Updates to Volume 3, Restricted Materials and Permitting Compendium: Field Fumigation Methods for Reduced Volatile Organic Compound Emissions

The Director of the Department of Pesticide Regulation (DPR) has signed the Director‘s Decision to approve three field fumigation methods as Reduced Volatile Organic Compound Emissions Field Fumigation Methods, pursuant to California Code of Regulations, Title 3 (3 CCR), section 6452. The three newly-approved methods are named:

• Nontarpaulin/Deep/Strip
• Nontarpaulin/Deep/GPS-targeted
• Tarpaulin/Deep/Broadcast-strip – with tarp eligible for 60 percent credit

Interim approval of the three new methods is effective August 1, 2014 and continues for three years from the effective date.

The Methods

The first two of the newly-approved methods are modified versions of the “Nontarpaulin/Deep/Broadcast” method described within 3 CCR section 6448.1(d)(5). In order to reduce Volatile Organic Compound (VOC) emissions during applications of 1,3 Dichloropropene or chloropicrin, the “Nontarpaulin/Deep/Broadcast” method is modified by applying fumigant only within strips that are separated from each other by untreated areas. Strip application is often used for orchard or vineyard replant, and may be controlled either manually or via a Global Positioning System (GPS). To qualify as a reduced VOC method, the total fumigated area must not exceed 60 percent of the application block. In addition, an individual application block may not be fumigated more than once in any calendar year (i.e., “split” applications are prohibited).

The third newly-approved method is a modified version of the “Nontarpaulin/Deep/Broadcast” method described within 3 CCR section 6448.1(d)(6). To qualify as a reduced VOC method, the tarpaulins must meet the requirements for a 60 percent buffer zone credit on the fumigant product labeling. Such tarps are commonly referred to as totally impermeable film (TIF) tarps.

All fumigation method requirements (e.g., injection depth and tractor implements) specified in the 3 CCR sections cited in the enclosed table still apply.

The only change is the use of strip application and (when used) the use of tarps that meet the requirements for a 60 percent buffer zone credit. DPR’s recommended permit conditions for field fumigants specify that tarps that meet the requirements for any percentage buffer zone credit, including TIF tarps, must not be cut or perforated sooner than nine days after fumigation, and must not be removed sooner than 24 hours after tarp cutting or perforation.

Pesticide Use Reporting

These three new methods have been assigned codes for pesticide use reporting, and have been incorporated into the table of approved field fumigation methods. That table is enclosed with this letter.

For pesticide use reporting, pesticide users should begin using the new method codes shown in the enclosed table immediately, or as soon as their pesticide use reporting vendor updates its software. County agricultural commissioners may use enforcement discretion when reviewing field fumigation method codes on use reports, because there may be a lag time to inform all affected parties of these changes and to update vendors’ pesticide use reporting software.

Enclosed is an updated version of a factsheet explaining how to file pesticide use reports for field fumigant applications. For field fumigant applications made within an ozone nonattainment area, 3 CCR section 6626(d) requires that the pesticide use report include a description of the method of application. If portions of your county are located within a nonattainment area, please use the enclosed factsheet to remind users within those areas to include the application method on pesticide use reports for field fumigant applications. When reviewing pesticide use reports, please verify that the method of application is included when required.

The enclosed table replaces Appendix Section G.2 of the Pesticide Use Enforcement Program Standards Compendium, Volume 3 – Restricted Materials and Permitting. Users of Volume 3 should remove the old Appendix Section G.2 (three pages) and insert the new version (three pages).

If you have questions, please contact the Enforcement Branch Liaison assigned to your county.

Sincerely,