SUMMARY
Current proposed US Environmental Protection Agency (EPA) Re-registration Eligibility
Decisions for fumigants, including chloropicrin, metam potassium, metam sodium and methyl
bromide, will cripple vegetable production in Georgia. The adoption of these regulations in
Georgia vegetable plasticulture production, at a minimum, would 1) reduce farmer income by
$20.94 million or 15.3% of their total income; 2) reduce sales value or output impact by $73.13
million; 3) reduce labor income by $35.1 million; and 4) would eliminate at least 775 workers.
In bareground vegetable production, these proposed regulations would completely eliminate
fumigant use. Similar reductions in farmer income, labor income, loss of jobs and loss of
fumigate use will also occur in Georgia’s fruit production (peach, blueberry, & strawberry).
The EPA’s objective to make fumigation safe for workers and bystanders is a goal that we share
and value; however, this objective can be achieved in the absence of these overly restrictive
regulations. Realistically, Georgia fruit and vegetable growers that depend upon these fumigants
for crop production will have only two options if these regulations are passed into law: 1) going
out of business or 2) keep producing their crops following current practices while ignoring the
law assuming fumigant manufacturers, distributors, and applicators are able to remain in
business in light of the additional operating cost burden and reduction in fumigate demand
resulting if these rules are implemented.
Proposed regulations are developed from fumigant emission studies that were conducted using
cultural practices common for the application of methyl bromide. As methyl bromide is being
removed from the market place, alternative systems are being adopted that utilize different and
often more intense management practices requiring that fumigation applicators understand soil
texture, soil moisture, soil temperature, and soil compaction . Research from 2008 shows that
cultural and management practices have a tremendous impact on fumigant emissions (often a
reduction of over 50%). Reduced fumigant emissions indicate increased fumigant retention,
which would likely improve pest control. Improved pest control should lead to reduced fumigant
rates with time. Adopting these practices would be extremely economical for the grower and
effective at protecting agricultural workers and bystanders from fumigant exposure. These
results are in stark contrast to the impact that the proposed EPA regulations would have on
fumigant use and vegetable production in the United States.
In light of the changes in cultural practices, coupled with the on-going research focusing on
mitigating fumigant gas emissions by using soil texture, soil moisture, soil temperature and soil
compaction, the Georgia Fruit and Vegetable Growers Association (GFVGA) and The
University of Georgia (UGA) are requesting changes be made to the proposed regulations.
Regulations that are of concern include the following: 1) buffer zones distances to homes or
occupied structures; 2) right-of-way buffer zones distances; 3) buffer zones adjacent to field
areas treated the previous day; 4) respiratory requirements for handlers; 5) warning zones; 6)
notification of state agency; and 7) and the fumigant management plan. Concerns with these
regulations and potential solutions to these regulations are discussed throughout this document.
The UGA and GFVGA are willing to fully cooperate with the EPA in any means necessary to
obtain or develop research needed by the EPA in an effort to protect agricultural workers and
bystanders while sustaining a vibrant fresh fruit and vegetable industry in Georgia.