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: Chloropicrin Risk Assessment Comments

To Whom It May Concern:

The following information is being provided in response to Docket No.
EPA-HQ-OPP-2006-0661 for the chloropicrin risk assessment. 

The Kern County Agricultural Commission’s fumigant permitting
documents* state that specify buffer zone requirements for chloropicrin
applications near sensitive areas, defined as residential areas,
hospitals, labor camps, or other areas designated by the commissioner. 
Schools are categorized separately for chloropicrin applications.  A
buffer zone of up to 1 mile is required near a school and up to one half
mile near a sensitive area, depending on the application method
(injection or drip) and subsequent sealing method (water seal, tarp, bed
shaper, etc.).    However, 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 for the
Chloropicrin risk assessment on behalf of the California Fresh Carrot
Advisory Board.

Sincerely,

Robert Schramm

* Kern County Chloropicrin Permit Conditions (May 2004).

 

