Department of Pesticide Regulation

VOLATILE ORGANIC COMPOUND EMISSIONS REDUCTION METHODS USING TOTALLY IMPERMEABLE FILM (TIF) TARPAULINS

The Director of the Department of Pesticide Regulation (DPR) has signed the Director's Decision to approve certain 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 newly approved methods use tarpaulins that meet the requirements for a 60% buffer zone credit on the fumigant product labeling. Such tarps are commonly referred to as totally impermeable film (TIF) tarps.

The TIF 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. Interim approval of the TIF methods is effective May 1, 2013 and continues for three years from the effective date.

For pesticide use reporting, pesticide users should begin using the TIF method codes shown in the enclosed document 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 will be a lag time to inform all affected parties of these changes and to update vendors' pesticide use reporting software.

All fumigation method requirements (e.g., injection depth and tractor implements) specified in the 3 CCR sections cited in the enclosed document still apply. The only change is that a tarp that meets the requirements for a 60% buffer zone credit on the fumigant product label must be used instead of a standard polyethylene tarp. 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 9 days after fumigation, and must not be removed sooner than 24 hours after tarp cutting or perforation.

The enclosure 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 (two pages) and insert the new version (three pages).

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

cc:   Ms. Nan Gorder, Chief, Pest Management and Licensing Branch
        Mr. Joe Marade, DPR Agricultural Commissioner Liaison