Department of Pesticide Regulation
Chris Reardon
Acting Director
  Edmund G. Brown Jr.
Governor
 
 
October 26, 2011   ENF 11-28
 
 
TO:
County Agricultural Commissioners  
 
SUBJECT:
SULFURYL FLUORIDE STRUCTURAL LABELING CHANGES:
CHLOROPICRIN PPE / PRECAUTIONARY STATEMENTS
 
 

There have been some revisions to the Sulfuryl Fluoride (SF) structural fumigant labels. The product labels and applicator/structural fumigation manuals were revised in early 2011 to include personal protective equipment (PPE) to be worn when applying the warning agent chloropicrin, employer responsibilities for care/maintenance of PPE, and procedures for using chloropicrin. These revisions were mandated by the U.S. Environmental Protection Agency (U.S. EPA) to mitigate risks to applicators.

Products currently registered and available in California:

VikaneEPA Registration #62719-4Registrant: Dow AgroSciences LLC
Zythor EPA Registration #81824-1Registrant: Ensystex II, Inc.
Master FumeEPA Registration #19713-596Registrant: Drexel Chemical Company

Products coming into the Channels of Trade:
Registrants must begin selling SF cylinders with the newly revised labeling (product labels and applicator manuals) by December 10, 2011. All three registrants expect to have their updated product in the marketplace during Fall of 2011.

There could be a mix of existing and updated product in the marketplace, and thus at the fumigation site. Applicators must have the appropriate applicator manual corresponding to the product label being used.

Most Significant Change:
Respiratory Protection requirement when applying chloropicrin:

“Persons applying chloropicrin must wear either a positive pressure self-contained breathing apparatus or combination air-supplied/SCBA when applying chloropicrin to more than two chloropicrin introduction points within a single fumigated structure.”

Thus, each person (applicator) can apply chloropicrin to 2 chloropicrin introduction points (pic pans) without wearing SCBA within a single fumigated structure. Placement of four (4) pic pans could be done by two applicators, each applying to 2 pic pans, without wearing SCBA.

Reminder: Persons applying chloropicrin must be a certified applicator (licensed Field Representative or Operator) or be under the supervision of an on-site certified applicator.

Other Changes added to labeling

  1. Chemical-resistant (C-R) Gloves. Each SF product refers to differing:
    1. Chemical-resistant materials
    2. Category on the U.S. EPA Chemical-Resistance Category Chart
  2. Protective Eyewear. Protective eyewear for Chloropicrin differs from that required for SF
  3. Employer responsibility for provision/use/care/maintenance of Chloropicrin PPE
  4. Directive regarding placing pic pans and exiting the structure.

Determining Chemical-Resistant Materials for Personal Protective Equipment

  1. The DPR Glove Category Selection Key which should be used for selecting gloves is enclosed.
  2. The U.S. EPA Chemical-Resistance Category Chart referred to on the product labels is also available as a general reference guide for types of PPE materials.

The chart Sulfuryl Fluoride Labeling Changes which provides details and a comparison of the product labeling statements and recent changes is enclosed.

If you need further assistance, please contact the Enforcement Branch Liaison assigned to your county.

 
Sincerely,
 
 
Original Signature by:
 
Nan Gorder, Ph.D.
Chief, Enforcement Branch
916-324-4100

 
Glove Category Selection Key, PDF (35 kb)
Sulfuryl Fluoride Labeling Changes, PDF (14 kb)

cc:       Mr. Tom Babb, DPR Agricultural Commissioner Liaison
            Mr. William Douglas, SPCB Interim Registrar
            Enforcement Branch Liaisons



 
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A Department of the California Environmental Protection Agency