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Department of Pesticide Regulation

The Great Seal of the State of California
Brian R. Leahy
  Edmund G. Brown Jr.
April 20, 2012   ENF 12-04
County Agricultural Commissioners  



The current soil fumigant labels state that handlers performing certain tasks--those without liquid contact potential--must wear certain protective garments, but cannot wear gloves.

Previous DPR interpretation, based on U.S. Environmental Protection Agency (U.S. EPA) labels, was that wearing any type of glove was prohibited, even for the handlers performing tasks without liquid contact potential such as tarp shoveling. The purpose of this prohibition was to prevent methyl bromide from being trapped between the gloves and skin, which can result in chemical burns.

The interpretation has been revisited to prohibit the wearing of chemical-resistant gloves, but to allow the wearing of cloth or leather gloves for tasks which don‘t have liquid contact potential. This is to protect those handlers‘ bare hands from cold or abrasion injuries such as blisters or cuts. See also ENF letter 11-25, question #47 which outlines activities with liquid contact potential.

Recently, U.S. EPA has changed the glove requirement on the labels. The upcoming U.S. EPA phase II labels for methyl bromide and 1,3-D will state the following:

"Handlers with no potential contact with liquid fumigant (e.g. shovelers) may wear cotton, leather, or other porous, non-chemical resistant gloves. If such gloves are exposed to liquid fumigant, they must immediately be removed and discarded."

So, only the use of chemical resistant gloves will be prohibited.

In anticipation of U.S. EPA label revisions which will become effective December 1, 2012, DPR is providing an interim interpretation of the current glove requirement. This interpretation is for the short term, until the new labels are in the field.

This will resolve the long-standing problem of fumigation tarp shovelers, and others without liquid contact potential, being prohibited from wearing cloth or leather gloves to protect their hands from cold and physical abrasion. For handlers without liquid contact potential, gloves made of leather or fiber (cloth) are not expected to trap fumigants in contact with the skin. Allowing these workers to use cloth or leather gloves will be more protective from cold or physical abrasion when working with shovels, wrenches, and other tools.

DPR will be revising inspection procedures in Compendium Volume 4, Inspection Procedures, to allow handlers (those without fumigant liquid contact potential) to wear cloth or leather gloves, but still prohibit wearing chemical resistant gloves. Inspectors should interpret the current labeling prohibition for handlers with no liquid contact potential to mean prohibiting only the use of chemical resistant gloves, but allowing cloth or leather gloves. DPR will allow this interpretation and will not consider it a violation or noncompliance.

We expect that this short-term solution will provide greater protection for workers until the new label restrictions and clarifications are on the California pesticide product labels. As always, if you have any questions, please contact the Enforcement Branch Liaison assigned to your county.

Original Signature by: 
George Farnsworth
Chief, Enforcement Branch


cc:        Mr. Tom Babb, DPR Agricultural Commissioner Liaison
             Ms. Fabiola Estrada, U.S. EPA Project Officer
             Enforcement Branch Liaisons

1001 I Street  ·   P.O. Box 4015  ·  Sacramento, California 95812-4015  ·
A Department of the California Environmental Protection Agency