater than 10 ppm  or when sulfur dioxide
concentrations are unknown, each person in the exposure area must wear
either 

-- a supplied-air respirator (MSHA/NIOSH approval number prefix TC-19C),
or 

-- a self-contained breathing apparatus (SCBA) (MSHA/NIOSH approval
number prefix TC-13F)." 	Immediately following/below Precautionary
Statements: Hazards to Humans and Domestic Animals

Label bearing directions for fumigation in trucks, vans, railcars and
trailers

	“When treating grapes in a truck, trailer or other transport vehicle,
do not release into the atmosphere treated air containing concentrations
of sulfur dioxide in excess of 2 ppm as measured by a direct reading
detection device, such as a Matheson-Kitagawa, Draeger, or Sensidyne.

Sulfur dioxide concentration in transport vehicles must be below 2 ppm
before moving over public roads or highways.

Do not perform sulfur dioxide aerations concurrently from multiple
chambers.”	Label Bearing Directions Immediately Following Use
Directions.

Label bearing directions for warehouse fumigation

	“When treating grapes for Botrytis cinerea (bunch rot/gray mold) or
black widow spider in a warehouse fumigation chamber, do not release
into the atmosphere treated air containing concentrations of sulfur
dioxide in excess of 30 ppm as measured by a direct reading detection
device, such as a Matheson-Kitagawa, Draeger, or Sensidyne.

Do not perform sulfur dioxide aerations concurrently from multiple
chambers.”	Label Bearing Directions Immediately Following Use
Directions.

Restrictions during warehouse aeration

	See aeration buffer zone table in Attachment I.  Table to appear on the
label exactly as it appears in Attachment 1.

“The certified applicator supervising the fumigation must determine
the buffer zone (the appropriate distance from the point of release)
that must be maintained during aeration until the air concentration
exhausted from the treatment warehouse is 30 ppm or less." 	Directions
for Use for Fumigation under the heading “Buffer Zones”



User Safety Requirements	“User Safety Requirements

Respirator Requirements: When a respirator is required for use with this
product, the certified applicator supervising the fumigation must ensure
that:

--respirators are fit tested and fit checked using a program that
conforms with OSHA’s requirements (described in 29 CFR Part 1910.134)

--respirator users are trained using a program that conforms with
OSHA’s requirements (described in 29 CFR 1910.134)

--respirator users have been examined by a qualified medical
practitioner to ensure the physical ability to safely wear the style of
respirator to be worn; --respirators are maintained according to a
program that conforms with OSHA’s requirements (described in 29 CFR
Part 1910.134)

Follow manufacturer’s instructions for cleaning/maintaining PPE.  If
no such instructions for washables exist, use detergent and hot water. 
Keep and wash PPE separately from other laundry.

Discard clothing and other absorbent materials that have been drenched
or heavily contaminated with this product’s concentrate. Do not reuse
them.”	

Precautionary Statements:  Hazards to Humans and Domestic Animals
immediately following the PPE requirements



User Safety Recommendations	“User Safety Recommendations

Users should remove clothing/PPE immediately if pesticide gets inside.
Then wash thoroughly and put on clean clothing.

Users should remove PPE immediately after handling this product.  Wash
the outside of gloves before removing. As soon as possible, wash
thoroughly and change into clean clothing.

Users should remove PPE immediately after handling this product.  Wash
the outside of gloves before removing.  As soon as possible, wash
thoroughly and change into clean clothing.”	

Precautionary Statements under:  Hazards to Humans and Domestic Animals
immediately following Engineering Controls

(Must be placed in a box.)

Environmental Hazards	“This product may be toxic to plants.  Do not
discharge effluent containing this product to sewer systems without
previously notifying the local sewage treatment plant authority.  For
guidance contact your State Water Board or Regional Office of the
EPA.”	

Precautionary Statements immediately following the User Safety
Recommendations



Notification Requirements for all fumigations	  SEQ CHAPTER \h \r 1
PLACARDING OF FUMIGATED AREAS

The certified applicator in charge of the fumigation (or someone under
his/her supervision) must placard all entrances to the fumigated area
with signs bearing: 

“-- skull and crossbones symbol 

-- DANGER/PELIGRO, 

-- Area under fumigation, DO NOT ENTER/NO ENTRE,

-- Sulfur Dioxide Fumigant in use, 

-- the date and time of fumigation, and

-- name, address, and telephone number of the certified applicator in
charge of the fumigation.”

“Do not allow entry by unprotected persons into the fumigated area
until the signs are removed.  Such signs must only be removed when the
air concentration level of sulfur dioxide is 2 PPM or less.  Signs must
remain legible during entire posting period.”

  SEQ CHAPTER \h \r 1 "The warning signs at entrances to fumigated
structures may only be removed by the certified applicator in charge of
the fumigation (or someone under his/her supervision)."  

  SEQ CHAPTER \h \r 1 "Vehicles must be placarded with D.O.T. specified
warning signs."  SEQ CHAPTER \h \r 1 	In the Directions for Use for
Commodity Fumigation under the heading “PLACARDING FUMIGATED AREAS” 






  Table XX: Summary of Labeling Changes for Sodium Metabisulfite 





Description	

Amended Labeling Language	

Placement on Label



For all Manufacturing Use Products	

“Only for formulation for the following use(s) [as a impregnable pad
preservative to treat grapes for the fungus Botrytis cinerea.]”	

