This addendum updates and supersedes ENF 09-12 concerning
the use of sulfur dioxide (SO2) in wineries relative to labeling respiratory
requirements.
Background
In June 2009, the Department of Pesticide
Regulation (DPR) corresponded with U.S. Environmental Protection Agency (EPA)
concerning The Fruit Doctor, Compressed Sulfur Dioxide, EPA Registration No. 11195
-1-AA, relative to an inconsistency in the respiratory protection
requirements between the label and the application manual referred to on the
label. The label indicates that a supplied air or self-contained breathing
apparatus (SCBA) is required in enclosed areas. However, the label is silent on
respiratory requirements when the product is used in other areas. The application
manual indicates several conflicting requirements which include: defining an
action level of 2.0 parts per million (ppm) for instituting respirator use with no
mention of being indoors or outdoors (pages 3 and 8), and requiring the use of a
National Institute for Occupational Safety and Health (NIOSH) and Mine Safety and
Health Administration (MSHA) approved respirator when making gas applications
(page 3) in direct conflict with page 8, which indicates supplied air or SCBA is
not required when making gas applications if SO2 concentration in the gassing or
work area does not exceed 2.0 ppm.
To address the labeling inconsistencies, DPR requested that U.S. EPA require
the registrant to amend the label and applicator manual accordingly. In its
response, U.S. EPA agreed that the labeling is inconsistent and can easily be
misunderstood. They also concurred with some of DPR's proposed text
modifications. However, they will not address this problem with the registrant
until 2013 when all SO2 fumigation products are scheduled for registration review.
Starting in 2013 under registration review, all SO2 labeling will be
revised/harmonized at the same time.
Interim Guidance Resolving Labeling Inconsistencies
DPR establishes the following interim guidance for respiratory protection until
U.S. EPA, through registration review, requires amendment of registered labeling
to resolve the current respiratory requirement inconsistencies.
Handlers:
- Unless an indoor fumigation work area is
continuously monitored to ensure SO2 levels measured in the work area do not
exceed 2.0 ppm, respiratory protection is required.
- If the 2.0 ppm concentration is exceeded at any
time in the indoor work area, handlers must wear a supplied-air respirator
with NIOSH approval number prefix TC-19C, or SCBA with NIOSH approval
number TC-13F.
- When handlers conduct fumigations in an outdoor
work area no respiratory protection and no monitoring is required.
Workers Other Than Handlers
If the 2.0 ppm concentration is exceeded at any time, workers other than handlers
working in an indoor fumigation work area must either leave the fumigation work
area immediately or wear the same respiratory protective equipment required for
handlers.
Continuous Air Concentration Monitoring
There are real-time air concentration monitoring devices available. Without
information as to air concentrations associated with handler indoor work
activities, respiratory protection is required. However, use of immediate read
-out real-time personal monitoring devices to continuously monitor actual
exposure levels will alleviate this requirement, provided exposure does not exceed
2.0 ppm.
Available Immediate Read-out Real-time Units
The following samplers are examples of devices that can be used to continuously
monitor indoor or outdoor fumigation work sites to ensure SO2 levels measured at
the work site do no exceed 2.0 ppm. DPR does not endorse or recommend any
particular manufacturer of such devices.
Dräger Pac 7000
Gasman-SO2
If you have any questions, please contact the Enforcement Branch Liaison
assigned to your county. |
