Stewardship Plans

• Stewardship Requirements
• Stewardship Plan Criteria
• Stewardship Plans

The Agency has determined it is necessary for all sulfuryl fluoride registrants to submit stewardship plans to EPA for residential structural fumigations. The plans are available on the EPA website and a reference to the plan and annual training must be listed on product labels.

All information regarding sulfuryl fluoride clearance devices is available on the Sulfuryl Fluoride Clearances Devices page.

To submit a stewardship plan to the EPA website, please contact Moana Appleyard ([email protected]).

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Stewardship Requirements

EPA will only list the standard elements of stewardship plans, but individual states will have the responsibility--if they have the capacity--to approve stewardship plans for their state.

1. EPA will publish and maintain a list of basic elements to be included in each sulfuryl fluoride registrant’s stewardship plan on the EPA website.
2. Registrants must submit to the Agency their stewardship plan that includes the generic criteria, which will be listed on the EPA website.
3. States with the capacity to do so will be responsible for reviewing and approving stewardship plans.
4. Sulfuryl fluoride product labels registered for structural applications, where people could occupy or sleep or live, must list the product stewardship plan reference and link, indicating it is available at the EPA website.

The following language must be placed on all sulfuryl fluoride labels:

“[The registrant]’s Product Stewardship Plan that includes EPA’s stewardship plan criteria is available at [link to website]. Applicators and distributors of [product name] must participate in [the registrant’s] product stewardship plan for residential structural fumigations. This plan is also available at [link to website] for [product name].  [Product name] must only be used by application personnel who satisfactorily comply with the [product name] stewardship plan, including the initial and annual training requirements.”

Stewardship Plan Criteria

Training

1. All employees (including owner or licensed employee responsible for managing/supervising the fumigation operations as required by state regulations) who introduce chloropicrin and sulfuryl fluoride, reenter fumigated spaces wearing a self-contained breathing apparatus (SCBA), initiate aeration, and/or conduct final clearance testing must take initial registrant-provided stewardship training before administering, overseeing, or applying the fumigant. This stewardship plan requirement is specific to the use of sulfuryl fluoride and may be beyond the scope of state fumigation requirements. The fumigation company is responsible for training newly hired certified applicators on the content in the initial training. The fumigation company is responsible for requiring all their employees who meet the above criteria to participate in the registrant-provided stewardship training.
2. An objective metric to gauge individual knowledge and understanding should be incorporated into the training for both the initial and the annual stewardship training. This includes specific guidance for instructors on how to assess knowledge and understanding. The stewardship plan must include a process for what happens if a person does not demonstrate knowledge and understanding.
3. Require an annual recurrent training.

Applicator Training Elements Required to be included as part of the Sulfuryl Fluoride Registrant-Provided Stewardship Training

Persons required to take the training:

• Customers: including any person, partnership, firm, corporation, or other business entity engaged in the business entity that purchase and apply the registrant’s sulfuryl fluoride product.
• In states with a licensing requirement to engage in the business of structural pest control using fumigants, the Customer is the person, partnership, firm, corporation or other business entity having a license or other authorization issued by their respective state for engaging in the business of structural pest control using fumigants.
• In states without a licensing requirement, the Customer is considered the entity purchasing the fumigant from a registrant or its distributor for the purpose of engaging in the business of structural pest control using fumigants.
• Fumigation employees: All employees (including owner or licensed employee responsible for managing/supervising the fumigation operations as required by state regulations) who introduce sulfuryl fluoride, reenter fumigated spaces wearing an SCBA, initiate aeration, and/or conduct final clearance testing.

Timing and Frequency of Training

1. Initial Training:
   1. Initial training must be completed by a company’s fumigation employee prior to the first sale of fumigant to any newly licensed fumigation company.
   2. Initial training must be completed prior to the first sale of fumigant to a licenses fumigation company that has not purchased sulfuryl fluoride fumigant within the past three calendar years.
   3. Attendees must demonstrate knowledge and understanding of the training content to the satisfaction of the registrant’s instructor. 
       
2. Annual Recurrent Training:
   1. Every fumigation employee must complete Annual Training at least once per calendar year and no later than 18 months after the date of the fumigation employee’s prior completion of an Annual Training session.
   2. New fumigation employees must complete Initial Training within 90 days of hire and prior to any role in fumigation. This requirement includes fumigation employees that have transferred from a non-fumigation role into a fumigation role.
   3. Attendees must demonstrate knowledge and understanding of the training content to the satisfaction of the registrant’s instructor.

Training Content - Registrants are responsible for developing product-specific training modules that meet the content requirements below:

1. Initial Training:
   1. Fumigation good practices and requirements
   2. Proper use, handling, and storage of fumigant
   3. Label-required procedures for fumigation
      1. Preparation – including new remote aeration preparation
      2. Sealing
      3. Securing the fumigation site
      4. Posting at the fumigation site
      5. Introduction of chloropicrin warning agent and sulfuryl fluoride
      6. Aeration
      7. Final clearance testing
   4. The proper use and calibration requirements for approved clearance detection devices listed in the [Registrant] product stewardship plan.
   5. The proper use of label-required safety equipment including the self-contained breathing apparatus (SCBA).
   6. Review of the label, manual, Safety Data Sheets, safety procedures, and Stewardship Policy for the registrant’s residential fumigant.
   7. Dosage calculation for the registrant’s residential fumigant.
       
2. Annual Training:
   1. Fumigation good practices and requirements.
   2. Review of the proper use, handling, and care of safety equipment and clearance detection devices.
   3. Review of the labeling and stewardship requirements for worker protection and public safety.
   4. Review of any updates to registrant’s residential fumigant labeling.
   5. Review of any updates to registrant’s residential Stewardship Policy.

Stewardship Plans

Stewardship plans coming soon.