Directions for Use



One of these statements may be added to a label to allow reformulation
of the product for a specific use or all additional uses supported by a
formulator or user group	

“This product may be used to formulate products for specific use(s)
not listed on the MP label if the formulator, user group, or grower has
complied with U.S. EPA submission requirements regarding support of such
use(s).

This product may be used to formulate products for any additional use(s)
not listed on the MP label if the formulator, user group, or grower has
complied with U.S. EPA submission requirements regarding support of such
use(s).”	

Directions for Use



Environmental Hazards Statements Required by the RED and Agency Label
Policies 	

“This product may be toxic to plants.  Do not discharge effluent
containing this product into lakes, streams, ponds, estuaries, oceans,
or other waters unless in accordance with the requirements of a National
Pollutant Discharge Elimination  System (NPDES) permit and the
permitting authority has been notified in writing prior to discharge. 
Do not discharge effluent containing this product to sewer systems
without previously notifying the local sewage treatment plant authority.
 For guidance contact your State Water Board or Regional Office of the
EPA.”	

Precautionary Statements

Label Statements for Sodium Metabisulfite  End Use Products Intended for
Occupational Use



PPE Requirements Established by the RED for Sodium Metabisulfide End Use
products 	“Personal Protective Equipment (PPE)

Applicators, and other handlers must wear:

-Long-sleeved shirt, long pants and,

-Shoes plus socks.”	Immediately following/below Precautionary
Statements: Hazards to Humans and Domestic Animals

User Safety Requirements	“Follow manufacturer’s instructions for
cleaning/maintaining PPE.  If no such instructions for washables exist,
use detergent and hot water.  Keep and wash PPE separately from other
laundry.”	Precautionary Statements:  Hazards to Humans and Domestic
Animals immediately following the PPE requirements

User Safety Recommendations	“User Safety Recommendations

Users should wash hands before eating, drinking, chewing gum, using
tobacco, or using the toilet.

Users should remove clothing/PPE immediately if pesticide gets inside. 
Then wash thoroughly and put on clean clothing.

Users should remove PPE immediately after handling this product.  Wash
the outside of gloves before removing*.  As soon as possible, wash
thoroughly and change into clean clothing.”	Precautionary Statements
under: Hazards to Humans and Domestic Animals immediately following
Engineering Controls

(Must be placed in a box.)

Precautionary Statements

NOTE:  this statement must be printed on each individual pad in a manner
that is legible and will remain legible for the life of the pad	“This
pad contains sodium metabisulfide which may trigger an asthmatic
response in sulfite sensitive individuals.”  	Hazards to Humans and
Domestic Animals

General Application Restrictions

NOTE:  these statements must be printed on each individual pad in a
manner that is legible and will remain legible for the life of the pad	

“This pad must be removed and disposed of prior to displaying grapes
for sale.  Do not allow consumers access to pads.

If pad is torn: Carefully dispose of pad, pad contents, and grapes which
have contacted pad contents.

For Disposal: Place pad in a plastic bag, seal bag and place in an
outdoor trash receptacle (dumpster).”	Directions for Use



1 PPE that is established on the basis of Acute Toxicity of the end-use
product must be compared to the active ingredient PPE in this document. 
The more protective PPE must be placed in the product labeling.  For
guidance on which PPE is considered more protective, see PR Notice 93-7.

			

ATTACHMENT I

Buffer Zones (in Feet) Required During Aeration with SO2 concentrations
in Excess of 30 ppm

		The following tables indicate the required aeration buffer zone size
(in feet).  Aeration buffer zone size is determined from the treatment
chamber 	volume, the initial release SO2 concentration expected during
aeration, and by the flowrate of the treated air during aeration.  Only
persons supervising or 	performing fumigation activities are permitted
within the buffer zones.  An aeration buffer zone must be established
and maintained until the sulfur dioxide 	concentration being exhausted
is less than 30 ppm.  The buffer zone must be measured from below the
center point of the stack at ground level.  If multiple 	stacks are used
to exhaust treated air, measure from each stack and use the largest
resulting buffer zone.

			Table 1.

Treatment Chamber Volumes up to 9,500 ft3

Application Rate

(ppm)	Initial Release Air SO2 Concentration        (ppm)	Treated Air
Release Flowrate (in ft3/minute)



Greater than 6,000 up to  10,000 ft3/min	Greater than 10,000 up to
14,000 ft3/min	Greater than 14,000 up to 17,000 ft3/min	Greater than
17,000 ft3/min

!0,000	>2500 up to 3000	328	296	246	214

	> 2000 up to 2500	296	246	214	164

	>1500 up to 2000	246	214	164	132

	> 1000 up to 1500	197	164	115	82

	30 up to 1000	132	99	66	33



			Table 2.

                                    Treatment Chamber Volumes between
9,500 and 15,000 ft3

Application Rate

(ppm)	Initial Release Air SO2 Concentration        (ppm)	Treated Air
Release Flowrate (in ft3/minute)



Greater than 6,000 up to  10,000 ft3/min	Greater than 10,000 up to
14,000 ft3/min	Greater than 14,000 up to 17,000 ft3/min	Greater than
17,000 ft3/min

!0,000	>2500 up to 3000	443	410	361	328

	> 2000 up to 2500	394	361	312	279

	>1500 up  to 2000	328	296	263	230

	> 1000 up to 1500	279	230	197	148

	30 up to 1000	197	164	132	82



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