Pesticides

Impacts of Phase 1 label changes for applicators, dealers, growers, and property owners 

General impacts

• Labeled uses cover a large cross-section of industries in Wisconsin including vegetable and fruit crops, nurseries, greenhouses, turf, and ornamentals.
• As mentioned above, the new safety measures are extensive. As a result, the new product labels are substantially longer than the old ones.
• Soil fumigant applicators will need to continue to read and understand the new labels in advance of making applications; there are several requirements that will require advance preparation.

Examples of specific Phase 1 impacts.

• Note: this list is by no means comprehensive. More information about the requirements is available at EPA’s website (see resources section below) and on the new product labels.
• All soil fumigant products containing any of the active ingredients listed above will now be classified as restricted use pesticides (RUP). Previously, not all soil fumigants were restricted use. RUP dealers can only sell RUPs to certified pesticide applicators and must meet state licensing and recordkeeping requirements. All applicators, and persons involved in the application of RUPs, must be certified in an appropriate certification category and currently licensed in order to apply one of these soil fumigants.
• The fumigant management plan (FMP) label requirements will require advance preparation. The requirements are very extensive and prescriptive. Applicators will be required to ensure that a written site-specific FMP exists prior to the application. Growers or property owners will likely need to provide some of the details required for FMPs. EPA states that written plans and procedures for safe and effective applications will help prevent accidents and misuse and will capture emergency response plans and steps to take in case an accident occurs. Templates are available at EPA’s website (see resources section below) along with templates developed by industry. (See resource section below and link to Agrian Inc.) The applicator supervising the application must also complete a post-application summary within 30 days if there are any deviations from the FMP.
• Handler and worker protection requirements will require advance preparation. For example, new respiratory protection requirements will require handlers to either use air-purifying respirators or stop working and leave the area if handlers experience sensory irritation. Other respiratory protection requirements include: air monitoring while handlers wear respirators; fit-testing, training, and medical examination of handlers who will wear a respirator; and availability of an air purifying respirator with the appropriate cartridges for each handler who will wear a respirator. Other protection requirements include tarp perforation, tarp removal, and entry-restricted period requirements.
• The new labels include many mandatory good agricultural practices. These practices previously were advisory but are now required.